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Hinkley Point C Development Consent Order Application

Report

Doc Ref 3.1October 2011

Consultation Report

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Consultation Report - Introduction | October 2011


CONTENTS

EXECUTIVE SUMMARY

0.1 Overview..........................................................................................................................3

0.2 Structure of the Consultation Report ...............................................................................5

0.3 Consultation Process.......................................................................................................6

0.4 Principal Results from Consultation and EDF Energy Response ....................................7

0.5 Conclusions...................................................................................................................19

CHAPTER ONE

1. INTRODUCTION .............................................................................................................3

1.1 Overview of Consultation Process...................................................................................3

1.2 Legislation and Guidance ..............................................................................................31

1.3 Related Consultation .....................................................................................................61

CHAPTER TWO

2. CONSULTATION PROCESS ..........................................................................................3

2.1 Introduction......................................................................................................................3

2.2 Consultation with the Local Community and the General Public .....................................3

2.3 Consultation with Statutory Consultees .........................................................................75

2.4 Exceptions/Departures ..................................................................................................86

2.5 Next Steps.....................................................................................................................90

CHAPTER THREE

3. RESULTS OF CONSULTATION .....................................................................................6

3.1 Introduction......................................................................................................................6

3.2 Quantitative Results ........................................................................................................7

3.3 Summary of Qualitative Results by Theme....................................................................98

a) Accommodation.............................................................................................................99

b) Transport .....................................................................................................................101

c) Socio-Economics and Procurement ............................................................................104

d) Sustainability ...............................................................................................................113

e) Waste Management ....................................................................................................115

f) Environmental Mitigation .............................................................................................117

g) Health Impact Assessment ..........................................................................................119

h) Environmental Impact Assessment .............................................................................121


2 Consultation Report – Introduction | October 2011


i) Habitats Regulations Assessment ...............................................................................125

j) Hinkley Point C Development Site...............................................................................127

k) Hinkley Point C Development Site Environmental .......................................................129

l) On-site Accommodation Campus ................................................................................133

n) Cannington Bypass .....................................................................................................138

o) Combwich....................................................................................................................141

p) Williton.........................................................................................................................143

q) Bridgwater A ................................................................................................................145

r) Bridgwater C................................................................................................................147

s) M5, Junction 23 ...........................................................................................................149

t) M5, Junction 24 ...........................................................................................................151

u) Planning Strategy ........................................................................................................153

v) Consultation.................................................................................................................159

w) Issues Beyond the Scope of the Consultation .............................................................161

3.4 Qualitative Summary of Workshops and Focus Groups ..............................................162

CHAPTER FOUR

4. INFORMAL SUPPLEMENTARY ENGAGEMENT...........................................................3

4.1 Introduction......................................................................................................................3

4.2 Overarching Consultation with the Joint Local Authorities ...............................................6

4.3 Local Authority Work Streams .........................................................................................9

4.4 Engagement with Regulators.........................................................................................27

4.5 Statutory Consultees .....................................................................................................29

4.6 Emergency Services and Local Authorities Group ........................................................60

4.7 Health Impact Assessment and Associated Engagement .............................................64

4.8 Habitats Regulations Assessment .................................................................................67

4.9 Engagement with Landowners ......................................................................................74

4.10 Non-statutory Consultees/Stakeholders ........................................................................80

4.11 Engagement with the Local Community, Parish Councils and Other Local Representatives.............................................................................................................91

4.12 Business and Supply Chain Stakeholders...................................................................103

4.13 Telephone Surveys......................................................................................................108

CHAPTER FIVE

5. CONSULTEE RESPONSE ANALYSIS ...........................................................................3

5.1 Introduction......................................................................................................................3




5.2 Qualitative Analysis Methodology – Schedule of Responses ..........................................4

5.3 Public Reference Tracking System..................................................................................9

5.4 External Surveys, Petitions and Standard Campaign Letters ........................................10

5.5 Response Sources ........................................................................................................11

CHAPTER SIX

6. CONCLUSION.................................................................................................................3

6.1 The Consultation Process................................................................................................3

6.2 Consultation Compliance.................................................................................................3

6.3 Evolution of the Hinkley Point C Proposals......................................................................4

6.4 End Note..........................................................................................................................6

APPENDICES

APPENDIX A: PRESS NOTICES AND RELATED DOCUMENTS A.1 Siting of New Nuclear Power Station Advert (Pre-Stage 1) ...............................................

A.2 SOCC Advertisement (Stage 1).........................................................................................

A.3 Consultation Strategy (Stage 2).........................................................................................

A.4 SOCC Advertisement (Stage 2).........................................................................................

A.5 EDF Energy Response to Local Authority Comments .......................................................

A.6 Consultation Strategy (Stage 2 Update) ............................................................................

A.7 SOCC Advertisement (Stage 2 Update) ............................................................................

A.8 Consultation Strategy (Stage J24).....................................................................................

A.9 SOCC Advertisement (J24 and Highways)........................................................................

A.10 Section 48 Advertisement (Stage 2) ..................................................................................

A.11 Section 48 Advertisement (Stage 2 Update)......................................................................

A.12 Section 48 Advertisement (J24 and Highways) .................................................................

A.13 Letter to IPC (Stage 1).......................................................................................................

A.14 Letter to IPC (Stage 2).......................................................................................................

A.15 Letter to IPC (Stage 2 Update) ..........................................................................................

A.16 Letter to IPC (Junction 24 and Highways Improvements)..................................................

APPENDIX B: CONSULTATION REPORTS B.1 Public Consultation Statement (Pre-Stage 1) ....................................................................

B.2 Stage 1 Consultation Report: Summary ............................................................................

B.3 Stage 1 Consultation Report..............................................................................................




B.4 Temporary Jetty Development Consultation Report ..........................................................

B.5 Site Preparation Works Consultation Report .....................................................................

APPENDIX C: CONSULTATION MATERIALS C.1 Advertisement (Pre-Stage 1) .............................................................................................

C.2 Advertisement November 2009 (Stage 1) .........................................................................

C.3 Poster for Additional Exhibition (Stage 1) ..........................................................................

C.4 Advertisement June 2010 (Stage 2) ..................................................................................

C.5 Advertisement August 2010 (Stage 2)...............................................................................

C.6 Poster for Somerset County Council Staff (Stage 2) .........................................................

C.7 Advertisement July 2011 (J24 and Highways)...................................................................

C.8 Questionnaire (Pre-Stage 1)..............................................................................................

C.9 Questionnaire (Stage 1) ....................................................................................................

C.10 Questionnaire (Stage 2) ....................................................................................................

C.11 Questionnaire (Stage 2 Update)........................................................................................

C.12 Questionnaire (J24 and Highways)....................................................................................

C.13 Exhibition Exit Survey (Stage 1) ........................................................................................

C.14 Exhibition Exit Survey (Stage 2) ........................................................................................

C.15 Tourist Survey (Stage 2)....................................................................................................

C.16 Newsletter October 2008...................................................................................................

C.17 Newsletter December 2008 ...............................................................................................

C.18 Newsletter April 2009 ........................................................................................................

C.19 Newsletter July 2009 .........................................................................................................

C.20 Newsletter October 2009...................................................................................................

C.21 Newsletter November 2009 ...............................................................................................

C.22 Newsletter March 2010......................................................................................................

C.23 Newsletter June 2010........................................................................................................


C.25 Newsletter November 2010 ...............................................................................................

C.26 Newsletter Early February 2011 ........................................................................................

C.27 Newsletter Late February 2011 .........................................................................................

C.28 Newsletter April/May 2011.................................................................................................

C.29 Newsletter June 2011........................................................................................................


C.31 Exhibition Boards (Pre-Stage 1) ........................................................................................

C.32 Exhibition Boards (Stage 1)...............................................................................................




C.33 Exhibition Boards (Stage 2)...............................................................................................

C.34 Exhibition Boards (Stage 2 Update) ..................................................................................

C.35 Exhibition Boards (J24 and Highways) ..............................................................................

C.36 Letter Re Questionnaire Error (Stage 1)............................................................................

C.37 Letter to Stockmoor Residents (Stage 2)...........................................................................

C.38 Initial Proposals and Options Summary Document (Stage 1)............................................

C.39 Preferred Proposals: Summary (Stage 2)..........................................................................

C.40 Preferred Proposals: Summary (Stage 2) - Chinese .........................................................

C.41 Preferred Proposals: Summary (Stage 2) - Polish.............................................................

C.42 Preferred Proposals: Summary (Stage 2) - Bengali...........................................................

C.43 Preferred Proposals: Summary (Stage 2) – Portuguese ...................................................

C.44 Preferred Proposals: Navigation Document (Stage 2).......................................................

C.45 Preferred Proposals: Environmental Appraisal Summary (Stage 2) ..................................

C.46 Changes to the Preferred Proposals (Stage 2 Update) .....................................................

C.47 Changes to the Preferred Proposals (Stage 2 Update) - Bengali ......................................

C.48 Changes to the Preferred Proposals (Stage 2 Update) - Chinese.....................................

C.49 Changes to the Preferred Proposals (Stage 2 Update) - Polish ........................................

C.50 Changes to the Preferred Proposals (Stage 2 Update) - Portuguese................................

C.51 Proposed Changes to the Preferred Proposals, including M5 Junction 24 and Highway Improvements in the Bridgwater Area (J24).................................................

C.52 Young Advisors Consultation Report – Minehead (April 2011)..........................................

C.53 Young Advisors Consultation Report – Bridgwater (June 2011)........................................

C.54 Overview of Numbers Engaged at Each Stage of Consultation.........................................

C.55 Community Forum Minutes................................................................................................

C.56 Transport Forum Minutes ..................................................................................................

C.57 Main Site Neighbourhood Forum Minutes .........................................................................

C.58 Press Releases .................................................................................................................

APPENDIX D: THIRD PARTY PETITIONS, QUESTIONNAIRES AND CAMPAIGN LETTERS D.1 Cannington Parish Council Questionnaire (Stage 1) .........................................................

D.2 Cannington Parish Council Questionnaire (Stage 2) .........................................................

D.3 Otterhampton Parish Council Questionnaire (Stage 2)......................................................

D.4 Save Cannington Action Group Petition (Stage 1).............................................................

D.5 Stop Hinkley Petition (Stage 1)..........................................................................................

D.6 Stop Hinkley Standard Petition (Stage 2) ..........................................................................

D.7 Equestrian Community Petition (Stage 2)..........................................................................




D.8 J24 Campaign Letter (J24 and Highways).........................................................................

D.9 Williton Residents Survey (Stage 1) ..................................................................................

APPENDIX E: ADDITIONAL OPINION GATHERING E.1 Mitigation and Property Price Support Scheme Questionnaire..........................................

E.2 Mitigation and Property Price Support Scheme Details .....................................................

E.3 Mitigation and Property Price Support Scheme Consultation Letter ..................................

E.4 Main Site Neighbourhood Support Scheme Document .....................................................

E.5 ICM Poll October 2010 ......................................................................................................

E.6 ICM Poll April 2011............................................................................................................

APPENDIX F: FOCUS GROUPS AND STAKEHOLDER WORKSHOPS

F.1 Bridgwater Unemployed Focus Group Minutes (Stage 2) .................................................

F.2 Accommodation Providers Focus Group Minutes (Stage 2) ..............................................

F.3 Working Parents Focus Group Minutes (Stage 2) .............................................................

F.4 Somerset REC Focus Group (Stage 2) .............................................................................

F.5 Bridgwater Stakeholder Workshop Minutes (Stage 2) .......................................................

F.6 Taunton Stakeholder Workshop Minutes (Stage 2) ...........................................................

F.7 Weston-super-Mare Stakeholder Workshop Minutes (Stage 2).........................................

F.8 Minehead Stakeholder Workshop Minutes (Stage 2) ........................................................

F.9 Vale of Glamorgan Stakeholder Workshop Minutes (Stage 2) ..........................................

F.10 Cannington Stakeholder Workshop Minutes (Stage 1)......................................................

F.11 Minehead Stakeholder Workshop Minutes (Stage 1) ........................................................

F.12 Taunton Stakeholder Workshop Minutes (Stage 1) ...........................................................

F.13 Vale of Glamorgan Stakeholder Workshop Minutes (Stage 1) ..........................................

F.14 Weston-super-Mare Stakeholder Workshop Minutes (Stage 1).........................................

APPENDIX G: LIST OF SECTION 42 CONSULTEES AND OTHER RELEVANT STAKEHOLDERS

G.1 List of bodies consulted at each stage by reference to the appropriate part of Section 42......................................................................................................................

APPENDIX H: CONSULTEE RESPONSE ANALYSIS

H.1 Schedule of Responses.....................................................................................................

H.2 Consultee Comment Key...................................................................................................

H.3 Schedule of Responses Framework..................................................................................


EXECUTIVE SUMMARY



Consultation Report – Executive Summary | October 2011 1


CONTENTS

EXECUTIVE SUMMARY..............................................................................................................3

0.1 Overview..........................................................................................................................3

0.2 Structure of the Consultation Report ...............................................................................5

0.3 Consultation Process.......................................................................................................6

0.4 Principal Results from Consultation and EDF Energy Response ....................................7

0.5 Conclusions...................................................................................................................19


2 Consultation Report – Executive Summary | October 2011


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EXECUTIVE SUMMARY

0.1 Overview

0.1.1 This Consultation Report is intended to fulfil the requirements of Section 37 of the Planning Act 2008. This requires EDF Energy to provide a consultation report to accompany the application for a development consent order which gives details of the consultation activities that have been carried out, the relevant responses and how these have been taken into account.

0.1.2 A fundamental principle of the approach set out in the Planning Act 2008 is that the applicant has a duty to consult on proposals before they are submitted to the Infrastructure Planning Commission. EDF Energy has embraced this principle throughout its engagement with local authorities and other statutory bodies, with the local community, and with the general public.

0.1.3 EDF Energy’s corporate values include Openness and Transparency, and the Company intends to play a leading role in building trust in the nuclear sector and to educate people about the role of nuclear in the energy mix. Ongoing activities include invitations to visit power stations, public speaking events, public and stakeholder workshops and other communications activity.

0.1.4 EDF Energy first announced its intention to nominate land at Hinkley Point as potentially suitable for the development of a new nuclear power station, and sought views on the scope of the Environmental Impact Assessment, in autumn 2008. Recognising that the proposed development would be a large and complex Nationally Significant Infrastructure Project, a multi-stage approach to consultation was adopted. This allowed meaningful input to the development of the final proposals, which are the subject of the Development Consent Order (DCO) application.

0.1.5 The overall approach to consultation was initially set out formally in a Statement of Community Consultation (SoCC) published in November 2009. This was updated to reflect the scope of each stage of consultation.

0.1.6 The guiding philosophy has been to encourage a genuine two-way dialogue recognising the need for a long-term relationship with local communities based on transparency and trust during the planning, construction and the 60-year operational life of Hinkley Point C.

0.1.7 With a project of this importance, scale and complexity, EDF Energy has inevitably not been able to satisfy everyone with its proposals. But it has presented and explained the proposed development, changed some aspects of its plans as a direct result of consultation and explained why it has not been possible to change other aspects requested by consultees.




0.1.8 Throughout the consultation period, EDF Energy has widely and actively publicised its activities to raise awareness within the local community and to encourage active engagement by as many people as possible. As well as advertising and holding public events, where EDF Energy specialists have been available, newsletters have been widely distributed within the areas potentially affected by the development when there was significant progress to report. A dedicated consultation website has also been maintained to provide access to relevant documentation. The nature and the scale of the development means that there has been considerable media interest in the project, with extensive coverage in print, broadcast and online media.

0.1.9 The first stage of formal consultation set out initial proposals and options, and took place between November 2009 and January 2010. This took place at a relatively early stage in formulating proposals in respect of associated developments in particular, allowing for meaningful consultation at a point at which there was significant scope for shaping the proposals.

0.1.10 The second stage of formal consultation set out preferred proposals for development, and ran from July to October 2010. This provided further details of the proposals and preliminary environmental information, taking account of feedback from the first stage of consultation and eliminating some initial options.

0.1.11 This was followed up by two supplementary consultations on specific aspects of the proposals as development work progressed and new information became available, as well as reflecting the views from consultees. These supplementary formal consultations took place in February/March and July/August 2011.

0.1.12 In addition to formal consultation activities, EDF Energy has held numerous meetings with local authorities, statutory bodies, local organisations and community groups. All of these meetings provided valuable input and contributed to the development of the final proposals.

0.1.13 Over almost two years of formal consultation activities, a very large number of individual comments have been received, some particularly extensive and detailed comments from a number of the statutory bodies and other relevant organisations (under Section 42 of the Act); from local communities living in the vicinity of the site (Section 47); and from the general public (Section 48). This Consultation Report provides a breakdown of the responses received as well as providing EDF Energy’s response to the consultation.

0.1.14 The proposals have been directly shaped by the feedback received and a number of material changes have been made, which are outlined in this report.

0.1.15 During the formal consultation stages alone, which took place within the period November 2009 to August 2011, EDF Energy directly engaged with 6,480 consultees, held 34 public exhibitions, attended 67 meetings with local authorities and other stakeholder groups, and attracted 109,000 unique visitors to its project website. This does not include the large amount of informal engagement undertaken up to submission of this application.




0.1.16 This, and other consultation and engagement activity, prompted more than 2,000 responses, out of which almost 33,000 comments were processed. These comments were organised into 23 overarching themes, which were sub-divided into 225 categories and further broken down into more than 1,200 topics requiring a response from EDF Energy.

0.1.17 EDF Energy is very grateful to all those that have taken the time to engage in the consultation process and provide their views.

0.2 Structure of the Consultation Report

0.2.1 Chapter 1 of the report provides an overview of the consultation process and the legislative background as set out in the Planning Act 2008. This is followed by references to relevant guidance from the Department for Communities and Local Government (CLG) and the Infrastructure Planning Commission (IPC) and other bodies. Chapter 1 also provides details of other consultations which may be relevant to the Hinkley Point C Project.

0.2.2 Chapter 2 describes the consultation process in detail, with separate sections

covering the definition and scope of consultation with the local community, and with those statutory bodies that were required to be consulted. Chapter 2 also details where and why there have been occasional departures from IPC, CLG or local authority guidance in the approach to or scope of consultation. This chapter also explains the next steps in terms of the IPC consideration of the application, and how EDF Energy proposes to make documentation available and keep the local community informed.

0.2.3 Chapter 3 sets out the responses to each stage of consultation, and provides a summary analysis of the responses to identify the main themes emerging from consultation, and the geographical distribution of responses. A qualitative summary of the response to consultation is provided, broken down into 23 themes which address the impacts of the development in a structured way. For each theme, EDF Energy has set out how it has addressed the issues raised in formulating the final proposals.

0.2.4 Chapter 4 describes informal engagement activities which have been undertaken in addition to the formal consultations required under the Act, and also gives the results of opinion polls carried out to provide supplementary evidence and to inform the consultation process.

0.2.5 Chapter 5 provides an explanation of the methodology used in carrying out the qualitative analysis of responses, and of the recording and tracking system which allows individual comments to be tracked through the process to identify whether the proposals have changed as a results of comments made, along with the EDF Energy response. This chapter also explains how comments from organisations not covered by the requirements of the Planning Act have been treated.

0.2.6 Chapter 6 gives overall conclusions on the pre-application consultation.




0.2.7 Appendices to the consultation report are also provided. These are listed in the

contents, and provide copies of relevant documents published elsewhere as part of the consultation process, reports from workshops and other events as well as a complete schedule of all comments received. It should be noted that these schedules are very large documents.

0.3 Consultation Process

0.3.1 EDF Energy’s pre-application consultation complied with legal requirements and guidance as set out in the Planning Act 2008, supplementary guidance from the IPC, particularly ‘Guidance Note 1 on Pre-Application Stages’ (revised August 2011), the CLG’s ‘Guidance on pre-application consultation’ (September 2009), HM Government Code of Practice on Consultation and the Statements of Community Involvement (SCI) from the three local authorities (West Somerset Council, Sedgemoor District Council and Somerset County Council).

0.3.2 At each stage, EDF Energy published a Statement of Community Consultation (SoCC) having consulted the local authorities and having had prior regard to their comments. The SoCC included details of the proposals, the planning process and how EDF Energy proposed to consult with the local community. For the second and subsequent SoCCs, a consultation strategy document was also prepared to support each SoCC and provide further information.

0.3.3 EDF Energy had regard to other consultations relevant to proposals for Hinkley Point C. These included the Government’s consultations on draft National Policy Statements for energy infrastructure, National Grid’s consultation on the Hinkley Point C connection project, and Sedgemoor District Council’s consultation on its draft Core Strategy. In addition, there have been other related consultations, including West Somerset Council’s two rounds of consultation on EDF Energy’s planning application for site preparation works, consultation by the Marine Management Organisation on EDF Energy’s application for a Harbour Empowerment Order in respect of a temporary jetty at Hinkley Point, and the Environment Agency’s consultations on EDF Energy’s environmental permit applications. As part of EDF Energy’s transparency and openness initiative, the environmental permit applications and its Nuclear Site Licence application to the Office for Nuclear Regulation were publicised and uploaded to EDF Energy’s Hinkley Point C project website (www.edfenergyconsultation.info).

0.3.4 EDF Energy consulted on preliminary works applications for Hinkley Point C during Stage 1 and Stage 2, as well as informal consultation in the intervening period. This consultation was combined with the formal DCO application consultation stages due to its close relationship with the overall Hinkley Point C Project and to minimise any potential confusion or consultation fatigue.




0.3.5 EDF Energy is required, under section 47 of the Act, to consult people living in the vicinity of the land it proposes to develop, both at Hinkley Point C and other land further away that may be required for associated development. In order to fulfil this duty, EDF Energy consulted people in three broad consultation zones. The most intensive public consultation was within the ‘inner zone’, which included people within a five-mile radius of the proposed Hinkley Point C Development Site and, for Stage 2, Stage 2 Update and Junction 24 and Highway Improvements consultations, those within 0.5 miles of associated development proposals.

0.3.6 EDF Energy undertook formal consultation in line with the commitments set out in the SoCC for each stage of consultation. EDF Energy used a wide variety of consultation tools to ensure everyone interested in the proposals had the opportunity to participate. These consultation tools included: media relations; advertisements; community newsletters; stakeholder and public meetings; public exhibitions; proposal summary documents; community, transport and development site neighbourhood forums; focus groups; workshops; and a project website.

0.3.7 Throughout the consultation process, EDF Energy used questionnaires as one of the routes for the local community and general public to feed back their views on the proposals for Hinkley Point C and associated developments. At Stages 1 and 2 of the consultation, the questionnaires contained a mixture of specific questions and comments boxes to generate qualitative and quantitative responses. For the supplementary Stage 2 consultations, themed comment boxes were provided.

0.3.8 EDF Energy utilised similar consultation tools to consult with statutory consultees, including landowners, in accordance with Section 42 of the Act.

0.3.9 EDF Energy also undertook extensive engagement and informal consultation with local communities and key stakeholders outside the formal consultation process. This included drop-in sessions in respect of site investigative works, home visits and meetings with local residents and representatives of stakeholder groups at EDF Energy’s Bridgwater office.

0.4 Principal Results from Consultation and EDF Energy Response

0.4.1 EDF Energy has considered all the responses received to consultation, many of which have led to real improvements to the overall proposals, through identfying alternatives which have lower environmental or community impact. The consultation also helped identify issues of most concern to those living in the vicinity of the proposed development, and wherever possible EDF Energy has sought to provide mitigation of the impacts.

0.4.2 There are some aspects of this sizeable project for which full mitigation of impacts is not possible, and there is clearly limited scope to alter the fundamental design of the power station, which is driven by engineering requirements for an efficient and reliable plant which will meet safety, security and environmental standards. In addition, comments received express conflicting views in many cases. In these circumstances, the views do not “cancel out”, but a judgement has to be made on the overall balance of impacts. Wherever possible, EDF Energy has explained how this judgement has been made.




a) Accommodation

0.4.3 The impact on the local housing market of an influx of temporary construction workers and permanent staff for operations was a key issue in response to consultation. Availability of affordable housing, and potential adverse impacts on the local tourist industry were also identified as important issues, in particular by the local authorities. Respondents to consultation were also concerned about the impact of temporary accommodation on the character of the areas in which such facilities were proposed, and the potential for anti-social behaviour. Some respondents welcomed the opportunities that would be created to provide temporary accommodation for construction workers.

0.4.4 EDF Energy has significantly revised its accommodation proposals. This reflects further analysis of existing capacity and overall requirements, and in response to comments on both the location and type of temporary accommodation. In particular, the number of sites at which temporary accommodation is proposed has been reduced (from six to three), and each site will have associated amenities such as sports pitches which can be made available to local residents. Comments on the overall design have been reflected into the masterplans, and considerable attention has been given to measures to mitigate any adverse impacts on the local landscape, through provision of additional screening and design changes.

b) Transport

0.4.5 The need to move large quantities of construction materials and equipment, as well as to allow construction workers to travel to the HPC site efficiently, is an essential element of the Project. The additional traffic inevitably has impacts, given the rural location of the site and the limited capacity of the existing transport infrastructure. Detailed analysis has been undertaken to devise a solution which is sustainable and provides mitigation of adverse impacts. A large number of comments were received throughout the consultation period on transport matters, both from local residents and statutory bodies. Issues raised related to both freight movements and worker transport, and concerns focused on the potential for additional congestion, disturbance and noise, air quality and road safety. Detailed discussions of options and mitigation have been held with the Highways Agency and Somerset County Council (as Highways Authority) regarding road transport, and with other relevant agencies regarding transport by sea and rail.

0.4.6 From the outset, EDF Energy has recognised the importance of an overall integrated approach to transport. The approach aims to minimise the number of HGV movements to the site through use of sea transport directly to the site for bulk materials wherever possible, and to minimise the number of private cars travelling to the site by provision of park and ride facilities at a number of strategic locations.




0.4.7 The initial proposals for transport of materials and workers have been refined in the light of consultation responses. In particular, the scale of park and ride facilities have been revised, with increased capacity at the M5 motorway junction locations, and decreased capacity at Williton and Cannington. Alternative sites at Williton and near Junction 24 of the M5 have been identified, which use brownfield rather than greenfield land. The number and detailed configuration of freight management facilities has been revised, eliminating the need for freight facilities at Williton and Cannington. Use of the wharf at Combwich is a key element of the transport infrastructure, facilitating the delivery of abnormal and indivisible loads. The proposal for a temporary jetty has been retained throughout the consultation phase, and has met with general support. In response to comments received, EDF Energy has proposed and consulted on a number of highway improvements.

0.4.8 Many respondents to consultation on transport issues felt that a new road from the M5 north of Bridgwater to connect with the A39 west of Cannington should be a pre-requisite for allowing the development. EDF Energy considered this option but has not accepted that such a road is necessary or justified, as long as other measures to mitigate transport impacts are implemented. These include a bypass to the west of Cannington, traffic calming measures within Cannington, and a number of highway and junction improvements within Bridgwater and on the main route to the development site.

c) Socio-economics and Procurement

0.4.9 The Hinkley Point C development is a very large construction project, and will have socio-economic impacts locally, regionally, nationally and internationally. The benefits of the development, through generating economic activity during construction and operation, will be substantial. Within the locality of the development, there will be beneficial and adverse socio-economic impacts associated with the influx of construction workers. A wide range of comments were received on the socio-economic impacts, with some local residents expressing concern over the potential for anti-social behaviour caused by construction workers. Local businesses and business groups have recognised the potential opportunities, and education and skills providers have commented on the importance of preparing well in advance if local employment opportunities are to be maximised. The local authorities in particular have made detailed comments on the potential impacts and the importance of a comprehensive mitigation package to help the local and regional economy, and to support education, skills and employment opportunities and ensure that local services are able to meet increased demands.




0.4.10 EDF Energy has worked closely with local authorities, the emergency services, education providers and business groups in the development of a set of proposals which can be included in Planning Obligations. These include substantial investments in the local colleges to enable them to provide courses and training in the skills needed by the Project. Financial contributions are proposed towards policing and other emergency services, as well as addressing potential additional requirements for local schools and to provide additional leisure facilities in the locality. For residents close to the main Hinkley Point C Development Site, voluntary schemes are proposed to provide mitigation against noise impacts, and to protect property values for those who want to move home. A substantial Housing Fund is proposed to mitigate impacts on the local housing market. In addition, a Community Fund is proposed that would be locally administered to mitigate residual impacts.

d) Sustainability Strategy

0.4.11 EDF Energy’s vision for HPC is that the development, operation and ultimate decommissioning of the power station will be undertaken in a manner consistent with the highest standards of safety, reliability and sustainability. A Sustainability Evaluation report was published as part of the Stage 2 consultation.

0.4.12 Sustainability is a broad issue, and a number of comments were made on EDF Energy’s Sustainability Evaluation report, published along with the Stage 2 consultation on the preferred proposals, and on the general issue of sustainability. These have informed the development of the proposals and mitigation measures against likely impacts.

0.4.13 EDF Energy has prepared a Sustainability Statement, building on the Sustainability Evaluation and the responses to consultation. It takes account of updated information from the Environmental Impact Assessment, socio-economic studies and additional detail on the scheme design, and is aligned with the vision referred to above.

e) Waste Management Strategy

0.4.14 A number of consultees sought further information regarding EDF Energy’s waste management strategy for conventional (i.e. non-radioactive) waste, and this has been discussed further with the relevant local authorities. Use of the waste hierarchy will be adhered to in the construction, operation and ultimate decommissioning of the power station.

0.4.15 A waste management implementation strategy has been produced which sets out predictions of the waste volumes that would arise throughout the life of the Project, and how the waste hierarchy would be applied in practice to ensure waste minimisation and to maximise re-use of unavoidable waste arisings. EDF Energy will set demanding targets for re-use, recycling or recovery of construction, demolition and engineering-related wastes.




0.4.16 Disposal routes for waste would be selected to achieve the most sustainable outcome, and measures would be adopted to minimise vehicle movements associated with waste transport. Contractors would be offered incentives to achieve key waste management goals. Inevitably, there would be some waste to be disposed of to landfill, and if the development proposals are approved all off-site disposal would be to licensed sites. The peak for waste production is likely to be in the post-construction reinstatement phase, and waste management methods would be reviewed prior to the start of this phase of work.

f) Environmental Mitigation Strategy

0.4.17 EDF Energy set out its vision for the Hinkley Point C Project in its Stage 2 consultation. As part of that vision, and as required by regulation, if the development proposals are approved EDF Energy will ensure that any significant adverse effects of the construction, operation or decommissioning of the power station are appropriately managed or mitigated in ways which are environmentally responsible and sensitive both to the needs of the community and to the strategies of the relevant authorities.

0.4.18 Detailed comments on EDF Energy’s proposals for environmental mitigation were received from the statutory bodies responsible for environmental protection, and from other interested bodies and specialist groups. A best practice approach to environmental impact assessment, including identification of likely significant impacts and mitigation measures, has been adopted. The methodology used is set out in detail in the Environmental Statement submitted with this application for development consent. Further discussions were held with the relevant statutory bodies and other interest groups on the proposed mitigation measures, and the overall mitigation strategy. EDF Energy also responded to concerns raised by local residents in relation to potential impacts, particularly during the construction phase, and made significant changes to the construction area boundary and its landscaping.

g) Health Impact Assessment

0.4.19 A Health Impact Appraisal was published as part of the Stage 2 consultation. This considered the potential health effects (both positive and negative) of the Hinkley Point C Development Site and off-site associated developments on the local population, the extent of these effects and proposed mitigation for adverse effects. In response to consultation, the health authorities sought a more detailed Health Impact Assessment in support of the DCO application. A number of local residents expressed concerns over the risk to human health from radiological releases (both authorised and accidental releases) from power station operations and from interim storage of spent fuel and radioactive waste. Concerns over potential increased incidence of of leukaemia or other cancers in the neighbourhood of nuclear facilities were also raised.




0.4.20 EDF Energy undertook further work on health impacts, and has provided a more detailed Health Impact Assessment as part of the DCO application. The safety of the proposed Hinkley Point C power station, including the associated fuel store, will be assessed by the Office for Nuclear Regulation, and a licence to construct and operate will be conditional on the proposals complying with strict regulatory requirements, and a demonstration of compliance with their Safety Assessment Principles. Radioactive discharge, combustion and water discharge permits are the responsibility of the Environment Agency (EA), and separate permit applications have been made to the EA, which will have carried out its own consultation on permit applications.

h) Environmental Impact Assessment

0.4.21 Extensive preliminary environmental information was provided as part of the Stage 2 consultation. This covered all the topic areas that are required for an Environmental Impact Assessment (EIA) under the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (SI 2009/2263). The process of EIA is iterative, building up layers of data and taking account of responses and input from the local community, the general public and statutory bodies. Statutory bodies in general felt that, notwithstanding the extensive information provided, further details would be needed in a number of areas before they could be satisfied that all significant impacts had been correctly assessed and adequate mitigation measures proposed.

0.4.22 EDF Energy engaged early with statutory bodies, and has continued to consult formally and informally in preparing its application documents and in particular the Environmental Statement (ES). The ES submitted with the DCO application takes account of comments received throughout the consultation process, and will be made available by the IPC as part of its examination process post-submission.

i) Habitats Regulation Assessment

0.4.23 A key aspect of preparing a Habitats Regulation Assessment (HRA) is effective engagement and consultation with the relevant statutory bodies, in particular Natural England, Environment Agency, Countryside Council for Wales and the Marine Management Organisation. EDF Energy has been in consultation with these bodies since 2008 to ensure that a full understanding of the baseline is established, to discuss the design and location of infrastructure and to identify appropriate means of mitigating impacts.

0.4.24 As a result of the dialogue with statutory bodies and comments received during the formal stages of the consultation process, a detailed assessment of impacts on habitats, including iteration on design proposals, has taken place with the various authorities and expert groups, and an HRA report compiled. The main habitats interest in Bridgwater Bay are the bird assemblages, coral and marine vegetation and fish populations. As a result, a number of specific measures will be implemented to ensure that the integrity of the designated features is unlikely to be affected. These include a system to deter fish from entering the cooling water intakes, and a fish recovery and return system. The principal terrestrial interest is the use of parts of the Hinkley Point C site by Barbastelle bats, and a package of mitigation measures has been agreed.




j) Hinkley Point C Development Site

0.4.25 There is limited scope for changes to the overall design of the power station, which is driven primarily by engineering, safety and other regulatory requirements. This is recognised in the responses to EDF Energy’s consultation, which tended to focus mainly on the potential impacts during construction from noise, traffic and visual intrusion on the landscape. Comments were made about the rationale and justification for carrying out site preparations works in advance of receiving development consent.

0.4.26 Significant changes have been made to the construction site and its impacts on the local community in response to views expressed throughout the consultation period. In particular, material changes have been made to improve the landscaping at the southern and western boundaries of the development site, and the limit of the main construction area has been moved further north, away from residential properties in Shurton. Further details have been developed of the emergency access road, and changes have been made to the development boundary to accommodate access road changes and security requirements for a vehicle search area.

k) Hinkley Point C Development Site Environmental Topics

0.4.27 As noted above in the section on Environmental Impact Assessment, EDF Energy presented extensive preliminary environmental information with the Stage 2 consultation. Detailed comments were received from statutory bodies regarding a range of environmental topics. The principal issues raised were potential adverse impacts of cooling water intake and discharge, impacts on European protected species including bats that may use the development area for feeding and roosting, impacts on the local badger population and loss of habitat. In addition, comments were made on loss of archaeological heritage. The majority of public comments related to footpaths, landscape impacts, noise and disturbance.

0.4.28 EDF Energy has worked closely with Natural England, the Environment Agency, English Heritage, the local authorities and other bodies in developing its proposals for mitigation of adverse impacts on the environment. Careful consideration has been given to providing alternative public rights of way to mitigate for the loss of footpaths, and methods have been agreed to record and display any archaelogical finds that would otherwise be permanently lost. Other proposals include measures to relocate badgers and provide alternative roosts and feeding habitats for bats. A system will be provided for returning fish to the sea that are inadvertently taken into the cooling water intake.

l) On-site Accommodation Campus

0.4.29 The provision of an accommodation campus for construction workers at the Hinkley Point C site is a key element of EDF Energy’s accommodation strategy, minimising impacts on the local accommodation market and reducing local traffic movements. The initial proposals envisaged accommodation for up to 700, along with amenities, at the southern end of the construction area. These proposals were strongly opposed by most local residents, who were concerned about noise and disturbance, and potential anti-social behaviour. Proposals for on-site accommodation were supported by many living further afield.




0.4.30 In response to consultation, EDF Energy significantly revised its proposals for on-site accommodation, reducing the number of bedspaces to 510, reducing the size and moving the location of the campus and associated car parking further from the nearest properties, developing a Worker Code of Conduct, and introducing further landscaping to reduce the visual impact of the campus area. In addition, sports facilities will be accessible to local residents if the development proposals are approved.

m) Cannington

0.4.31 Proposals for associated developments at Cannington have been substantially revised through the consultation period, responding to issues raised by local residents and some statutory consultees. In its initial proposals, EDF Energy proposed an accommodation campus for up to 320 people, as well as park and ride and freight management facilities. There was strong opposition to the campus, park and ride and freight management facilities in many consultation responses. Local residents felt strongly that the scale of development could significantly alter the character of the village.

0.4.32 EDF Energy responded to the consultation and reconsidered and revised its requirements, in particular to focus temporary accommodation campuses at the Hinkley Point Development Site and in Bridgwater, and to only locate freight management facilities near to Junction 23 and 24 of the M5 motorway. The park and ride facility at Cannington has been reduced in size to 252 spaces, and the layout and access arrangements improved.

n) Cannington Bypass

0.4.33 Two initial options (to the east and west of the village) were presented at Stage 1 consultation for a Cannington bypass, to divert much of the construction traffic away from the village and provide a lasting legacy. There was a split of views expressed in response to consultation as to which option was preferred. Although most respondents supported the need for a bypass, many called for a Bridgwater bypass, linking the M5 to the A39 west of Cannington (see section on Transport).

0.4.34 In its Stage 2 consultation, EDF Energy presented the western route as its preferred option, as it is shorter, would have less environmental impact and there are fewer residential properties in close proximity. In response to consultation, a large number of detailed comments were received on the proposed route and the intersections with existing rights of way. These have led to improvements in the design and alignment of the road, farm access, screening and landscaping provisions and environmental measures to provide wildlife corridors and habitats. To complement the bypass proposal, traffic calming measures would be introduced in Cannington.




o) Combwich

0.4.35 Proposals for the upgrading and refurbishment of the existing wharf at Combwich, to be used for abnormal indivisible loads, met with broad support in response to Stage 1 consultation. The advantages of waterborne transport were widely recognised, and EDF Energy provided further detail of proposals at Stage 2 for use of nearby land as a temporary laydown area and for unspecified fabrication facilities. Local residents were very concerned about the scale of these facilities and the potential adverse impact through noise and disturbance, and increased traffic. Concerns were also expressed about flood risk and potential environmental impacts.

0.4.36 Significant changes have been made in response to views expressed on EDF Energy’s Stage 2 consultation on its preferred proposals. In particular, the overall size of the laydown area has been reduced, and proposals for a fabrication facility at Combwich have been dropped. Further measures have been proposed to provide flood protection and mitigation of noise and visual impact. Restrictions on operating hours for the laydown area will also be applied.

p) Williton

0.4.37 In its initial proposals, EDF Energy proposed both a workers’ accommodation campus and a park and ride facility at Williton. The campus proposals were strongly opposed in responses received to the consultation, and there was also some opposition to the park and ride proposal, with concern expressed over its location, the impact on traffic congestion in the local area, and on the road network between Williton and Hinkley Point.

0.4.38 EDF Energy reviewed whether an accommodation campus at Williton was required, and presented proposals for a park and ride facility only at Stage 2 to the west of Williton. This proposal was further revised, reducing the size of the facility in response to views expressed during consultation and in light of more detailed modelling of traffic flows. This also allowed the opportunity to make use of an existing site some two kilometres to the west of Williton, rather than using greenfield land.

q) Bridgwater A

0.4.39 The former Innovia site in north-east Bridgwater was proposed by EDF Energy as a potential location for provision of temporary accommodation for workers during the construction phase of the project. In response to consultation, there was general support for redevelopment of the site for this purpose, although some concerns were expressed about potentially adverse impacts on the local community through the influx of temporary construction workers and loss of amenities such as sports pitches. There was also a desire that any development of temporary accommodation should be sustainable and consistent with the North East Bridgwater Masterplan.




0.4.40 EDF Energy has refined its proposals for the Bridgwater A site, and optimised the number of bedspaces to meet expected demand for temporary accommodation in Bridgwater and in response to comments on the scale of development. The proposals have also been aligned as far as possible to facilitate future development of the North East Bridgwater Masterplan and to incorporate the provision of alternative sports pitches in an area accessible to the general public. EDF Energy has also proposed making specific contributions to local services and community provisions by way of mitigation against potentially adverse impacts arising from the influx of construction workers.

r) Bridgwater C

0.4.41 The proposed site for workers’ accommodation to the east of the town is on the training pitch of Bridgwater and Albion Rugby Football Club. Use of this site has been generally supported in responses to consultation, as long as consideration is given to future legacy use.

0.4.42 The preferred proposals are to provide accommodation for up to 150 people, and to share amenity facilities, for example catering and leisure with those to be provided at Bridgwater A. Once the campus is no longer needed for construction workers, it could be made available for student accommodation or other facilities associated with the nearby Bridgwater College site.

s) Junction 23

0.4.43 EDF Energy’s initial Stage 1 proposals identified two possible sites near Junction 23 of the M5 for the provision of both freight management and park and ride facilities. The principle of providing these facilities in this area was generally supported in responses to consultation by both public and some statutory consultees. The preferred site, on land near Dunball Wharf, is convenient for the M5 junction to the north of Bridgwater and is in an area already used for commercial premises. Responses to consultation also raised the issue of potential future legacy use.

0.4.44 The size of the facility has been revised in the light of further analysis and responses to consultation, with EDF Energy increasing the number of parking spaces from 750 in the initial proposals to 1,300 and providing 85 HGV holding spaces. Taking account of response to consultation, further consideration has been given to drainage and flood risk assessment, and additional landscaping treatment has been incorporated. A range of potential legacy uses for the site may be possible once construction is complete, for example to provide a park and ride facility for Bridgwater.




t) Junction 24

0.4.45 EDF Energy’s initial proposals considered three possible sites for locating a park and ride and freight management facility close to Junction 24 of the M5. The principle of providing park and ride facilities in this area was generally supported in responses to consultation, although there was limited public support for a freight management facility at this location. Taking account of these responses and more detailed investigation, the preferred proposals identified a site to the west of the A38 and close to Stockmoor village. Concerns were expressed in public responses to consultation (mainly from residents local to the site) over the potential noise, disturbance and additional traffic impacts of the use of this site.

0.4.46 Provision of park and ride and freight management facilities at this motorway junction is an important element of the overall transport strategy. An opportunity arose in mid-2011, after the Stage 2 Update consultation, to take advantage of an existing site on the Huntworth Business Park which currently provides warehousing, car and HGV parking and which had become available. Proposals for use of this alternative site were consulted on in July-August 2011, and have been generally preferred to the use of the greenfield site to the west of the A38. This site, which has now been selected in preference, has the further advantage that it can be made available for use early in the construction programme, and could be released for further commercial use when construction is complete.

u) Planning Strategy

0.4.47 Throughout the consultation period, comments were made by both statutory consultees and others on EDF Energy’s strategic approach to planning for Hinkley Point C. A number of comments related to the relevance of national policy, reflecting the parallel process of developing National Policy Statements (NPS) for Energy Infrastructure by the Government. Some respondents noted that the NPS does not specifically address the requirements for associated development, and emphasised the importance of creating a legacy of lasting benefits for the local area. Other comments questioned how EDF Energy’s proposals took account of local planning policies. There has been extensive comment from and engagement with local planning authorities in relation to providing mitigation against significant adverse impacts which cannot be avoided.

0.4.48 EDF Energy has set out its vision for the project, which has guided the overall planning strategy. Under this vision, EDF Energy would ensure that any significant adverse effects of the power station and associated developments are mitigated in a way that is environmentally responsible and sensitive to the needs of the local community. A Planning Statement which sets out details of EDF Energy’s approach to national and local policies accompanies the application for a Development Consent Order to the IPC (the DCO application).

0.4.49 As the NPS for nuclear power generation has been designated, this now provides the definitive position in relation to Government policy on the need for nuclear, and the potential suitability of Hinkley Point as a site for new nuclear development. The NPS makes clear that, for a nationally significant infrastructure project, the NPS prevails if there is a conflict with other planning policy documents.




0.4.50 EDF Energy’s approach to planning has been to maximise the inherent benefits of the Project, and the design of associated developments has been primarily to meet the needs of the project and mitigate likely impacts, while having regard to potential future use. The process of consultation has informed the details of the proposed mitigation measures, which are described in the draft Requirements and Obligations document which accompany the DCO application.

v) Consultation

0.4.51 The consultation programme for this project, in line with the requirements of the Planning Act 2008, has been wide-ranging, comprehensive and carried out over an extended period. There has been active engagement with local authorities and statutory bodies, and detailed responses received from members of the public as well as those bodies that have an obligation to respond. The local authorities have made full use of the arrangements under a Planning Performance Agreement with EDF Energy to engage specialist consultants and provide thorough analysis of proposals at each stage.

0.4.52 EDF Energy took account of feedback from the local authorities in the design of the consultation activities, and also commissioned independent surveys to obtain views on the public events that were held, and on the project more generally. The views of the local authorities were helpful in both designing the consultation and identifying the most appropriate locations for public-facing events.

0.4.53 Independent surveys showed that the overwhelming majority of visitors to the public exhibitions found the information provided through exhibition boards to be useful or very useful and the EDF Energy staff they spoke to to be helpful or very helpful. The majority of visitors also found the other printed materials useful or very useful. In terms of awareness of the consultation, a telephone survey in September 2010 of residents in the three districts most likely to be affected by the proposals (i.e. West Somerset, Sedgemoor and Taunton Deane) found that more than 60% were aware of EDF Energy’s consultation activity. Within 10 miles of Hinkley Point, this rose to approximately 75%. Further details of these surveys are included in Chapter 4 of the Consultation Report.

0.4.54 Inevitably, some respondents sought further detail than could be made available at early stages in the consultation. With such a large and complex project, it is also inevitable that some respondents found it difficult to assimilate all of the information provided within the time available for consultation. EDF Energy has endeavoured to provide information in an accessible way, with different levels of detail appropriate for public and statutory consultees. More detail has been provided progressively through the consultation stages, as the project definition has been refined. The EDF Energy office in Bridgwater is open to the public and has been available as a point of contact for local people. In addition, telephone and email contact enquiries have been accepted and responded to throughout. There has been widespread acceptance of the use of the internet to provide access to project documentation.




w) Issues Beyond Scope of Consultation

0.4.55 A number of comments were made in response to the consultation that did not relate directly to the planning documents. These included comments on Government policy in respect of nuclear power, comments on transmission lines which are not the subject of this application, comments on the safety of the installation and general comments on EDF Energy.

0.4.56 EDF Energy has reviewed all comments received and, if appropriate, brought these to the attention of the relevant bodies. A summary of the issues which EDF Energy considers to be beyond the scope of the consultation is included within the Consultation Report.

0.5 Conclusions

0.5.1 EDF Energy undertook initial consultations on its proposals for nuclear power station development at Hinkley Point, and the scope of Environmental Impact Assessment, in autumn 2008. Consultation in advance of submission of an application has therefore taken place over a three-year period, and has focused on those geographical areas where likely impacts would occur. In practice, this has meant that the majority of consultation has been in the county of Somerset, with more detailed and intensive public consultation in the neighbourhood of proposed development sites (for the power station and associated infrastructure), within the districts of West Somerset and Sedgemoor.

0.5.2 As expected for a development of this nature and scale, there has been active engagement from both people living in the vicinity and statutory bodies throughout the consultation period. During the formal stages of the consultation process, which took place between November 2009 and August 2011, there has been engagement with some 6,480 consultees, EDF Energy has held 34 public exhibitions and organised 67 meetings with local authorities and other stakeholder groups. Assimilating and responding to all of the comments made has proven to be a major exercise in its own right, and has provided both practical improvements and robust challenge to EDF Energy’s proposals for development.

0.5.3 This consultation report is intended to fulfil the requirements of section 37 of the Planning Act 2008 (and related statutory guidance), to provide a report to the Infrastructure Planning Commission that gives details of the consultation activities that have been undertaken, the responses received, and how EDF Energy has taken account of any relevant responses. Where changes have been made to the proposals as a result of the responses to consultation, these have been explained. Where responses to consultation have suggested an alternative approach and no material changes have been made to the proposals, the reasons for not making changes have been also explained.


CHAPTER 1: INTRODUCTION



CONTENTS

1. INTRODUCTION.............................................................................................................3

1.1 Overview of Consultation Process...................................................................................3

1.2 Legislation and Guidance ..............................................................................................31

1.3 Related Consultation .....................................................................................................61

TABLES Table 1.1: Consultation Liaison with Local Authorities on SoCC1..............................................10

Table 1.2: Consultation Liaison with Local Authorities on SoCC1 – Part 2 ................................13

Table 1.3: Consultation Liaison with Local Authorities on SoCC2..............................................17



Table 1.6: Compliance with Consultation Requirements............................................................38

Table 1.7: Planning Policy Consultations (November 2009 to current) ......................................68

Table 1.8: Planning Applications/Other Project Consultations (November 2009 to current) ......73

FIGURES Figure 1.1: Hinkley Point C Formal Consultation Chronology ......................................................5

Consultation Report - Introduction | October 2011 1



1. INTRODUCTION

1.0.0 This chapter provides an overview of the consultation process that EDF Energy carried out in relation to its proposals for a new nuclear power station at Hinkley Point C and associated development (the HPC Project). It also explains the steps taken by EDF Energy to comply with the legal requirements and guidance on pre-application consultation. Finally, it outlines the content and timing of other consultations that are relevant to the HPC Project.

1.1 Overview of Consultation Process

1.1.1 EDF Energy has undertaken a multi-stage consultation on its proposals for a new nuclear power station at Hinkley Point and associated development over nearly a three-year period from 2008 to 2011. Further details are provided in Chapters 2 and 4 of this report.

a) Early Engagement

1.1.2 Prior to the launch of its formal consultation under the Planning Act 2008 (the Act), EDF Energy commenced a process of informal engagement from 2008 with key statutory consultees, the local community and other interested parties. This provided EDF Energy with valuable feedback on key issues and options to be considered when preparing the proposals. It also informed the approach to be taken to formal consultation and provided information to assist stakeholder mapping.

1.1.3 Prior to the acquisition of British Energy by EDF Energy in January 2009, both companies consulted separately, but largely concurrently, on outline proposals for new nuclear development at Hinkley Point. Both consultations took place during the autumn of 2008 in the context of:

the Government’s Strategic Siting Assessment (SSA) and the requirement to nominate potential sites for new nuclear development; and

the requirement to define the scope of the Environmental Impact Assessment (EIA) scoping consultation for new nuclear development at Hinkley Point.

1.1.4 At the joint request of West Somerset and Sedgemoor District councils (WSC and SDC respectively), EDF Energy and British Energy agreed to co-ordinate their consultation activities and events and tried to ensure that a consistent message was delivered to the general public to avoid confusion. At the time, EDF Energy and British Energy remained separate and competing companies and their respective consultation programmes in autumn 2008 were therefore branded separately.

1.1.5 Details of EDF Energy’s consultation programme, the comments received and EDF Energy’s response to these were set out in a Public Consultation Statement (PCS) entitled ‘EDF Energy: Plans for New Nuclear Development at Hinkley Point’, published in January 2009 (See Appendix B).




1.1.6 The PCS formed part of the documentation submitted to the Government when EDF Energy (following acquisition of British Energy) formally nominated Hinkley Point C into the Government’s SSA for new nuclear power development in March 2009. It was also submitted to the three relevant Somerset local authorities (WSC, SDC and Somerset County Council (SCC)). In addition, a letter was circulated widely to stakeholders and community groups who had commented during the consultation process (including relevant parish/town councils), which provided a web link to the published PCS on EDF Energy’s project website, www.edfconsultation.info. The address of the project website was changed to www.edfenergyconsultation.info in October 2010.

b) Formal Consultation

1.1.7 Pre-application consultation is a legal requirement for Nationally Significant Infrastructure Projects (NSIPs) under the Act. Each stage of EDF Energy’s local community consultation was carried out in accordance with a separate Statement of Community Consultation (SoCC), consistent with section 47 of the Act. Prior to publishing each SoCC, EDF Energy consulted the relevant local authorities about its content, as explained further below.

1.1.8 EDF Energy undertook pre-application consultation activities as follows:

Stage 1: ‘Initial Proposals and Options’. 16 November 2009 –18 January 2010. This set out EDF Energy’s broad plans for the new nuclear power station and associated development, identifying initial options on which EDF Energy was seeking views.

Stage 2: ‘Preferred Proposals’. 9 July – 4 October 2010. This described EDF Energy’s ‘preferred proposals’ following review of the Stage 1 consultation responses and further investigation/studies.

Stage 2 Update: ‘Update on and Proposed Changes to the Preferred Proposals’. 25 February – 28 March 2011. This supplemented earlier consultations, giving people an opportunity to comment on material changes to EDF Energy’s plans.

Junction 24 and Highways Improvements consultation: ‘Proposed Changes to the Preferred Proposals including M5 Junction 24 and Highway Improvements in the Bridgwater Area’. 1 July – 12 August 2011. This supplemented earlier consultations, giving people an opportunity to comment on further specific material changes to EDF Energy’s plans.

1.1.9 The chronology of the formal consultation process is set out at Figure 1.1. Further information is provided in Chapter 2 of this report. The preparation of the SoCCs is explained further below.




Figure 1.1: Hinkley Point C Formal Consultation Chronology




1.1.10 At Stage 1, the consultation with statutory bodies under section 42 of the Act ran concurrently with consultation with the local community under section 47 of the Act. In accordance with guidance on multi-stage consultation, EDF Energy did not publicise the proposed application under section 48 of the Act until the start of Stage 2. For Stages 2 and 2 Update, consultation with statutory bodies, the local community and the general public was run concurrently. For the Junction 24 and Highways Improvements consultation, informal consultation with the local community began at the same time as the start of the formal consultation with statutory bodies and the general public. However, the formal consultation with the local community began two weeks later. This was to allow sufficient time for EDF Energy to consult with, and have regard to the responses from, the local authorities in respect of the content of the revised SoCC.

1.1.11 During the consultation exercise, EDF Energy invited comments on:

proposals for the main power station development at Hinkley Point C;

associated development to support the construction and operation of the power station; and

dealing with the potential impacts on, and benefits for, the local community and local area.

1.1.12 At Stage 1, EDF Energy outlined its initial proposals and invited comments on a number of options, including:

the number of bed spaces and locations of worker accommodation campuses;

the number of parking spaces and locations of park and ride facilities for workers;

the location of freight management facilities; and

the bypass options for Cannington.

1.1.13 This stage helped EDF Energy to understand better the needs and aspirations of the communities most likely to be affected by its plans for the Hinkley Point C Project, as well as the expectations of consultees.

1.1.14 Stage 2 gave consultees the opportunity to comment on more specific and detailed proposals. More information was available as a result of ongoing research and investigations, and as a result of feedback and analysis of comments received at Stage 1 of the consultation. A suite of documents in support of this consultation was made available to statutory consultees, other relevant stakeholders, the local community and the general public. One of those documents was an interim, 325-page consultation report, which summarised comments received at Stage 1 and outlined EDF Energy’s response to issues raised. This Stage 1 Consultation Report can be found at Appendix B.

1.1.15 The Stage 2 Update consultation was limited to material changes being proposed to the Project in response to feedback and ongoing detailed studies, such as the size or location of the various associated development sites. These were changes that EDF Energy considered it appropriate to consult on following Stage 2. They included any




changes that could result in new or significantly different impacts on people living in the vicinity of any of the proposed development sites. Due to the relatively limited scope of this stage of the consultation, EDF Energy decided not to publish an interim consultation report responding to all of the issues raised at Stage 2. Instead, EDF Energy made clear that it would provide a comprehensive overview of all issues raised during the entire consultation process, together with details of the responses to each issue, in this consultation report document.

1.1.16 The Junction 24 and Highways Improvements consultation was limited to material changes being proposed to the plans for a park and ride and freight management facility near Junction 24 of the M5 and further highway improvements in the Bridgwater area. The need for this additional consultation arose because a new potential site emerged for a park and ride and freight management facility near Junction 24, known as the Somerfield site, and as a result of further detailed work being undertaken on highway issues. Again, owing to the limited scope of this stage of the consultation, EDF Energy decided not to publish an interim consultation report.

1.1.17 EDF Energy’s original SoCC published in November 2009 set out three geographical zones within which consultation on plans for Hinkley Point C would be undertaken. These were:

Inner Zone: within approximately a five-mile radius of Hinkley Point C, including the West Somerset parishes of Holford, Kilve, Stogursey and Stringston, and within Sedgemoor District the parishes of Cannington, Fiddington, Nether Stowey, Otterhampton and Stockland Bristol.

Middle Zone: encompassed by Burnham-on-Sea in the north, the M5 to the east (but including Puriton), south of Bridgwater and along the Quantock Hills as far as Williton/Watchet.

Outer Zone: stretching around Taunton to the south, Minehead to the west, Weston-super-Mare to the north and to the west of the M5.

1.1.18 In addition to these zones of local community consultation, EDF Energy’s original SoCC undertook to consult, under section 42 of the Act, all local authorities with a boundary adjoining the three Somerset local authorities, plus Bristol City Council, South Gloucestershire Council and the Vale of Glamorgan Council.

1.1.19 The justification for these geographical consulation zones was based on the following:

ensuring the most intense consultation activity was undertaken in the communities most directly affected by development proposals and where there would be obvious direct, physical impacts – i.e. the inner zone;

recognising the considerable indirect impacts on communities further afield from Hinkley Point C in terms of, for example, economic development opportunities, impact on the tourist industry, potential health concerns and increased levels of traffic – i.e. the middle and outer zones; and

accepting that there could be long-distance indirect impacts on communities further afield including, for example, in visual terms from the coast of south Wales




and long-distance commuting and indirect economic impacts in the case of Bristol and South Gloucestershire.

1.1.20 These zones were discussed and agreed with the three Somerset local authorities as part of the consultation on the original SoCC. During the Stage 1 consultation process, those living within the inner zone received newsletters via post and had the most opportunities to attend public consultation events. Those living in the middle zone were sent newsletters via solus distribution through local newspapers (which normally has a lower level of household penetration than postal deliveries) and had fewer public consultation events. In the outer zone, consultation was mainly targeted towards key community stakeholders rather than direct to the general public.

1.1.21 EDF Energy decided that from Stage 2 the consultation zones should be extended so that the inner zone, where consultation was most intense, covered residents living in the vicinity of all the possible associated development sites, as well as the Hinkley Point C Development Site.

1.1.22 The revised inner zone therefore covered: approximately a five-mile radius of the Hinkley Point C site (covering the West Somerset parishes of Holford, Kilve, Stogursey, and Stringston, the Sedgemoor parishes of Cannington, Fiddington, Nether Stowey, Otterhampton and Stockland Bristol); and a half-mile radius of the potential associated development sites. Within the inner zone, newsletters were distributed by post, exhibitions were held close to every location where there might be development and home visits, residents meetings and drop-in surgeries were held, as appropriate. In the middle zone there were exhibitions at key locations, such as Minehead, while in the outer zone mainly stakeholder consultation was undertaken as before. The details are set out in the SoCCs in Appendix A.

1.1.23 Proposals for consulting with local authorities were unchanged from the original SoCC, which provided a map detailing the authorities to be consulted (see Appendix A).

1.1.24 At each stage of consultation, EDF Energy held a series of well-publicised public exhibitions at different locations potentially affected by the proposals being consulted upon. Consultation materials, including consultation documents and questionnaires, were made available at the exhibitions, and newsletters explaining the consultation process were distributed widely within the affected local communities in advance. The consultation material was also available to view online at the project website www.edfenergyconsultation.info, and in hard copy at EDF Energy’s Bridgwater office, relevant council offices, tourist information centres and local libraries. This consultation material included exhibition boards, the relevant consultation documents, maps and other leaflets. More information can be found in Chapter 2 of this report.

1.1.25 The comments received at each stage of the consultation were recorded, analysed and used to inform the evolution of the proposals. The analysed comments received at each stage are included in Appendix H. Consultees can track their comments, see the decision made in relation to them and read EDF Energy’s response. Comments made by organisations are arranged by name, while comments made by individuals can be tracked by an individual reference number. Further details of the




methodology behind EDF Energy’s consultation response analysis are given in Chapter 5 of this report.

c) Consultation on the Statement of Community Consultation

1.1.26 EDF Energy has prepared, consulted upon and published four separate versions of its SoCC during the pre-application consultation period, relating to the four separate phases of consultation.

1.1.27 Consultation on each of the SoCCs has been undertaken with the three local authorities within whose boundaries development is proposed (SCC, WSC and SDC) under the Act. This section of the report explains the consultation that took place in relation to each of the SoCCs and describes how EDF Energy has had regard to the views of the local authorities in preparing the final, published versions.

i. SoCC1: Plans for Nuclear New Build at Hinkley Point, November 2009

1.1.28 The first SoCC was published in November 2009 and guided EDF Energy’s Stage 1 consultation on ‘Initial Proposals and Options for Hinkley Point C’. Informal and formal consultation on the SoCC took place over two separate periods – during the spring/summer of 2009 and then again during the autumn, before SoCC1 was published in November 2009.

1.1.29 Stage 1 SoCC advertisements with details of the public consultation process were placed in the week commencing 16 November 2009 in the following weekly newspapers: Bridgwater Mercury (17 November), Burnham and Highbridge News (17 November), Somerset County Gazette (19 November), Bridgwater Times (19 November), and West Somerset Free Press (20 November).

1.1.30 Rather than publishing SoCC1 following formal consultation with the local authorities in the summer of 2009, EDF Energy decided to consult again on a revised SoCC incorporating a two-stage consultation process before publishing SoCC1.

1.1.31 The two stages of consultation were as a result of the Department for Communities and Local Government (CLG) publishing final guidance on pre-application public consultation under the Act in early September 2009 (see further below). This strengthened advice to promoters about the merits of undertaking a multi-stage process of pre-application consultation in respect of large developments.

1.1.32 The sequence of events in terms of informal and formal consultation on the draft SoCC1 during the spring and summer of 2009 was as follows:

informal discussion of draft SoCC with officers of the three Somerset local authorities at a meeting on 16 June 2009;

formal consultation with the local authorities on the draft SoCC, and with Planning Aid South West at the suggestion of the local authorities, from 3 July to 14 August 2009;

joint response received from the three local authorities and a separate response from Planning Aid South West at the end of August 2009, to which EDF Energy replied on 22 September 2009; and




decision taken by EDF Energy in September 2009 to issue a revised draft SoCC for further consultation with the local authorities and Planning Aid South West.

1.1.33 The key points made by the local authorities and Planning Aid South West at the end of the first round of formal consultation on the draft SoCC, and EDF Energy’s response to these points at the time, are summarised in the table below:

Table 1.1: Consultation Liaison with Local Authorities on SoCC1

Summary of Key Comments Made by Local Authorities/Planning Aid South West on Draft SoCC1

Summary of EDF Energy’s Response to these Comments

Joint response by Somerset County, Sedgemoor District and West Somerset councils, September 2009

More detail should be provided on the nature of the development and its likely impacts.

Some of the points raised by the local authorities should more appropriately be made in the Proposal Summary Document (PSD) to accompany the Stage 1 consultation process rather than in the SoCC itself.

Include a basic description of an European Pressurised Reactor, with links to websites for further information, indicate size of the project, cross refer to the Planning Performance Agreement and include glossary of terms.

Agreed to include website links in the SoCC – other suggestions more appropriate to be included in the PSD.

Refer to other major consultations affecting the Somerset coast.

Relevant consultations to be included in an appendix to the SoCC.

EDF Energy’s consultation should be undertaken after the Government has consulted on its draft 'National Policy Statement for Nuclear Power Generation (EN-6)' (draft Nuclear NPS) to avoid public confusion.

This is EDF Energy’s intention but the company must reserve the right to undertake consultation in advance of publication of the draft Nuclear NPS in the event that the Government’s timing slips.

Explain in more detail what the public is being consulted about.

Detail should be included in the PSD rather than the SoCC itself.

Scale and framework of community benefits should be set out clearly.

Detail of possible community benefits will be outlined in the PSD rather than the SoCC but examples will be referenced in the SoCC.

Infrastructure improvements should include IT investments and wider socio-economic benefits

Point noted and considered relevant for inclusion in the PSD rather than the SoCC itself.

Options to be considered as part of the consultation should be aligned with Environmental Impact Assessment options to avoid confusion, and the local authorities should be given advance notice of them.

Confirmed that options will be aligned with preliminary environmental information and that local authorities will be briefed in advance.

Socio-economic benefits should include procurement and wider economic investment through foreign direct investment.

Reference to potential for inward investment into Somerset to be included in the SoCC as an example of possible socio-economic benefit.

Local teams dealing with the Quantock and Mendip Hills Areas of Outstanding Natural Beauty (AONB), Exmoor National Park, the Somerset Strategic Partnership and other relevant Local Strategic Partnerships should be added to list of those to be consulted.

Agreed to add specific reference, although most of these bodies will be covered by EDF Energy’s requirement to consult with statutory consultees under section 42 of the Act.








Visitors should be consulted, as they are key to the tourism sector.

Agreed and added to the list of consultees in the SoCC.

List of consultees does not refer to hard-to-reach groups.

Hard-to-reach groups are referred to earlier in the document – additional reference to be added.

No reference to how young people will be consulted.

Preliminary consultation has taken place with local colleges – reference will be added to this.

No reference to the need to integrate and co-ordinate proposals with other local investments to play a positive role in place-shaping.

This point will be covered by reference to engaging with Local Strategic Partnerships.

No mention of how EDF Energy will engage with groups outside the key consultation zones – for example on a regional basis – such as Government Office for the South West (GOSW), South West Regional Development Agency (SWRDA), South West councils and leaders’ groups. Issue of inward investment not dealt with.

Most of these groups are covered by EDF Energy’s requirement to consult statutory consultees under section 42 of the Act. Reference will be made to the local inward investment body, Into Somerset, as a key consultee.

EDF Energy should offer to attend council meetings, AONB meetings, Exmoor National Park meetings, Somerset Strategic Partnership meetings and appropriate parish council meetings.

The SoCC makes it clear that EDF Energy will meet with parish councils – reference to be made to offering meetings with other groups mentioned.

Unclear how local authority responses to the consultation will be factored in and dealt with and conflicts resolved.

Not considered to be appropriate for inclusion in the SoCC – this is a matter for the Consultation Report to be prepared for the IPC explaining how EDF Energy has responded to views received from all consultees and how it has resolved such conflicts.

Unclear what the process is to formally include the outcome of all the detailed engagement taking place with the local authorities outside the consultation period with the wider community.

EDF Energy will ensure the SoCC makes it clear that preliminary consultation has already taken place and that consultation will continue beyond the consultation period specified with local authorities, stakeholders and the local community.

Public exhibitions should be held in tourist locations, such as Minehead and Burnham during a peak tourism month, such as August.

This is not possible given proposed timescales. However, EDF Energy will add reference to engaging with tourism stakeholders in relation to the final proposals.

Newsletter could be distributed from council offices and tourism information points.

Agreed.

EDF Energy’s proposed Hinkley Point C Community Forum is supported but thought should be given to its governance and membership.

Issues relating to governance and membership will be discussed at the Forum’s first meeting.

It should be made clear that EDF Energy has a statutory duty to present the results of community consultation to the IPC and that people’s views/opinions will be taken into account.

EDF Energy is satisfied that the wording of the draft SoCC already makes this clear.

Reference should be made to the fact that local authorities will be asked to comment to the IPC on the adequacy of EDF Energy’s consultation.

Agreed and reference to this will be added.






Indicate how you will accommodate people with different working patterns at residents meetings.

Reference made to meetings being held at different times and locations to suit people’s needs.

Contact parish/town councils well in advance with the offer of meetings.

Noted – this is EDF Energy’s normal practice.

Should be reference to the strategic leadership role of the councils and clarification that significant weight will be given to the councils’ views.

Agreed to amend the SoCC to make it clear that the views of the authorities will carry significant weight in the consultation process.

Clarification should be provided on the distribution of the newsletter reporting back on the outcome of the consultation process.

A description of how newsletters will be distributed is already provided in the SoCC.

Concerns about events potentially being held around the time of Christmas holidays.

Timetable is being changed as a result of the move to a two-stage consultation process. Agreed not to hold any specific consultation events during the period 21 December 2009 to 4 January 2010.

Consultations identified that could potentially clash with EDF Energy’s consultation.

A full list of relevant and related consultations will be published in the SoCC.

Specific attention should be paid in the consultation to towns and villages that will bear the brunt of the impacts of EDF Energy’s proposals.

Accepted and the wording of the SoCC will be changed to reflect this.

Response from Planning Aid South West

How will the arrangements differ if the consultation is conducted before publication of the Government’s draft Nuclear NPS?

This is an unlikely and hypothetical situation – if it occurs the framework for consultation set out in the SoCC will remain but the documentation will clarify why consultation is being undertaken in advance of the draft Nuclear NPS.

Wording should be changed to avoid the suggestion that consultation should cover how the socio-economic benefits from the development can be maximised – this is not a function of the planning system.

Agreed and wording changed to reflect this point.

A period of 30 days for the consultation is misleadingly short.

This point is accepted and a realistic period of time will be allowed – the move to a two-stage consultation will help to ensure this.

The SoCC should refer to other planning applications that might be made which are related to the proposals.

The SoCC can only deal with consultation arrangements relating to the main application to the IPC.

The SoCC should cover consultation for any proposed section 106 agreement and for the Environmental Statement (ES).

The SoCC will address all issues required by the Act, including preliminary environmental information.

Working definition of “community” should be widened to cover national community interest groups.

Amended the wording to make it clear that stakeholders will include such groups.

There is little attempt to build the capacity of the community to respond to the consultation, especially in relation to hard-to-reach groups.

Specific reference added to hard-to-reach groups in the list of consultees.






Government guidance on NSIPs recommends that people should be able to put forward their own ideas and have a role in developing proposals and options - not just commenting on formal proposals.

Consultation has been ongoing with the community for some time and much valuable input has already been provided. The move to a two-stage process will help to clarify that EDF Energy will be consulting on a range of development options, alternatives and proposals.

Detail should be provided on ‘innovative’ consultation techniques and there should be less reliance on communication simply by the written word.

EDF Energy will make it clear in the SoCC that consultation methods and other communications tools will not solely rely on the written word.

An advisory group for the consultation should be established including leading members of the community to offer support, advice and guidance on the consultation process.

The EDF Energy Hinkley Point C Community Forum will undertake this role.

There is no contingency for consultation on post-application changes to the proposals or consultation on reserved matters.

The SoCC is specifically concerned with pre-application consultation leading up to submission of DCO application to the IPC. It would not be appropriate to cover post-application consultation or reserved matters in this document.

1.1.34 A revised SoCC, incorporating the changes described above, was issued to the three Somerset local authorities and Planning Aid South West for further formal consultation on 30 September 2009 with a deadline for responses of 29 October 2009. A further joint response was received from the local authorities and comments from Planning Aid South West on 29 October 2009. EDF Energy responded to these additional comments on 6 November 2009 before publishing its SoCC in the Somerset Gazette on 12 November 2009. EDF Energy also suggested a round table meeting with the local authorities and Planning Aid South West to discuss some of the detail of the consultation programme following publication of the SoCC.

1.1.35 The key points made by the local authorities and Planning Aid South West at the end of the second round of formal consultation on the draft SoCC and EDF Energy’s response to these points at the time, as set out in a letter of 6 November 2009 to the local authorities, are summarised in the table below:

Table 1.2: Consultation Liaison with Local Authorities on SoCC1 – Part 2

Summary of Key Comments made by Local Authorities/Planning Aid South West on Revised Draft SoCC1


Joint response by Somerset County, Sedgemoor District and West Somerset District councils, October 2009

Welcome improvements on previous draft but believe there is a lot of detail missing and that a worked-up strategy is preferable to an overview or framework for consultation. Little detail is provided on the role expected of the local authorities.

Much of the information that the local authorities are seeking will be provided in the PSD available for the Stage 1 consultation. A new section will be inserted into the published SoCC highlighting the PSD and how people can obtain a copy.

The SoCC needs to strike a balance between, on the one hand, providing detailed information and,






on the other, giving a flexible framework within which consultation can be undertaken over an extended period, which can also be published in full in a locally-circulated newspaper, as required by the Act.

The level of detail presented within the SoCC should reflect, to some extent, the scale and complexity of the project – more detail should be presented on the initial stages of consultation.

Response as per comments above.

The SoCC should include full details of the description of the project and the proposals for consultation as well as details of venues, times and dates prior to public opening on the exhibitions or presentations to members.

Response as per comments above. All members and stakeholders will be invited to attend consultation events, and EDF Energy feels a briefing at the end of the Stage 1 consultation process would be appropriate to feed back outcomes to members and stakeholders.

Few details of the approach and timing of technical consultation on environment, transport, flooding, etc. are provided. A comprehensive list of stakeholders should be provided including statutory and non-statutory organisations. When will draft chapters of the ES be available?

The published SoCC will be amended to make it clear that technical consultation will be undertaken in parallel with the public consultation and further details given on preliminary environmental information. Otherwise the response as per comments above applies.

There is reference to the fact that the consultation will cover preliminary environmental information but no detail on how EDF Energy intends to consult on this information.

Further information on this is provided in the published SoCC.

There should be an explanation of what a PSD is and a glossary of terms and definitions.

More information is provided on the content and availability of the PSD and all acronyms are explained in the text.

The importance of the Planning Performance Agreement should be emphasised.

We do not believe it is either necessary or appropriate to go into further detail on the Planning Performance Agreement in the SoCC.

There should be more detail on: consultation with local businesses; engagement with tourism/leisure sector; methods used to engage with hard-to-reach groups; and stakeholder engagement with the outer consultation zone.

Consultation has already been undertaken with hard-to-reach groups and the business community, and events are planned in the Stage 2 consultation in the outer consultation zone and with tourism industry/visitors. The round table meeting proposed will help EDF Energy to flesh out the detail of this programme.

No reference in the document to the relationship between this consultation and the councils’ Local Development Framework(s).

EDF Energy will have regard to the Local Development Framework but believes that the primary policy driver for the plans will be the Nuclear NPS and that this is what should be highlighted in the SoCC.

No reference to the Government Office for the South West.

Noted, and reference has been re-inserted in the published SoCC.

Will EDF Energy’s consultation events take place after local consultation on the Government’s draft Nuclear NPS?

Yes, publication of the draft Nuclear NPS and local consultation events will take place before EDF Energy’s Stage 1 consultation on Hinkley Point C.

Document should state that EDF Energy “will” invite views on related community benefits and

Noted and the published SoCC has been changed.






not “may”.

Lack of information on the proposed preliminary works applications to be submitted to the local authorities.

A new section has been added to the published SoCC to deal with this.

Comments from Planning Aid South West, October 2009

Concerned about the timing of the consultation in relation to the draft Nuclear NPS.

All points made by Planning Aid South West have been considered in detail by EDF Energy. Most of these are covered by the responses above or EDF Energy’s earlier response to Planning Aid South West. Any outstanding matters can be dealt with at the round table meeting proposed.

Nothing is said about any planning applications that might be submitted in relation to the plans.

See comments above.

No reference is made to consultation on any proposed section 106 or similar agreement.

See comments above.

No reference is made to building capacity of the community to respond to the consultation.

See comments above.

Disappointed in the earlier response to our point that people should have an opportunity to put forward their own ideas and consider options/alternatives – this should be covered in the SoCC.

See comments above.

SoCC is short of detail of “innovative” consultation techniques to engage with hard-to-reach groups and too dependent upon communications by the written word.

See comments above.

No discussion in the SoCC about the potential use of deliberative mechanisms to involve the community and help to resolve conflicts between different elements of the community – this should be in the terms of reference of the Community Forum.

See comments above.

There should be a commitment that EDF Energy’s newsletter and other communications material will report things objectively and not be used as a public relations vehicle by the promoter. The SoCC should reveal how the consultation process can be externally validated.

See comments above.

Community Forum membership should include representatives of hard-to-reach groups.

See comments above.

The SoCC should include details of proposed consultation post application.

See comments above.

1.1.36 Although a full round table meeting with the local authorities and Planning Aid South West did not take place immediately, EDF Energy representatives subsequently met with SDC/Homes in Sedgemoor on 30 November 2009 and with the Somerset Federation of Equality and Diversity on 13 January 2010, specifically to discuss greater engagement with hard-to-reach groups. These meetings helped to influence the content of the subsequent SoCCs.


1.1.37 A separate letter was also sent to Planning Aid South West on 30 November 2009 explaining EDF Energy’s proposals for engaging with hard-to-reach groups during the Stage 2 consultation process. This letter outlined EDF Energy’s proposals for working with Homes in Sedgemoor and the Somerset Federation of Equality and Diversity and drew attention to the agenda item on engagement with hard-to-reach groups at the EDF Energy Hinkley Point C Community Forum on 10 December 2009.

ii. SoCC2: Stage 2 Consultation Strategy and Revised Statement of Community Consultation, June 2010

1.1.38 EDF Energy took the view that it would be appropriate to prepare, consult on and publish a further SoCC to guide its Stage 2 consultation on its ‘Preferred Proposals for Hinkley Point C’. In response to requests for more detailed information from the local authorities and Planning Aid South West, EDF Energy also decided to publish on the project website a more detailed Consultation Strategy document to underpin SoCC2.

1.1.39 The SoCC2 advertisements, which included details of the initial public exhibitions planned for the Stage 2 ‘Preferred Proposals’ consultation, were placed in the following newspapers in the week commencing 29 June 2010: Bridgwater Mercury (30 June), Somerset County Gazette (2 July) and West Somerset Free Press (3 July).

1.1.40 Informal consultation on the second draft SoCC and the draft Consultation Strategy took place during April and May 2010. Meetings were held with the authorities and Planning Aid South West on 8 April and 28 April 2010 to discuss the content of the SoCC and Consultation Strategy, and a draft of both documents was circulated for informal comment on 4 May 2010. Comments on these informal drafts were received independently from Ove Arup & Partners, on behalf of Sedgemoor and West Somerset Councils, from Somerset County Council and from Planning Aid South West.

1.1.41 On 20 May 2010, the draft Stage 2 Consultation Strategy and draft revised SoCC were sent to the local authorities for formal consultation with comments requested by 18 June 2010. Enclosed with these draft documents was a detailed response from EDF Energy to the comments received during the informal consultation period from the local authorities and Planning Aid South West (see Appendix A).

1.1.42 A formal joint response was received from the local authorities at the close of this consultation period. EDF Energy responded to these comments by letter on 25 June 2010 and the final SoCC and supporting Consultation Strategy were first published on 29 June 2010. The key points raised by the local authorities in the formal consultation period on draft SoCC2 and EDF Energy’s response to these are shown in the table below.





Summary of Key Comments made by Local Authorities on draft SoCC2


Concern that the Stage 1 report on consultation is not being published until the Stage 2 consultation starts – this hinders the local population's consideration of the proposals and the councils' assessment of the adequacy of consultation.

EDF Energy does not agree because:

Releasing the Stage 1 consultation report at an earlier stage could result in uninvited responses to address which could create uncertainty about what exactly EDF Energy has taken into account in preparing its ‘Preferred Proposals’.

There is a distinction between the two stages of the consultation which reassures the public, and other consultees, that EDF Energy is using a well-defined process including a set period in which it has had regard to all consultation responses.

It is accepted practice – which central Government follows – to provide feedback on consultation at the beginning of the next stage of consultation.

The consultation seems to be about an evolving project at a particular point of time and not a draft DCO application. The councils should have access to Stage 2 documentation in advance so that they can respond to enquiries from the community as soon as the consultation begins.

Insufficient time has been given to allow the councils to provide a high-quality, technically robust response, particularly as part of the consultation period covers the peak summer holidays when many people are away and town/parish councils may not have meetings.

This is a two-stage consultation process and is necessarily iterative and evolving. It is quite clear that the consultation is a precursor to an application for a DCO in due course. EDF Energy could not provide documentation earlier, as this would have reduced its time to give due consideration to all parties’ feedback following Stage 1. Relevant council officers had the opportunity to comment while the ‘Preferred Proposals’ were in development.

Stage 2 consultation runs from mid-July until early October 2010 - considerably longer than the statutory period required - to reflect the scale and nature of the proposals and to take account of the summer holiday period. A 12-week period should be more than adequate.

No consultation is planned beyond Stage 2 and prior to submission to the IPC. There will therefore be no opportunity for local communities to fully appreciate how the comments they have given during Stage 2 have influenced the final proposals.

It is EDF Energy’s intention to publicise feedback on Stage 2 consultation at the same time as the application is made for the DCO. The most important requirement for EDF Energy is to have regard to all consultation responses in preparing its application documents. If EDF Energy makes changes to its proposals following Stage 2 which, in its opinion, require a third stage of consultation either generally or on specific matters, it would conduct this.






Summary of Key Comments made by Local Authorities on draft SoCC2


Specific comments raised in relation to the level of engagement with:

Hard-to-reach groups.

Women and younger people via supermarkets.

Focus groups for the unemployed and those not in employment.

Working parents.

Potential workforce and local businesses.

Tourism bodies and tourism visitors.

Secondary schoolchildren.

There should be a clearer definition of community benefit to ensure adequate engagement on this issue.

EDF Energy has considered these comments in detail and will:

Hold additional public events in Minehead and Burnham during August, investigating the possibility of holding these in supermarkets in August.

Approach the various schools suggested to invite them to participate in educational and engagement visits to EDF Energy’s Bridgwater office.

iii. SoCC3: Proposed Changes to the ‘Preferred Proposals’, Consultation Strategy and Revised Statement of Community Consultation, February 2011

1.1.43

aterial changes made to the proposals since the close of the Stage 2 Consultation.

1.1.44

summarises the key issues raised and EDF Energy’s response to these at the time.

1.1.45

merset County Gazette (17 February) and West Somerset Free Press (18 February).

1.1.46 rgy consultation website along with the Consultation

Strategy on 15 February 2011.

As EDF Energy’s ‘Preferred Proposals’ evolved in light of feedback received from the Stage 2 consultation, and as more information had become available as the project developed, it was decided to consult again on the m

A revised SoCC and accompanying Consultation Strategy were therefore prepared to guide this further stage of limited consultation. Given the limited scope of this further consultation, and in view of the extensive earlier consultations in relation to previous SoCCs, EDF Energy did not consult informally with the local authorities but wrote to them with a draft SoCC on 17 December 2010 inviting comments by 20 January 2011. A joint response was received from the local authorities and the table below

As at Stage 2, SoCC advertisements that included details of the public exhibitions planned for the Stage 2 Update consultation were placed in the following newspapers week commencing 14 February 2011: Bridgwater Mercury (15 February), So

The final version of the SoCC was sent to the local authorities on 10 February 2011 and published on the EDF Ene



Summary of Key Comments made by Local Authorities on Draft SoCC3 and Consultation Strategy


The public may find the definition of ‘material changes’ and ‘key stakeholders’ difficult to understand.

Definitions have been inserted into the documents.

The means by which EDF Energy intends to address the concerns of the local community on the previous stage of consultation are unclear and have not been addressed. There should be wider consultation with the local communities on some of the technical detail contained in draft application documentation and the draft ES.

This consultation is not intended to be a response to previous consultations. Responses to all concerns raised at previous stages of the consultation will be dealt with in the Consultation Report. There is no legal requirement to consult the community on draft application documentation or a draft ES at this stage.

Will ‘material changes’ include negotiating solutions and mitigation issues prior to DCO application submission?

The consultation will inform discussions, before submission of the DCO application, of solutions or mitigation in respect of the ‘material changes’.

Although it is appreciated that EDF Energy does not think it necessary to re-consult on the whole project, the opportunity to feed back on other matters will be provided to help ensure the consultation strategy as a whole is thorough and effective.

EDF Energy is pleased that the councils appreciate this is not re-consultation on the project as a whole.

EDF Energy should work with the councils to agree which elements of the changes to the ‘Preferred Proposals’ hold local significance. The consultation should set out where the councils do not support EDF Energy’s proposals.

EDF Energy is consulting on proposed ‘material changes’. Where these are considered to have local significance, EDF Energy believes it is for the councils to make their views clear.

There should be a robust communications strategy to articulate the rationale for the changes – a plain English summary should be widely distributed so it is clear to all who is, and is not, affected by these changes.

EDF Energy believes that there is a robust communications strategy in place. The consultation document itself will be a concise document, written in plain English, with a summary of the proposed changes within it. Reference to this summary of proposed changes will be added to the Consultation Strategy.

The 31-day period for consultation is very limiting, particularly for parish councils who need a reasonable amount of time and advance notice to provide meaningful feedback.

EDF Energy believes a 31-day period for consultation is proportionate given the limited nature of the changes to the ‘Preferred Proposals’ and the earlier publication of the SoCC that will give advance notice of the consultation.

The Councils should have a complete set of the documentation prior to the launch of the consultation to ensure they can respond to public enquiries and have adequate time to review the material.

Documentation will not be available until the start of the consultation but EDF Energy will ensure the councils are aware of exactly what documents will be published. EDF Energy will not be publishing a large volume of material.

Given council committee and scrutiny dates, the consultation period will not be sufficient to allow for a high-quality, technically robust response.

See comments above. It is up to the councils to determine their process in compiling responses. EDF Energy will continue to engage with the councils and other statutory bodies in the lead-up to submission of the DCO application.








The councils request that EDF Energy extend the period of consultation so that drafts of the councils' responses can be provided within the deadline, but will not constitute a formal response until the document has been approved through council and scrutiny processes.

See comments above.

We believe the SoCC’s intention to undertake a comprehensive and targeted engagement programme is, to some extent, undermined by the short timescale for consultation.

See comments above.

It is important that any organisation or individual with an interest in the proposed development is provided with an adequate opportunity to provide further feedback on the changes. The consultation should be publicised to the wider community.

This is EDF Energy’s intention and will be achieved via the newsletter, the project website and via local media coverage and advertising. The SoCC will be amended to make this clearer.

It is important that EDF Energy provide tailored information, including justification, to stakeholders and households where no changes are proposed.

See comment and change to the SoCC above.

It is EDF Energy’s responsibility to approach parish/town councils to establish whether meetings are required and that sufficient time should be allowed for this.

EDF Energy will approach all parish/town councils with the offer of a meeting if required.

We wish to discuss and formally agree with EDF Energy who will need to be consulted as this depends on the changes the company is proposing to make to its ‘Preferred Proposals’.

EDF Energy is consulting across the whole local community in the same way as at Stage 2. This was agreed with the councils at the time and it is, therefore, not considered necessary to agree this again.

Local media should include print, web and broadcast outlets, as well as regional media.

All these media will be covered.

The offer of a translation service and documents in alternative formats and languages should be widely publicised.

It will be in the EDF Energy Hinkley Point C newsletter, on the project website and in media releases.

Adequate access to EDF Energy staff and specialist members of the project team should be provided to the public and organisations to help them respond to the consultation.

EDF Energy agrees this is important and these staff members will be available at public events. The SoCC and Consultation Strategy will be amended to make it clear that public exhibitions will be fully staffed.

EDF Energy should consider what activities it may need to carry out to consult with hard-to-reach groups. To date, engagement with some communities likely to be significantly affected by the project, for example in Bridgwater, has not been sufficient to gain robust community response.

EDF Energy consulted extensively in Stage 2 with hard-to-reach groups through public exhibitions in supermarket car parks and tourist locations, focus groups and surveys. All those who registered an interest at these events will be sent a consultation document and will, therefore, have an opportunity to comment on the proposed changes. EDF Energy considers it would be disproportionate to hold specific events for hard-to-reach groups as EDF Energy is not re-consulting on the project as a whole.






It would be helpful if EDF Energy could publicise related consultations and events on the project website and at exhibitions.

Agreed – this has been made clear in the Consultation Strategy.

EDF Energy should be mindful of the possibility of public confusion with its preliminary works applications.

Agreed – the Consultation Strategy makes it clear that EDF Energy is aware of this issue.

After the close of the consultation and in the lead-up to submission of the DCO application, EDF Energy should hold briefings with the councils, drop-in sessions and targeted mailings to keep local communities informed and to help them understand how their comments have influenced the final proposals.

EDF Energy will consider holding further events and this possibility is already referred to in the Consultation Strategy. Engagement with statutory consultees and council officers will continue.

The local and regional media should be engaged so the general public is signposted to the project website, EDF Energy offices and public exhibitions.

This is EDF Energy’s intention – the point will be added to the Consultation Strategy.

There should be a better description of ‘material changes’.

See comments above.

Further details should be provided on the form and nature of further consultation with statutory consultees.

This is not strictly a matter for the SoCC. The Consultation Strategy makes it clear that EDF Energy will be consulting statutory consultees under section 42 of the Act in parallel with community consultation under section 47.

The Consultation Strategy should refer to key dates in the programme going forward with the proposed submission date for the IPC.

EDF Energy is not in a position to specify key dates going forward including the date of submission of the DCO application. Timing could be affected by the outcome of the consultation or external factors.

EDF Energy should elaborate on how the section 48 publicity requirement will be addressed.

The SoCC and Consultation Strategy relate to section 47. However, reference to section 48 advertising will be added to the Consultation Strategy.

Further clarification should be provided on the statement that EDF Energy will “…give the public and key stakeholders an opportunity to provide feedback on other matters in order to ensure the consultation strategy as a whole is thorough and effective...”

The Stage 2 Update Consultation Document will make it clear exactly what EDF Energy is consulting on. The Consultation Strategy will be amended to make this clearer.

There should be reference to how ongoing consultation before submission of the DCO application will be managed. The councils would like to see reference to the objective of genuinely seeking to listen to local opinions.

At this stage, EDF Energy is committed only to ongoing engagement not to further consultation. We believe that the objectives of the consultation process have been adequately described.

EDF Energy should be clearer in saying that it “will” publish additional information to support the proposed changes and in giving details of what this is.

These points are agreed and EDF Energy will make the appropriate changes in the Consultation Strategy.






There should be an explanation of how material will be sent to households where no changes are proposed and the information sent should explain why no changes are being made.

EDF Energy does not believe it is helpful in this consultation process to provide explanation to sections of the community where no changes are made – this will be dealt with in the Final Consultation Report.

Reference should be included to consultation by the councils on the draft Hinkley Point Nuclear Supplementary Planning Document.

Agreed and EDF Energy has added reference to this in the Consultation Strategy.

EDF Energy should show restraint in communicating the economic benefits of the project as the technical assessments have not been completed.

EDF Energy is unclear why the councils believe that it is communicating economic benefits in an unrestrained fashion. IPC guidance suggests that the SoCC should set out, in broad terms, the benefits and impacts of the proposed development, and EDF Energy believes the draft is factually accurate in this respect.

Reference should be made in the SoCC to the IPC being disbanded and merged into the Planning Inspectorate.

Agreed – reference to this has been added into the SoCC.

References to preliminary environmental information being provided are unclear and vague.

It is not EDF Energy’s intention to release further preliminary environmental information in addition to that which was provided at Stage 2. The Stage 2 Update Consultation Document will discuss the impacts and mitigations arising from proposed changes. We have therefore removed reference to the release of preliminary environmental information from the SoCC.

The SoCC should refer to the specific areas of work – such as accommodation, transportation etc. – that will be subject to the consultation.

This is covered in the Consultation Strategy but EDF Energy will add a cross reference to this in the SoCC.

iv. SoCC 4: Proposed Changes to the Preferred Proposals Including M5 Junction 24 and Highway Improvements in the Bridgwater Area, Consultation Strategy and Revised Statement of Community Consultation, July 2011

1.1.47 The proposals evolved further in light of feedback received and as more information became available. EDF Energy decided to consult again on further material changes proposed since the close of the Stage 2 Update consultation in March 2011.

1.1.48 EDF Energy identified a possible alternative to the site proposed in the Stage 2 and Stage 2 Update consultations for a park and ride and freight management facility near Junction 24 of the M5. In March 2011, the ‘Somerfield’ site, a former distribution and warehouse facility also near Junction 24 of the M5, came onto the property market. EDF Energy concluded that it should consult the local community, statutory consultees and the general public about potentially moving the Junction 24 park and ride and freight management facility to this new site.

1.1.49 In addition and following further discussions with SCC as highway authority, EDF Energy decided to also consult on potential further highway improvements in the Bridgwater area.


1.1.50 A revised SoCC and accompanying Consultation Strategy were therefore prepared to guide this further stage of limited consultation. Given the limited scope of the consultation, and in view of the extensive consultations in relation to previous SoCCs, EDF Energy did not consult informally with the local authorities but sent them a draft SoCC and Consultation Strategy on 13 June 2011 inviting comments by 11 July 2011. A joint response was received from SDC and WSC and a separate response from SCC. The table below summarises the key issues raised by the local authorities in relation to the draft SoCC and Consultation Strategy and EDF Energy’s response to these at the time.

1.1.51 The final versions of the SoCC and Consultation Strategy were sent to the local authorities on 14 July 2011 and published on the same day. SoCC advertisements that included details of the public exhibitions planned for the formal stage of Junction 24 and Highways Improvements consultation were placed in the following newspapers: Somerset Gazette (14 July 2011) and Bridgwater Mercury (19 July 2011).




Response from Somerset County Council, July 2011

Concern at not being consulted informally prior to the drafting of the SoCC.

EDF Energy consulted for 28 days on the draft SoCC prior to its publication as required by the Act. Although there was informal consultation with the local authorities prior to formal consultation on the draft SoCC at Stages 1 and 2, EDF Energy did not think it was either possible or necessary to consult informally on this SoCC because:

It was the fourth SoCC, which largely updated earlier versions which had been subject to extensive informal consultation.

The consultation was limited in scope compared with the Stage 1 and Stage 2 consultations.

There was insufficient time to consult informally if the consultation was going to be carried out prior to the summer holiday period.

The focus of the consultation is on changes around Junction 24 of the M5 and it is not clear how EDF Energy will manage community engagement in relation to potential highway improvements in the Bridgwater area.

The focus of the consultation is on both potential highway improvements in Bridgwater and changes near Junction 24. Two of the three public exhibitions are planned in Bridgwater itself and EDF Energy is managing community engagement in relation to highway improvements in the same way as the proposed Junction 24 changes.








As the changes have partly originated from consultation responses, Somerset County Council requests that the full Stage 2 consultation responses are made available.

EDF Energy has previously made it clear that consultation responses will be published and responded to in the Consultation Report and not during the consultation process.

The main reason for the potential change near Junction 24 is the fact that the Somerfield site has recently come onto the property market. The Consultation Strategy document has been amended to reflect the main reason for this potential change.

Risk of confusion for local residents regarding why there is a ‘formal’ and ‘informal’ consultation process.

Will all comments recorded be given equal weight whether these are within the ‘formal’ or ‘informal’ consultation period?

Will communities receive adequate notice of when ‘informal’ consultation events are taking place as some will be prior to publication of the SoCC?

EDF Energy is aware of the potential for confusion which is why information provided to the public has generally not drawn a distinction between the ‘formal’ and ‘informal’ consultation periods. The period for consultation with the local community and the general public has been advertised as from 1 July until 12 August 2011. The only exception to this is the SoCC advert where, for obvious legal reasons, a distinction has been drawn between the ‘formal’ and ‘informal’ consultation process.

EDF Energy can confirm that all comments recorded will have equal weighting whether they are submitted during the ‘formal’ or ‘informal’ part of this Junction 24 and Highway Improvements consultation.

EDF Energy has ensured that there has been adequate notification of the public exhibitions by advertising these in a newsletter distributed throughout the Bridgwater area, through paid-for advertising in the Bridgwater Mercury and the Somerset Gazette, through local media coverage of the consultation, and by writing to community stakeholders and those who have responded to previous consultations. This information exercise and advertising took place in early July 2011 before the first consultation event.






It is surprising that EDF Energy has chosen to carry out consultation with the councils on the SoCC in parallel and on a different timeframe to the community consultation.

EDF Energy accepts that the approach is different to the previous consultations. It was decided to hold the section 42 consultation between 1 and 29 July 2011 because many statutory bodies do not hold meetings and many key staff are often on leave during the holiday period.

It was not possible to begin the formal section 47 consultation at the same time because EDF Energy was required under section 47 of the Act to consult with, and have regard to responses from, the relevant local authorities in respect of the SoCC. The draft SoCC was sent to the local authorities for comments on 13 June 2011 with a deadline for responses set of 11 July 2011. EDF Energy took the view that, in order to allow time to review comments from the local authorities, the earliest date that the final SoCC could be published was 14 July 2011, with the formal section 47 consultation beginning on 15 July 2011. However, EDF Energy recognised that this coincided with the summer holidays, and therefore decided to hold a period of informal consultation with the local community between 1 July and 14 July 2011 so that members of the community could provide their input before the school holidays began if they so wished.

The council does not understand why the local authorities and other statutory consultees have been given two weeks less to respond than the local community and the general public.

EDF Energy would normally have ensured that consultation with the local community, the general public and statutory consultees would run concurrently. The different timescales for local community and statutory consultation simply reflect the constraints imposed by section 47 of the Act. The section 42 and section 47 consultees will have had exactly the same length of formal consultation (i.e. 28 days), albeit that this consultation started on different dates.

The CLG guidance does make it clear that it may not always be possible for the timescales for formal consultation with communities and technical consultees to be synchronised.

Somerset County Council would like further clarification from EDF Energy on the timescales for the intended submission of the application for development consent and this should be set out in the Consultation Strategy.

At this stage EDF Energy cannot give a precise intended date for submission of the DCO application. The aim is to submit later this year and the Consultation Strategy has been amended to reflect this.






The intention to focus consultation on a 0.5 mile radius seems arbitrary – Somerset County Council recommends that any decision on consultation zones is based on EDF Energy’s previous experience of consultation in the local area.

Since consulting on the draft SoCC, EDF Energy has proposed a number of new and improved highway improvements schemes in the Bridgwater area, and therefore accepts that there should be a wider focus to the consultation.

The programme has therefore been extended to include additional consultation events in the Bridgwater area and reference to the 0.5 mile radius is no longer included.

The Junction 24 and Highways Improvements Consultation Strategy Document and published SoCC have been amended to reflect these changes.

The proposed changes do need to be seen in the wider context of the proposals for a new nuclear power station at Hinkley Point, and Somerset County Council thinks it is very important that any organisation or individual with an interest in the development should be provided with an adequate opportunity to feed back their comments.

EDF Energy agrees, and believes that the revised consultation programme with the wider focus will provide adequate opportunity for everyone to provide feedback, whether or not they live within the vicinity of any of the proposed changes.

EDF Energy should clarify the intended timing of their newsletter. We anticipate that this will land on doorsteps at least one week prior to the first public exhibition.

The newsletter was distributed from 30 June 2011 by post to around 12,300 residential and business addresses, including homes and businesses in the vicinity of the Junction 24 site, to ensure there was adequate notification of the first exhibition held at the Sedgemoor Auction Centre on 11 July 2011.

The solus distribution of the newsletter, covering the whole of Bridgwater, took place between 8 and 9 July 2011 giving adequate notification of the exhibitions in Bridgwater on 16 and 21 July 2011.

Somerset County Council would like to confirm that EDF Energy has also notified local media about the consultation programme and events.

A press release announcing the consultation programme was issued by EDF Energy to local media on 1 July 2011 and there was separate advertising of the consultation events in local newspapers, via the newsletter and on the website. The Consultation Strategy and published SoCC have been amended to reflect this point.

Somerset County Council would like to request prior sight of consultation materials sent to councillors.

EDF Energy has supplied all three Somerset local authorities with advance copies of the Junction 24 and Highways Improvements Consultation Document, newsletter (both 30 June 2011) and press release (1 July 2011) announcing the consultation process.

Somerset County Council requests an extension to the consultation period to 12 August 2011 to allow time for its internal governance processes.

As in previous rounds of consultation, EDF Energy will be flexible where organisations are having genuine difficulty meeting deadlines. However, EDF Energy would be concerned about deadlines for responses from statutory consultees extending until 12 August 2011 given the need to fully consider detailed and technical responses.






Somerset County Council would like to see the consultation material continue to be available in Somerset libraries and council offices/tourist information centres in West Somerset and Sedgemoor during the formal consultation period.

This is EDF Energy’s intention, and the Consultation Strategy and published SoCC have been amended to reflect this point.

EDF Energy should actively publicise the availability of consultation documents in alternative formats and the translation/interpretation service.

EDF Energy agrees and confirms that it will publicise these services in its newsletter, on the project website and at the public exhibitions. The Junction 24 and Highways Improvements Consultation Strategy has been changed to clarify how these services will be advertised.

EDF Energy should make Somerset County Council aware of specific requests for additional meetings or consultation events and provide justification for holding/refusing to hold such events.

EDF Energy’s normal practice is to accommodate such events where reasonable and possible. It would not be appropriate or proportionate to have to justify this in every case to the County Council – this will be covered in the Consultation Report accompanying the DCO application.

There is concern that EDF Energy is not holding specific events with hard-to-reach groups. Attention should be given to consulting with deprived communities to drive up the level of interest and engagement.

EDF Energy notes the council’s position, but believes it would be disproportionate to hold specific events for hard-to-reach groups given the limited scope of this consultation. All those who attended the events for hard-to-reach groups at Stage 2 of the consultation have been notified about the consultation and will have an opportunity to respond.

If there are any specific requests for meetings or events from hard-to-reach groups, EDF Energy should endeavour to host a meeting.

EDF Energy will try to accommodate, where reasonable and possible, any such requests.

EDF Energy should be mindful of the potential for confusion due to West Somerset Council’s consideration of the site preparation works application.

Since the consultation on the draft SoCC, West Somerset Council has confirmed the date for this application to be heard at Committee. EDF Energy is mindful of the potential for confusion and will, therefore, refer to this in the Consultation Strategy and published SoCC.

Somerset County Council requests early access to key DCO application documents.

EDF Energy will, where appropriate, provide the local authorities with advance copies of key documents.

Somerset County Council would like to see specific examples in the SoCC of where potential highway improvements in the Bridgwater area may take place.

EDF Energy does not believe that it is appropriate to provide this level of detail in the SoCC – this approach was not taken in previous rounds of consultation. This information is available in the Consultation Document, on the website and at the public exhibitions.






Joint response from Sedgemoor District Council and West Somerset Council, July 2011

The councils request that the full Stage 2 consultation responses relevant to these proposed changes are made available as part of the consultation material.

EDF Energy has previously made it clear that consultation responses will be published and responded to in the Consultation Report and not during the consultation process.

The main reason for the potential change near Junction 24 is the fact that the Somerfield site has recently come onto the property market. The Consultation Strategy has been amended to reflect the main reason for this potential change.

The Councils do not understand why the local authorities and other statutory consultees have been given two weeks less to respond to the proposed changes than the public.

EDF Energy would normally have ensured that consultation with the local community, the general public and statutory consultees would run concurrently. The different timescales for local community and statutory consultation simply reflect the constraints imposed by section 47 of the Act. The section 42 and section 47 consultees will have had exactly the same length of formal consultation (i.e. 28 days), albeit that this consultation started on different dates.

The CLG guidance does make it clear that it may not always be possible for the timescales for formal consultation with communities and technical consultees to be synchronised.

The timeline does not allow for adequate member engagement or any formal response. We would like to provide a formal response by 12 August 2011.

As in previous rounds of consultation, EDF Energy will be flexible where organisations are having genuine difficulty meeting deadlines. However, EDF Energy would be concerned about deadlines for responses from statutory consultees extending until 12 August 2011 given the need to fully consider detailed and technical responses.

EDF Energy should consult on the implications of the proposed changes for project-wide strategies and to report on the implications for changes to previously-reported environmental impacts and mitigation measures.

EDF Energy accepts that, if plans change as a result of the consultation, there may need to be some consequential revisions to the overarching strategies – covering, for example, freight and construction – that were consulted upon during the Stage 2 Update consultation. Any changes to these strategies will be based upon the material EDF Energy is consulting on in this consultation.

Preliminary environmental information should provide sufficient details on the impacts of the changes in order to fully understand what mitigation and compensation may be necessary.

EDF Energy notes these comments and draws the attention of the local authorities to the preliminary environmental information published on the project website.

The councils are concerned that there will be little time to consider responses to this consultation given EDF Energy’s timescale for submitting its DCO application. Further clarification is sought on the programme for submitting the DCO application.

At this stage, EDF Energy cannot give a precise intended date for submission of the DCO application. The aim is to submit later this year and the Consultation Strategy has been amended to reflect this.






Local communities should have adequate access to EDF Energy staff and its specialists time so they can appreciate the extent and complexity of the changes proposed.

The public exhibitions being held as part of the consultation will be fully staffed by relevant members of the project team.

Outside the public exhibitions, members of the public and representatives of local communities can access EDF Energy specialists via the Bridgwater office or by using the contact information provided on all consultation documents, newsletters and in advertisements.

Focussing the consultation on residents and businesses within a 0.5-mile radius of the site is not appropriate or adequate. The consultation should be widened to cover all the residents of Bridgwater and, specifically, residents of Stockmoor village.

Since consulting on the draft SoCC, EDF Energy has proposed a number of new and improved highway improvements schemes in the Bridgwater area, and therefore accepts that there should be a wider focus to the consultation.

The programme has therefore been extended to include additional consultation events in the Bridgwater area, and reference to the 0.5 mile radius is no longer included.

The Junction 24 and Highways Improvements Consultation Strategy Document and published SoCC have been amended to reflect these changes.

Consultation with the Bridgwater Vision Board, the Bridgwater Chamber of Commerce, Sedgemoor Business Forum, major employers and smaller retailers and businesses should be included.

EDF Energy welcomes these comments and will approach business representative organisations in the Bridgwater area as part of the section 47 consultation. The Consultation Strategy and published SoCC have been amended to reflect these changes.

There should be sensitivity in the language used, particularly in view of low literacy levels in Bridgwater. Consideration should be given to face-to-face contact for those most affected with the support of the council or Homes in Sedgemoor.

EDF Energy welcomes these comments and will approach Homes in Sedgemoor as part of the formal section 47 consultation. The Consultation Strategy and published SoCC have been amended to reflect these changes.

The Consultation Document, which is widely available at the public exhibitions and meetings, has been written in clear, non-technical language suitable for all readers.

The Councils request further details of the type of communities and stakeholders to be consulted with a full schedule or organisations and groups to be attached to the Consultation Strategy.

EDF Energy will be consulting across the full range of local communities affected by the Hinkley Point C project in a similar way to its previous consultations. All those who have previously responded to any stages of consultation have received notification of this consultation.

EDF Energy does not consider it necessary or proportionate to provide a schedule of organisations or groups as an appendix to the Consultation Strategy.






The Councils do not agree that there should be no further consultation events specifically for hard-to-reach groups – there should be a strong focus on deprived communities to drive up the levels of interest or engagement in Bridgwater.

EDF Energy notes the Council’s position but believes it would be disproportionate to hold specific events for hard-to-reach groups given the limited scope of this consultation. All those who attended the events for hard-to-reach groups in Stage 2 of the consultation have been notified about the consultation and will have an opportunity to respond.

There should be a more detailed briefing and discussion on local issues in relation to the proposed highway improvements in Bridgwater involving local members.

EDF Energy believes that its Transport Forum, which will be discussing the consultation on 26 July 2011, could be a suitable forum for local ward members to raise these detailed local issues in relation to proposed junction improvements. EDF Energy would welcome attendance at this meeting by affected Sedgemoor councillors.

EDF Energy needs to be mindful of the potential for conflict and confusion due to West Somerset Council’s consideration of the site preparation works application.

Since the consultation on the draft SoCC, West Somerset Council has confirmed the date for this application to be heard at Committee. EDF Energy is mindful of the potential for confusion and will therefore refer to this in the Consultation Strategy and published SoCC.

d) Informal Supplementary Engagement

1.1.52 In addition to the formal stages of pre-application consultation, EDF Energy has undertaken informal consultation as appropriate. This has included frequent and regular liaison meetings and presentations, an ongoing Community Forum, the establishment of a Transport Forum (in February 2011) and a Development Site Neighbourhood Forum (in April 2011), as well as regular newsletters and updates to the project website. Where extensions to the proposed redline boundaries presented at the Stage 2 Update consultation were necessary, for example at Junction 23 and Junction 24 sites, letters of notification were issued to the relevant stakeholders to inform them of these changes prior to submission of the application for Development Consent (DCO application).

1.1.53 Discussions with consultees, in particular the relevant local authorities and key statutory consultees, have continued up to the submission of the DCO application to the Infrastructure Planning Commission (IPC) and will continue throughout the examination of the application and beyond. Throughout the consultation period, EDF Energy’s Bridgwater office in King Square has been open during normal office hours, with members of staff on hand to liaise with members of the public. Further information about this informal supplementary engagement is provided in Chapter 4 of this report.

e) Post-Submission Activities

1.1.54 Following acceptance of the DCO application by the IPC, EDF Energy will carry out a public information exercise providing details of its final proposals for the Hinkley Point C Project, in addition to the formal notification requirements under the Act for accepted DCO applications. Details of these activities, which are designed to assist


understanding of the proposals and facilitate their examination by the IPC, are given in Chapter 2 of this report.

1.2 Legislation and Guidance

1.2.1 This section of the report summarises the legal requirements and guidance on pre-application consultation and explains the steps taken by EDF Energy to comply with those requirements.

a) Planning Act 2008

1.2.2 Section 55(3)(e) of the Act provides that the IPC must be satisfied that the applicant has complied with Chapter 2 of Part 5 of the Act relating to pre-application procedure. That chapter requires promoters of NSIPs to consult various statutory consultees and other relevant stakeholders, the local community and the general public before submitting a DCO application. In deciding whether the pre-application procedure has been followed, the IPC must have regard to matters including the consultation report (which must be prepared under section 37(3)(c)).

1.2.3 The key legal requirements for promoters in relation to pre-application consultation under the Act are briefly summarised below:

Sections 42-45 require the promoter to consult a wide range of prescribed statutory consultees, local authorities in whose area development is proposed and adjoining local authorities, owners, lessees, tenants and occupiers of the land, persons who are interested in the land or have the power to sell/convey or release the land, and persons who the promoter thinks would or might be entitled to make a claim under Section 10 of the Compulsory Purchase Act 1965 or Part 1 of the Land Compensation Act 1973. At least 28 days must be allowed for this consultation.

Section 46 requires the promoter to provide all consultation material to the IPC on or before commencing consultation under section 42.

Section 47 sets out the duty on the promoter to consult the local community including the following requirements: to draw up a statement (SoCC) on how the consultation with the community will be undertaken; to consult local authorities in whose area the development is proposed, for a minimum of 28 days, about what is to be in this statement; to have regard to the responses from the local authorities; to publish the statement in a newspaper circulating in the vicinity of the land; and then to carry out the consultation as laid out in the statement.

Section 48 requires the promoter to publicise widely the proposed application and set a deadline for receipt of responses to the publicity.

Section 49 requires the promoter to have regard to relevant responses to the above consultation and publicity before making the DCO application.

Section 37(3)(c) requires the preparation of a consultation report to accompany the DCO application, which provides details of what has been done in compliance with statutory consultation requirements, along with details of any response to the statutory consultation that was received by the relevant deadline and details of the




account taken by the promoter of any such response. Section 55(3)(b) of the Act provides that the IPC may only accept the application if the requirements of section 37(3) are met.

1.2.4 Various regulations have been made pursuant to the Act. The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 (PFP Regulations) prescribe consultees under Regulation 3. Regulation 4 prescribes the manner in which a DCO application is to be publicised under section 48 of the Act.

1.2.5 The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (EIA Regulations) also contain provisions that are relevant to consultation. Regulation 6 requires the applicant, before carrying out consultation under section 42 of the Act, to notify the IPC that it proposes to provide an Environmental Statement in respect of the proposed development. Regulation 10 requires that the SoCC prepared under section 47 of the Act sets out whether the proposed application relates to EIA development and how the applicant intends to publicise and consult on the preliminary environmental information. Regulation 11 requires that an applicant, at the same time as publishing notice of the proposed application under section 48 of the Act, must send a copy of that notice to the “consultation bodies” and to any person notified to the applicant under Regulation 9(1)(c). The “consultation bodies” in this context are the prescribed consultees under the PFP Regulations and the relevant local authorities pursuant to section 43 of the Act. EDF Energy has not been notified of any consultees under Regulation 9(1)(c).

1.2.6 Table 1.6 provides further details of the steps taken by EDF Energy to meet those requirements.

b) IPC Guidance

1.2.7 Section 50 of the Act provides for the IPC and the Secretary of State to issue guidance on pre-application consultation, which must be taken into account by the promoter of a DCO application. Section 37(4) of the Act enables the IPC to give guidance about how the requirements of section 37(3) of the Act (including the preparation of a consultation report) are to be complied with.

1.2.8 Section 55(4)(c) of the Act provides that in deciding whether a proposed application has complied with statutory pre-application procedure, the IPC must have regard to the extent to which the applicant has had regard to any guidance issued under section 50. Section 55(3)(d) provides that the IPC may accept the DCO application only if it gives reasons for those respects in which any applicable guidance given under section 37(4) have not been complied with.

1.2.9 The IPC has published guidance on the pre-application stages of the Act, including the preparation of the consultation report.

1.2.10 'IPC Guidance Note 1 on Pre-application Stages' was first published in December 2009. It was revised in March 2010 and again on 5 September 2011. It explains that the statutory requirements allow for some flexibility for applicants to determine the most applicable programme by which they will be able to comply most effectively with their consultation duties. It provides guidance on the timing and content of the section 42 consultation and the approach to be taken to the preparation of a SoCC




and consultation under section 47. It states that a SoCC should contain sufficient information to enable the community to understand on what and how it will be consulted, although advises that it may need to be a concise document to suit local press publishing requirements. Further advice is given on the timing of the section 48 publicity in relation to the section 42 consultation and the duty to take into account consultations. The guidance also addresses the preparation and contents of a consultation report, including the categorisation of consultation responses and the approach to setting out the reply of the promoter to those responses.

1.2.11 'IPC Guidance Note 2 on preparation of application documents under s37 of the Planning Act 2008' was published on 7 December 2009 and contained guidance on the form and content of DCO application material. This guidance was withdrawn on the same date as the publication of Revision 2 of IPC Guidance Note 1 in September 2011, which now contains the relevant guidance on the preparation of a consultation report.

1.2.12 The IPC has also prepared a series of Advice Notes including ‘Advice Note Six: Preparation and Submission of application documents’. This includes at Appendix 2 a checklist that the IPC uses to determine whether application documents will be accepted, by reference to the statutory requirements summarised above. This Advice Note does not however constitute statutory guidance issued by the IPC under sections 37 or 50 of the Act.

1.2.13 Table 1.6 below provides further detail of how the consultation process undertaken by EDF Energy has complied with the advice set out in IPC Guidance Note 1, subject to limited departures from it which were intended to enable a bespoke approach which reflected the particular circumstances of the Hinkley Point C Project. These are explained in the ‘Exceptions and Departures’ section of Chapter 2 in this report. Table 1.6 below refers to the guidance as it stood on the date on which this report was sent to print.

1.2.14 That table also identifies how the consultation process and consultation report address the checklist as set out in IPC Advice Note Six.

c) Department for Communities and Local Government Guidance

1.2.15 CLG published guidance under section 50 of the Act in September 2009, entitled 'Guidance on pre-application consultation'. One of its main purposes is to guide promoters of NSIPs as to how the pre-application requirements of the Act should be fulfilled. The guidance outlines what the Government’s expectations are and suggests a range of approaches for promoters to use.

1.2.16 The guidance makes it clear that the SoCC should set out in detail who is going to be consulted and how. CLG encourages promoters to view the requirement in the Act to consult people living in the ‘vicinity of the land’ broadly and suggests that the views of people who live, work and otherwise use the affected areas should be sought. It advises that there will be bodies in addition to those specified in the legislation who may be able to make a contribution and encourages promoters to consult widely.

1.2.17 According to the guidance, a range of methods should be used by promoters to consult communities. It stresses that consultation should not rely on written




documents alone and should reflect the fact that those to be consulted may have varying degrees of literacy, do not always have English as their first language, may not have ready access to a computer or have disabilities that make it difficult for them to engage in the process. Engagement with hard-to-reach groups is encouraged.

1.2.18 The guidance puts forward a number of suggestions for community engagement techniques including: local exhibitions; drop-in sessions; workshops; telephone advice line; citizen panels; meetings with parish/town councils; internet; and local media.

1.2.19 The importance of consultation with statutory consultees and local authorities is highlighted in the guidance, with an emphasis on early engagement and the provision of relevant supporting technical information to consultees.

1.2.20 In terms of the timing of consultation, promoters are encouraged to consult as early as possible and to consider a phased consultation consisting of two or more stages. This is particularly encouraged for larger projects with long development periods.

1.2.21 Guidance is provided about the information that promoters need to supply to technical consultees. For local communities, it recommends that a short document should be produced, written in non-technical language, describing the proposals and outlining the matters on which the views of the local community are sought. It suggests that promoters should make this document available in different formats for those with disabilities if requested and in other languages in some areas. The summary document should also provide details of consultation events, where the full documents can be inspected and give a deadline for a response to the consultation process.

1.2.22 EDF Energy has had regard to the CLG guidance during its pre-application consultation process, as explained further in Table 1.6.

1.2.23 CLG published 'Planning Act 2008: Guidance for Local Authorities' in March 2010, which included guidance on pre-application consultation. Although this guidance was directed at local authorities rather than promoters and was not published under section 50 of the Act, it was still taken into account by EDF Energy from Stage 2 onwards (as it was published after the launch of Stage 1). In particular, EDF Energy had regard to the guidance on how to most effectively carry out consultation with the local authorities in respect of the SoCC. Further details are provided in Table 1.6.

d) HM Government Code of Practice on Consultation

1.2.24 The Government has had a Code of Practice on Consultation since 2000 that sets out best practice advice on how government consultation should be run. Many public sector organisations have signed up to this voluntary Code, the latest version of which was published in July 2008.

1.2.25 Although the Code does not have legal force, it sets out the Government’s general policy on its formal, public, written consultation exercises. The Code contains seven key consultation criteria summarised below:




1) Consultation should take place at a stage when there is scope to influence the policy outcome.

2) Consultation should normally last for at least 12 weeks.

3) Consultation documents should be clear about the process, what is being proposed, the scope to influence and the expected impacts and benefits of the proposals.

4) Consultation exercises should be accessible to all and clearly targeted at those people it is intended to reach.

5) The burden of consultation should be kept to a minimum.

6) Consultation responses should be analysed carefully and clear feedback provided to participants.

7) Those running consultations should seek guidance in how to run an effective consultation exercise.

1.2.26 Although EDF Energy is not a public body, its consultation process for the development of its plans for Hinkley Point C has been informed by these criteria, as explained further in Table 1.6.

e) Local Authority Statements of Community Involvement

1.2.27 WSC, SDC and SCC have adopted Statements of Community Involvement (SCIs) which provide some advice about how developers should undertake pre-application consultation in relation to planning applications for major projects.

1.2.28 WSC’s SCI was adopted in November 2007. It encourages developers to undertake pre-application consultation, arguing that this should provide a faster route for decision-making, save money for the developer and the council, and provide the local community with a level of ownership of the project. The developer should take the lead role in the consultation and the pre-application period is identified as the key stage in which to consult.

1.2.29 The SCI establishes a Consultation Matrix that recommends the level of consultation the developer should undertake depending on the scale and significance of the application. It makes it clear that while the guidance on planning application consultation is not prescriptive for developers, and not all the consultation methods identified in the matrix need to be undertaken, discussion between the Council and the developer should help to decide the appropriate form of consultation.

1.2.30 It specifically identifies applications for power stations as ‘Tier Level 1’ applications that should be subject to wider community involvement. WSC lists the following potential methods for the developer to use to engage with stakeholders and the local community: public meetings; public exhibitions; citizen panels; website; local architectural or design panel; parish councils; media; surgeries; Enquiry by Design and/or Planning for Real methodology; Planning Aid; consultation panel; development briefs; and workshops.




1.2.31 The SCI recommends that the results of the pre-application consultation should be reported in the form of a consultation summary along with the planning application. The summary should provide details of the consultation undertaken, allowing the Council to understand with whom, how and when the consultation took place and show that the views of stakeholders and the local community have been taken into account.

1.2.32 SDC’s SCI was adopted in April 2007. Much of the material and advice for developers is similar to, or consistent with, that set out in WSC’s SCI. It is clear about the need for developer-led pre-application consultation for significant development proposals. Level 1 applications are defined as those that require an EIA or a Transport Assessment. The SCI also has a Consultation Matrix that suggests the following consultation techniques for Level 1 applications: public meetings; public exhibitions; development briefs; workshops; Enquiry by Design methodology; Planning for Real methodology; town and parish councils; media; website; Planning Aid.

1.2.33 The SCI advises that the level of consultation for each individual proposal should be discussed between the Council and the applicant. It makes specific reference to the need for developers to use a mix of consultation techniques and ensure there are opportunities for hard-to-reach groups to participate in the process. Applicants are advised to submit a statement with their applications dealing with how the community has been involved in the proposals, summarising the consultation responses and providing a list of all respondents to the pre-submission consultations.

1.2.34 In addition to its SCI, SDC has also adopted its own consultation policy. While this applies to the actions of the Council, rather than those of developers, its key policies reflect the Government’s own Code of Practice on Consultation: consultation should take place when there is scope to influence decisions; it should normally last for at least 12 weeks; consultation documents should be clear about the process, what is being proposed, the scope to influence matters and the expected costs and benefits; the process should be accessible to those people it is intended to reach; and responses should be analysed carefully and feedback provided to participants.

1.2.35 SCC, which adopted its own SCI in November 2006 as part of its Minerals and Waste Development Framework, is less prescriptive. It encourages developers to consult the local community and stakeholders early in the process so that issues can be raised and addressed. A report on the results of pre-application community consultation is also suggested as part of the planning application process.

1.2.36 EDF Energy’s pre-application consultation process for development at Hinkley Point C has taken into account the consultation advice produced by the three relevant Somerset local authorities (see Table 1.6). The majority of the consultation techniques suggested by WSC and SDC have been deployed, and account has been taken of the need to engage with hard-to-reach groups and to report back on the outcome of the consultation process.






f) Compliance with Statutory Requirements and Consultation Guidance

1.2.37 The following table summarises how EDF Energy’s pre-application consultation process has complied with statutory requirements under the Act and the guidance provided by the IPC as well as by central and local government.


Table 1.6: Compliance with Consultation Requirements

Statutory Requirements/ Consultation Guidance

EDF Energy Action and Comment Timings

Sections 42 to 45, Planning Act 2008

Consultation of prescribed persons under section 42(1)(a) (see too PFP Regulations Regulation 3).

Consultation of local authorities under section 42(1)(b) and section 43.

Consultation under section 42(1)(d) and section 44 of persons in Categories 1 (owner, lessee, tenant or occupier), 2 (person interested in the land or with power to sell and convey or release the land) and 3 (persons who would or might be entitled to make a relevant claim under section 10 of the Compulsory Purchase Act 1965 or under Part 1 of the Land Compensation Act 1973).

Notification under section 45 of persons consulted under section 42 of deadline for receipt of response to consultation, the deadline not being less than 28 days from day after receipt of consultation documents.

IPC Checklist 5.4, 5.5, 5.6.

Consultation was undertaken with all of the bodies specified in section 42 of the Act at all stages of the consultation: see Chapter 2 and Appendix G for further details of those consulted and the manner in which consultation was carried out. Details of the bodies consulted at each stage of the consultation are also included in this report.

As the Stage 2 Update and Junction 24 and Highways Improvements consultations were limited, focused stages of EDF Energy’s consultation that did not re-consult on the project as a whole, EDF Energy only consulted those people falling within section 42(1)(d) of the Act to the extent that they had an interest in, or were affected by, the land that was the subject of material changes being consulted upon.

Each consultation lasted for at least 28 days and the consultation material specified the deadline by which responses to the consultation had to be received (see Appendix A).

Stage 1: ‘Initial Proposals and Options’, 16 November 2009 – 18 January 2010 (64 days).

Stage 2: ‘Preferred Proposals’, 9 July – 4 October 2010 (88 days).

Stage 2: Update: ‘Update on and Proposed Changes to the Preferred Proposals’, 25 February – 28 March 2011 (32 days).

Junction 24 and Highways Improvements consultation: ‘Proposed Changes to the Preferred Proposals – M5 Junction 24 and Highway Improvements in the Bridgwater Area’, 1 July – 28 July 2011 (28 days).

Section 46, Planning Act 2008

Notification to IPC of proposed application

IPC Checklist 5.7, 5.8, 5.9

EDF Energy complied with this section of the Act by sending the consultation material for each stage of consultation to the IPC at the start of its section 42 consultation. The information sent to the IPC was the same as that sent to the section 42 consultees (see Appendix A).

Stage 1: 11 November 2009.

Stage 2: 8 July 2010.

Stage 2 Update: Main letter sent 24 February 2011. Supplementary figure amendment letter sent 25 February 2011.

Junction 24 and Highways Improvements consultation: 5 July 2011.









Preparation of statement under section 47(1) setting how applicant proposes the consult people living in the vicinity of the land about the proposed application.

Consultation under section 47(2) with each local authority in whose area the proposed application land falls, about what is to be within the statement.

Requirement under section 47(5) to have regard to any response to consultation under section 47(2) that is received before 28-day deadline imposed by section 47(3).

Publication under section 47(6) of the statement in a newspaper circulating in the vicinity of the land.

Requirement under section 47(7) to carry out consultation in accordance with the proposals set out in the statement.

IPC Checklist 5.10, 5.11, 5.12, 5.13, 5.14, 5.15

A SoCC was prepared for each of the four formal periods of pre-application consultation with the community: see Chapter 1 and Appendix A. EDF Energy consulted both formally and informally with the three Somerset local authorities (SCC, WSC and SDC) within whose boundaries development is proposed: see Chapter 1, Chapter 4 and Appendices A and G. Each formal consultation with the local authorities on the draft SoCC lasted at least 28 days: see Chapter 2. EDF Energy had regard to the responses received from the local authorities before publishing the SoCC, in full, in local newspapers: see further Chapter 1 of this report.

EDF Energy carried out each stage of its pre-application consultation in line with the programme laid out in the relevant SoCC. Each SoCC was advertised in the local press: see Chapter 2 and Appendix A.

The Stage 1 SoCC stated that details of the first stage of public consultation would be set out in a Proposal Summary Document that would be publicly available; that consultation was intended to take place over two stages, involving “Initial Proposals and Options” and “Preferred Proposals”; and that there would be an Environmental Status Report submitted at the first stage and a draft Environmental Statement submitted at the second stage. The SoCC set out who would be consulted and how and when consultation would take place. It also explained that an interim consultation report for that stage would be prepared. Consultation at Stage 1 involved the documents referred to in the SoCC, covered the range of identified consultees and followed the identified timetable: see Appendices B, C and F, plus Chapter 1 and Chapter 2.

The Stage 2 consultation began four months later than had been envisaged in SoCC1. SoCC2 identified the revised consultation period and referred to the consultation documents that would be made available, including the Preferred Proposals and an Environmental Appraisal. It referred to the preparation of a full consultation report to be submitted with the DCO application. Consultation at Stage 2 covered the range of identified consultees, involved the documents referred to in the SoCC and followed the identified timetable: see Appendices A, C and F and Chapter 2.

Statutory consultation on SoCC1: 2 July – 14 August 2009 (44 days) and again from 29 September – 28 October 2009 (30 days).

Statutory consultation on SoCC2: 20 May – 18 June 2010 (30 days).

Statutory consultation on SoCC3: 17 December 2010 – 20 January 2011 (35 days).

Statutory consultation on SoCC4: 13 June – 11 July 2011 (29 days).

SoCC1 published on 12 November 2009 and advertised in local newspapers (64 days).

SoCC2 published on 29 June 2010 and advertised in local newspapers (87 days).

SoCC3 published on 15 February 2011 and advertised in local newspapers (32 days).

SoCC4 published on 14 July 2011 and advertised in local newspapers (29 days, which followed 14 days of informal consultation).






SoCC3 and SoCC4, relating to the Stage 2 Update and the Junction 24 and Highways Improvements consultations, related to limited consultations during which EDF Energy did not re-consult on the project as a whole. Both referred to the consultation material that would be made available to identify the changes, along with the timetable for consultation. Both stated that consultation events would be focussed in those communities around the land that was the subject of the material changes being consulted upon. However, these consultations were publicised in a similar way to the Stage 1 and Stage 2 consultations, so that people in all local communities had the opportunity to participate in the consultation process. All other steps referred to in the SoCC were taken: see Appendices A, C and F and Chapter 2.

Section 48(1), Planning Act 2008

Publication of proposed application in prescribed manner: see Regulation 4 of the PFP Regulations (publication to include prescribed matters, in local and national press - including at least two successive weeks in a local newspaper, and once in a national newspaper and the London Gazette).

IPC Checklist 5.16, 5.17

In parallel with the consultation with section 42 consultees at Stage 2, Stage 2 Update and the Junction 24 and Highways Improvements consultation, EDF Energy publicised the proposed DCO application through national and local advertising and invited comments from the wider public on its proposals. The notices complied with the requirements of Regulation 4(3) of the PFP Regulations.

Notices were published:

for at least two successive weeks in one or more local newspapers circulating in the vicinity of the land (the Somerset Gazette);

once in a national newspaper (the Telegraph);

once in the London Gazette; and

in the case of the Stage 2 Update and Junction 24 and Highways Improvements consultation, additionally in the Lloyd’s List and Fishing News.

The section 48 notices included amongst other things (see Appendix A):

the name and address of EDF Energy;

a statement that it intended to make an application for development consent to the IPC in relation to EIA development;

a summary of the proposals and their location at Hinkley Point C;

a statement that the relevant documents, plans and maps would be

Stage 2, ‘Preferred Proposals’ consultation advertising in: The Daily Telegraph, 9 July 2010; London Gazette, 9 July 2010; and Somerset Gazette 8 July and 15 July 2010.

Stage 2 Update: ‘Update on and Proposed Changes to the Preferred Proposals’ consultation advertising in:

The Daily Telegraph, 25 February 2011; London Gazette, 25 February 2011; Lloyd’s List, 25 February 2011; Fishing News, 25 February 2011; and the Somerset Gazette, 24 February 2011 and 3 March 2011.

Junction 24 and Highways Improvements consultation: ‘Proposed Changes to the Preferred Proposals – M5 Junction 24 and Highway Improvements in the Bridgwater Area’ consultation advertising in:

The Daily Telegraph, 1 July 2011; London Gazette, 1 July 2011; Lloyds List, 1 July 2011; Fishing News, 1 July 2011; and the Somerset Gazette, 30 June 2011 and 7






available for inspection free of charge in identified locations including the EDF Energy office in Bridgwater near the site;

details of charges to be made for any copies of those documents;

details of how to respond to the publicity; and

the deadline for receipt of responses.

In accordance with Annex B of CLG’s ‘Guidance on pre-application consultation’ on multi-stage consultations, EDF Energy chose to publicise its proposed DCO application in the prescribed manner through the publication of a section 48 notice at Stage 2, when detailed information was available about the preferred proposals. Although there was no requirement for EDF Energy to publish section 48 notices at each stage of consultation, for the two subsequent stages of limited update consultation, EDF Energy chose to supplement the previous publicity by publishing further section 48 notices. Each section 48 notice specified the project website where consultation material for that stage and all previous stages was available. EDF Energy accepted comments at each stage on all aspects of the proposals. For all stages of consultation, EDF Energy had regard to all responses, even those received after the relevant deadline, in developing its proposals (see Chapter 2).

July 2011.


Requirement under section 49(2), following compliance with sections 42, 47 and 48 of the Act, to have regard to relevant responses before deciding whether the application should be in the same terms as the proposed application.

IPC Checklist 5.19

EDF Energy has had regard to all relevant responses received throughout its pre-application consultation. EDF Energy published an interim consultation report at Stage 2 of its consultation, which provided preliminary information on how EDF Energy had regard to the comments received at Stage 1. See Appendix B.

This final Consultation Report provides detailed information on how EDF Energy has had regard to all comments received throughout the consultation exercise as a whole. Chapter 3 summarises the main themes of the representations and how EDF Energy has responded to them. Chapter 4 summarises informal engagement undertaken with key stakeholders and EDF Energy’s response. Chapter 5 sets out the methodology that has been devised to compile the formal representations and the responses by EDF Energy to them, which appear in full in Appendix H.

Interim consultation report published 9 July 2010.

Final consultation report submitted to the IPC with the DCO application.






Section 37(3)(c), Planning Act 2008

Application to be accompanied by the Consultation Report.

IPC Checklist 2.3

This report accompanies the DCO application.

Section 37(7)(a), Planning Act 2008

Consultation Report to give details of what has been done in compliance with sections 42, 47 and 48.

This report provides details of what has been done in compliance with sections 42, 47 and 48 of the Act in relation to the proposed DCO application: see Chapters 1 and 2 of this report.

Section 37(7)(b), Planning Act 2008

Consultation Report to give details of any relevant responses to consultation.

This report provides details of responses to the consultations under sections 42, 47 and 48 of the Act: see Chapters 1 and 3 and Appendix H of this report.


Consultation Report to give details of the account taken of any relevant responses.

This report provides details of the account taken by EDF Energy of relevant responses to the consultations under sections 42, 47 and 48 of the Act: see Chapters 1 and 3 and Appendix H of this report.

Section 55(3)(d), Planning Act 2008

Application to give reasons for any respect in which any IPC Guidance under section 37(4) has not been followed

IPC Checklist 4

See section addressing IPC Guidance below and Chapter 2 of this report.


In deciding whether a proposed application has complied with statutory pre-application procedure, IPC must have regard to the extent to which the applicant has had regard to any guidance issued under section 50.

IPC Checklist 5.20

See sections relating to IPC and CLG guidance below, which confirm that EDF Energy has had regard to all relevant aspects of that guidance.






Regulation 6, EIA Regulations

Applicant to notify IPC that proposes to provide an ES.

IPC Checklist 5.1

EDF Energy notified the IPC in its letter dated 11 November 2009. See Appendix A.

Regulation 10, EIA Regulations

SoCC to set out whether the proposed application relates to EIA development and how applicant intends to publicise and consult on the preliminary environmental information.

IPC Checklist following 5.15

Each SoCC stated that the intended DCO application would relate to EIA development: see Appendix A. Each stated how preliminary environmental information would be publicised and consulted upon. In the case of SoCC1, this was to be provided in the form of an Environmental Status Report; SoCC2 referred to an Environmental Appraisal; SoCC3 referred to the preliminary environmental information that had already been submitted and explained how the material relevant to that consultation would be consulted upon; and SoCC4 referred to further environmental information that had been prepared in relation to the ‘Somerfield’ site and highways improvements that were relevant to that stage of consultation.

Regulation 11, EIA Regulations.

Copy of section 48 notice to “consultation bodies” and any persons notified to the applicant under regulation 9(1)(c).

IPC Checklist 5.18

From Stage 2 onwards (the stage at which section 48 notices were published), EDF Energy included a copy of the section 48 notice with the consultation material sent to all prescribed statutory consultees and relevant local authorities. No other persons were notified to the applicant (see Appendix A).

Stage 2: ‘Preferred Proposals’, 9 July – 4 October 2010.

Stage 2 Update: ‘Update on and Proposed Changes to the Preferred Proposals’, 25 February – 28 March 2011.

Junction 24 and Highways Improvements consultation: ‘Proposed Changes to the Preferred Proposals - M5 Junction 24 and Highway Improvements in the Bridgwater Area’, 1 July – 12 August 2011.






IPC Guidance IPC Guidance Note 1 was originally published in December 2009, one month after the publication of EDF Energy’s original SoCC. That guidance was not, therefore, taken into account when preparing SoCC1 for its Stage 1 consultation, although the published SoCC reflected much of the spirit of that guidance. The original guidance was superseded by the first revision of March 2010, which was taken into account by EDF Energy in preparing SoCCs 2-4 for the Stage 2, Stage 2 Update and Stage 2 Junction 24 and Highways Improvements consultations.

The second revision of the IPC Guidance Note 1 (dated August 2011) was published by the IPC in September 2011 (at the same time as IPC Guidance Note 2 was withdrawn). Below, this section explains how the consultation process undertaken by EDF Energy has complied with this revised guidance.

SoCC2: published on 29 June 2010.

SoCC3: published on 15 February 2011.

SoCC4: published on 14 July 2011.

Intention that notification to IPC of proposed application and commencement of formal pre-application consultation will happen relatively close together (para. 7 IPC Guidance Note 1).

IPC encourages applicants to notify it as soon as feasible (para. 8 IPC Guidance Note 1).

See above. The IPC was notified of the proposed application and commencement of the different stages of pre-application consultation prior to the commencement of each stage (see Appendix A).

Section 42 consultation can be carried out first and changes to the scheme can be made as a result before the community consultation is carried out. A balance needs to be achieved between providing well-developed details and a less precise definition which can be amended in the light of consultation. The IPC will expect the balance between these issues to be carefully considered, and it may be that an approach to the local authority under s47 prior to publishing the SoCC could seek advice on whether an early community consultation would be advisable (para. 10 IPC Guidance Note 1).

EDF Energy considered that in the context of a multi-stage approach to consultation, it was appropriate to consult under sections 42 and 47 at broadly similar times. Any changes to the proposals that resulted from consultation with statutory consultees, particularly at the early stages of consultation, could still be the subject of consultation with the community at the next stage of consultation. EDF Energy had informal discussions with the Somerset local authorities prior to the preparation of SoCC1 (see Chapter 1 and Chapter 4) where the approach to be taken to section 47 consultation was discussed. The material made available at each stage of the consultation properly reflected the development of the application through a multi-stage consultation process.






If very little information on the project is provided at the section 42 stage, the ability to demonstrate comments have been taken into account in developing the proposal could be hampered (para. 11 IPC Guidance Note 1).

Unless there is a clear iterative consultation process followed and further documentation provided during the process the promoter will risk being unable to demonstrate that the scheme was carefully considered in the light of consultation responses received (para. 12 IPC Guidance Note 1).

EDF Energy considers that it provided the appropriate amount of information relating to the proposals at each consultation stage, having regard to the multi-stage consultation that had been envisaged from the outset (Consultation documents are included in Appendix C). Chapter 2 sets out the process that was followed pursuant to section 42 and demonstrates clearly EDF Energy’s commitment to an iterative consultation process. This is further confirmed by its preparation of an interim consultation report following the Stage 1 consultation (see Appendix B), by Chapter 3 of this consultation report, which summarises how the consultation process informed the proposals, and by Appendix H, which demonstrates how EDF Energy has considered the consultation responses received at each stage of the process.

Knowledge of local authorities at section 47 stage of consultation on SoCC may influence decisions on the geographical extent and methods of consultation.

Local authorities will also hold valuable information on umbrella community groups in the local area which could complement responses from the population generally (para. 13 IPC Guidance Note 1).

When an applicant consults a local authority on the SoCC the local authority will need to have the preliminary environmental information so that its response can be an informed one.

The consultation with local authorities under section 42 and contact with local authorities on the SoCC under section 47 can occur in parallel (para. 14 IPC Guidance Note 1).

EDF Energy entered into detailed discussions with the Somerset local authorities about the range and methods of consultation as part of its section 47 consultation, both informally and during the formal consultation process: see Chapter 1 and Chapter 4.

During the section 47 consultation, EDF Energy provided the Somerset local authorities with information regarding the proposals and their potential environmental effects: see Chapter 2.

Consultation with the Somerset local authorities under section 42 was carried out after contact with those authorities on the SoCC under section 47: see the timings for the section 42 consultation above and Chapter 1. EDF Energy considered it appropriate to engage with the local authorities regarding the scope of community consultation before that consultation was carried out under section 47 at broadly the same time as the consultation under section 42 (see further above).






To ensure the local community appreciates the context within which they are being consulted, the SoCC should include a succinct summary of the role of the IPC as examining authority, and draw attention to the status of NPSs. If a relevant NPS is in place, it is important to provide a realistic steer to the local community on the appropriate scope of any subsequent feedback. It should also highlight the importance of the pre-application consultation in relation to the examination process after an application is accepted by the IPC (para. 17, IPC Guidance Note 1).

Each SoCC summarised the planning process including the submission of the DCO application to the IPC and referred to the role of the IPC. Each SoCC also addressed the status and effect of the NPS relating to nuclear power at the time.

SoCCs 2-4 (relating to the Stage 2, Stage 2 Update and Junction 24 and Highways Improvements consultations respectively) explained that the decision of the IPC was to be made in accordance with national policy but that it would take account of the local impact of the proposal. The principle of whether there is a need for further nuclear power was referred to as being determined through the NPS process, along with the potential suitability of Hinkley Point C as a site for a new nuclear power station. These SoCCs also stated that the pre-application consultation would be important in relation to the examination process after the application has been accepted by the IPC: see Appendix A. Although SoCC1 (relating to the Stage 1 consultation) did not explicitly address these matters, that SoCC was prepared in November 2009, before IPC Guidance Note 1 was issued and before the draft NPS on nuclear power had been published. Further, the SoCC referred to the preparation of a consultation report to be submitted with the DCO application, which made clear the importance of the consultation process as part of the DCO application, prior to the replacement of this SoCC with SoCC2. See further the ‘Exceptions and Departures’ section of Chapter 2.






The SoCC should provide sufficient detail of the project, referring to both positive benefits to the local community that would result from the development and to issues which could be considered negative elements of the NSIP. The scale of the proposal should be described. The SoCC should also indicate what information will be provided during the consultation process on the scope for any associated land restoration, landscaping, other mitigation or compensatory measures for natural habitats’ impact (para. 18 IPC Guidance Note 1).

SoCCs 2-4 each described the proposals and their objectives and set out a range of effects that could be anticipated to arise, including construction operations, increased traffic, visual impact, loss of public access to parts of the site, environmental impacts and pressure on existing community infrastructure. Potential environmental impacts were identified. Each referred to where environmental information could be obtained as part of the consultation process, SOCCs 2 and 3 referring specifically to where information on mitigation or compensatory measures could be found: see Appendix A.

SoCC1 referred to the proposed development of two nuclear generating units and the associated on and off-site development. It also referred to potential benefits such as inward investment and to the need to provide support for local infrastructure such as schools, medical and social facilities. It did not refer to mitigation or compensatory measures for impact on natural habitats, but it did refer to the preparation of an Environmental Status Report as part of its Stage 1 consultation which provided a preliminary view of the key issues. Again, this SoCC was prepared in advance of the IPC Guidance Note 1 and was replaced by SoCC2: see Appendix A and the Exceptions and Departures section of Chapter 2.

The applicant should consider whether the most appropriate consultation will involve multiple stages, and whether there is a role for building knowledge at early stages which could help communities understand the proposal. Any such methods should be included in the SoCC (para. 19 IPC Guidance Note 1).

EDF Energy considered that multi-stage consultation was appropriate: see Chapter 1. Each SoCC referred to the consultation strategy and timetable: see Appendix A.






If relevant, the SOCC should also take account of any other major consultation exercises being undertaken in the area (para. 20 IPC Guidance Note 1).

In practice, to suit local press publishing requirements, the SOCC may need to be a concise document. The important point is that the SoCC needs to provide sufficient information on the project and its impact to encourage constructive participation. It may be advisable in some cases for applicants to also make available to the public a separate document which sets out in more depth the factors that had led to the view taken on consultation catchment, timing and methods to be employed and refer to this in the published SoCC (paras 21-2 IPC Guidance Note 1).

Each SoCC referred to other consultations that had a bearing on the EDF Energy proposals: see Appendix A.

The SoCCs were prepared as concise documents; however, they gave more than adequate information on the proposals to encourage constructive participation.

Following the Stage 1 consultation, EDF Energy prepared a consultation strategy document which set out the wider context to the consultation process. SoCCs 2-4 referred to this supporting document: see Appendix A. This form of strategy document was not prepared in association with SoCC1 (see the ’Exceptions and Departures' section in Chapter 2 of this report), although SoCC1 did explain the general context to the consultation process and the timings and methods to be employed.

It would be helpful if the published deadlines for receipt of views on the application under section 48 are as close as possible to deadlines given in the s42 consultation (para. 23 IPC Guidance Note 1).

As EDF Energy decided to adopt a multi-stage consultation exercise, it did not publish its section 48 notice until Stage 2 of the consultation. This was consistent with the guidance in Annex B of CLG's 'Guidance on pre-application consultation'. The deadline for receipt of views from members of the public, as set in the section 48 notice at Stage 2, mirrored the deadline given the consultees who were consulted under section 42 of the Act. The same applied to the Stage 2 Update consultation. EDF Energy decided to take a different approach with the Junction 24 and Highways Improvements consultation in summer 2011. For this consultation, the deadline for the receipt of views from the section 42 consultees (28 July 2011) was different for the deadline for the receipt of views following the section 48 notice (12 August 2011). The reason for this was that the section 48 deadline was set to coincide instead with the end of the consultation with the local community. See the section on Exceptions and Departures in Chapter 2 of this report.






The applicant is encouraged to carry out on-going consultation with statutory consultees after consultation under sections 42, 47 and 48, before submitting its application to the IPC. This will assist the applicant to comply with its s49 duty (para. 24 IPC Guidance Note 1).

EDF Energy has continued to carry out informal consultation with the Somerset local authorities, key statutory consultees and local community bodies, as explained further in Chapter 4.

The consultation report should draw together:

a. an account of the statutory consultation, publicity, deadlines set, and community consultation activities undertaken by the applicant at the pre-application stage under s42, s47 and s48;

b. a summary of the relevant responses to the separate strands of consultation; and

c. the account taken of responses in developing the application from proposed to final form (para. 25 IPC Guidance Note 1).

This report provides an account of the statutory consultation, publicity, deadlines set and community consultation activities carried out throughout the pre-application stage, as explained further in Chapter 2. Further informal consultation is described in Chapter 4.

Chapter 3 of this report provides a summary of EDF Energy’s response to the main themes raised as part of the consultation, along with a summary of how the responses were taken into account in developing the proposals. Further detail is provided in Appendix H according to a methodology that is explained in Chapter 5 of this report.

The report should also confirm any steps taken by the applicant to comply with Regulation 11 of the EIA Regulations (para. 26 IPC Guidance Note 1).

See above.






The consultation should be carried out to allow a robust and detailed report at the application stage. A list of the individual responses received should be provided and categorised in an appropriate way.

The list should also make a further distinction within those categories by sorting responses according to whether they contain comments which have led to changes, or have led to no change.

A summary of responses by appropriate category together with a clear explanation of the reason why responses have led to no change should also be included, including where responses have been received after deadlines (para. 27 IPC Guidance Note 1).

IPC Checklist 4.1, 4.2, 4.3, 4.4

EDF Energy considers that the consultation has been carried out such that this Consultation Report is robust and detailed.

Individual responses received have been categorised according to a methodology summarised above and explained further in Chapter 5 of this report. Appendix H contains detailed responses to the comments made at each stage of the consultation and distinguishes between those comments which have led to changes to the proposals and those which have not. All responses have been organised in successive levels of detail according to themes, categories and topics. The tables identify for each response the stage at which it was made and the type of consultee who made it. There is also included a list of consultees with a reference to the topics containing their responses.

Chapter 3 of this report includes a summary of responses according to appropriate themes together with an explanation of how responses led to a change to the proposals or otherwise. The organisation of Appendix H also makes clear the summarised position of the EDF Energy position in relation to each theme/category/topic. The consideration of responses received after deadlines is discussed in Chapter 2.

CLG Guidance The design of EDF Energy’s pre-application consultation programme took account of the guidance published by CLG in September 2009 on pre-application consultation relating to the Act.

Having regard to this guidance, EDF Energy designed and implemented a multi-stage pre-application consultation process, took a broad view of who should be consulted, used a wide variety of consultation techniques, consulted with statutory consultees in parallel with the local community consultation, produced summary documentation and engaged with hard-to-reach groups particularly, during Stage 2 of its consultation. Further explanation is provided below by reference to relevant aspects of that guidance.

Stage 1: ‘Initial Proposals and Options’, 16 November 2009 – 18 January 2010.



Junction 24 and Highways Improvements consultation: ‘Proposed Changes to the Preferred Proposals – M5 Junction 24 and Highway Improvements in the Bridgwater Area’, 1 July – 12 August 2011.






Promoters may find it helpful to make informal contact with the relevant local authorities in advance of formal consultation under section 47 (para. 42 CLG's 'Guidance on pre-application consultation').

Where they have not followed the advice in a local authority’s response to the consultation on the SoCC, promoters will need to present their reasons to the IPC (para. 45 CLG's 'Guidance on pre-application consultation').

Promoters are encouraged to consult informally as early as possible on their preferred approach to consultation. Where resolution of differences is not possible, promoters are expected to gain as broad a consensus as possible and to ensure a consistency of approach across all affected authorities (para. 46 CLG's 'Guidance on pre-application consultation').

Prior to launching Stages 1 and 2 of its consultation, EDF Energy informally discussed its proposed approach to consulting local communities with the relevant local authorities. As this approach was established at those stages, EDF Energy did not consider it necessary to undertake further informal discussions prior to the Stage 2 Update and the Junction 24 and Highways Improvements consultations; and it regarded the formal statutory 28-day period for consultation with the local authorities on the SoCC as sufficient pursuant to section 47 of the Act.

The process of consultation with the local authorities on the preparation of the SoCCs is set out above in tables explaining the main comments made by the local authorities and the responses of EDF Energy to those comments. These include reasons for any departure by EDF Energy from suggestions that were made by the local authorities about the relevant SoCCs.

See further the section on Exceptions and Departures in Chapter 2 of this report.






Promoters are encouraged to view the requirement to consult people “living in the vicinity of the land” from a broad perspective and reach a reasonable judgment as to what “vicinity” means in each case. The consultation plan should address the need to consult people who fall into the categories of those who would be significantly affected by the proposals and those who would not be directly affected but who will have a reasonable fear that they might be or have strong feelings about it (para. 53 CLG's 'Guidance on pre-application consultation').

Promoters should be able to demonstrate that the consultation plan is proportionate to the impacts of the project and takes account of the level of local interest and views of the local authority (para. 54 CLG's 'Guidance on pre-application consultation').

It is recommended that promoters request information from the local authorities about the social and economic character of the area, including techniques that might be appropriate to overcome barriers to communication (para. 59 CLG's 'Guidance on pre-application consultation').

EDF Energy adopted a broad approach to determining the scope of consultation, which took into account the likely interest in the proposals: see Chapter 1 and Chapters 2 and 4, plus Appendix A.

The SoCC prepared in relation to each stage of consultation was appropriate given the nature of the proposals and the level of local interest. The views of the relevant local authorities, along with information they provided regarding local circumstances and consultation techniques, were taken into account in the preparation of the SoCCs and thereafter: see Chapter 1. Chapters 2 and 4 indicate the wide range of consultation techniques that were adopted.

Promoters should usually carry out consultation of the local community under section 47 using a range of methods as this will be more effective than written documents alone (para. 62 CLG's 'Guidance on pre-application consultation').

Consultation with the local community involved a range of techniques, including public exhibitions, community forums and media releases via the internet, television and radio. Further details are set out in Chapters 2 and 4 of this report.






Where possible, the first of the two advertisements under section 48 of the Act should approximately coincide with the beginning of consultation with communities under section 47 (para. 65 CLG's 'Guidance on pre-application consultation').

As mentioned above, due to the multi-stage nature of the consultation exercise, EDF Energy did not publish its section 48 notice until Stage 2. CLG's 'Guidance on pre-application consultation' states that “however it is recognised that this alignment may not be possible especially where a multi-stage consultation is needed” (para. 65) and this is also acknowledged in the flowchart in Annex B to the guidance. For the Stage 2 and Stage 2 Update consultations, the first of the two section 48 advertisements approximately coincided with the start of the formal community consultation. For the Junction 24 and Highways Improvements consultation, the first of the two section 48 notices was timed to coincide with the start of the informal consultation with the local communities (1 July 2011), with formal consultation starting on 15 July 2011. See too the section on Exceptions and Departures in Chapter 2 of this report.

There will be a range of bodies in addition to specified statutory consultees that may also possess important information. Promoters are encouraged to consult widely (para. 66 CLG's 'Guidance on pre-application consultation') and engage early with bodies with technical information (para. 68 CLG's 'Guidance on pre-application consultation').

EDF Energy consulted with a wide range of bodies, both formally and informally, before and during the consultation process: see Chapter 1, Chapter 2 and Chapter 4.

As far as possible, the timescales for formal consultation with communities and technical consultees should be the same (para. 70 CLG's 'Guidance on pre-application consultation').

Paragraph 70 of CLG's 'Guidance on pre-application consultation' notes that it “is not always the best approach” for formal consultation with communities and technical consultees to be the same. At Stages 1, 2 and 2 Update, the timescales for consultation under sections 42 and 47 coincided. A different approach was taken for the Junction 24 and Highways Improvements consultation. See further the section on Exceptions and Departures in Chapter 2 of this report.

Consultation must happen at a sufficiently early stage to allow consultees an opportunity to influence the proposals (para. 73 CLG's 'Guidance on pre-application consultation').

The consultation process undertaken by EDF Energy, as explained in Chapters 1, 2 and 4 of this report, has enabled early engagement along with the opportunity for statutory consultees, the local community and the general public to influence the proposals, as detailed in Appendix H.






Many projects will require considerably longer than the minimum 28-day consultation period (para. 76 CLG's 'Guidance on pre-application consultation').

As explained earlier in this chapter, EDF Energy has undertaken more than 30 weeks of formal pre-application consultation: nine weeks during Stage 1; more than 12 weeks during Stage 2; more than four weeks during the Stage 2 Update consultation period and four weeks for the focussed consultation on Junction 24 and Highways Improvements. In addition, informal consultation has continued outside the formal stages.

Technical consultees will require a clear set of written documents, outlining proposals in sufficient detail for consultees to provide their assessment of the likely impacts (para. 81 CLG's 'Guidance on pre-application consultation').

A short document should be prepared specifically for local communities summarising the proposals and their aims and objectives, explaining their potential impacts and outlining the matters on which the view of the local community is sought (para. 82 CLG's 'Guidance on pre-application consultation'). The document should be written in clear, accessible and non-technical language (para. 83 CLG's 'Guidance on pre-application consultation').

Chapter 2 explains the consultation process that was undertaken with statutory consultees, including the documents that were provided. These documents (Appendix C) outlined the proposals in sufficient detail to enable an assessment of the impacts of the proposals.

At Stages 1 and 2 of the consultation, a large amount of information was published by EDF Energy and it was therefore considered appropriate to publish a summary document. The Stage 2 Update and Junction 24 and Highways Improvements consultations were more limited and focused stages which did not seek to re-consult on the proposals as a whole. For these stages, the consultation documents were relatively brief and it was concluded that it would not be appropriate to produce a summary document, although for the slightly longer Stage 2 Update document, an executive summary was provided. See the section on Exceptions and Departures in Chapter 2 of this report for further details.

Promoters are encouraged to engage iteratively before they undertake formal consultation and to consult throughout the application process and beyond (para. 85 CLG's 'Guidance on pre-application consultation').

EDF Energy carried out a process of informal engagement before undertaking formal consultation, as explained in Chapter 1. EDF Energy will continue to engage with all parties throughout the application process: see Chapter 2.

Consultation report should provide a general description of the consultation process (para 96 CLG's 'Guidance on pre-application consultation').

This report provides a general description of the consultation process in Chapter 1 and in Chapters 2 and 4 of this report.






Consultation report should set out specifically what EDF Energy has done in compliance with the requirements of the Planning Act 2008, CLG’s ‘Guidance on pre-application consultation’, and any relevant guidance published by the IPC (para 96 CLG's 'Guidance on pre-application consultation').

IPC Checklist 5.20

This report sets out in this table how EDF Energy has responded to the guidance issued by the IPC and CLG.

Consultation report should set out how EDF Energy has taken account of any response to consultation with local authorities on what should be in the promoter’s SoCC in accordance with s47(2) Planning Act 2008 (para 96 CLG's 'Guidance on pre-application consultation').

Chapter 1 explains how EDF Energy took into account the views of local authorities regarding the preparation of the SoCCs.

Consultation report should set out a summary of relevant responses to consultation (but not a complete list of responses) (para 96 CLG's 'Guidance on pre-application consultation').

Chapter 3 of this report provides a quantitative and qualitative analysis of consultation responses, which summarises the main themes raised during consultation and how the proposals were influenced by the consultation responses. The full details of comments made in the responses are set out in Appendix H, along with EDF Energy’s response. These details explain whether a comment resulted in a change to the proposals.

Consultation report should provide a description of how the application was influenced by relevant responses to consultation, outlining any changes made as a result and showing how significant relevant responses will be addressed (para 96 CLG's 'Guidance on pre-application consultation').

See above.






Consultation report should provide an explanation as to why any significant relevant responses were not followed, including advice on impacts from a statutory consultee (para 96 CLG's 'Guidance on pre-application consultation').

See above.

Where EDF Energy has not followed the advice of the local authority, not complied with CLG’s ‘Guidance on pre-application consultation’ or any relevant guidance published by the IPC, the consultation report should provide an explanation for the action taken (para. 96 CLG's 'Guidance on pre-application consultation').

EDF Energy considers that it has complied with IPC and CLG Guidance, for reasons set out in this table, subject to identified exceptions and departures that are explained in this table and in the Exceptions and Departures section of Chapter 2.

Consultation report should be expressed in terms sufficient to enable the IPC to fully understand how the consultation process has been undertaken, and significant effects addressed, but need not include full technical explanations of these matters (para. 97 CLG's 'Guidance on pre-application consultation').

This Consultation Report has been structured to provide an overview of the consultation process (Chapter 1), followed by a more detailed explanation of the detailed steps that have been taken by EDF Energy to undertake consultation both under the Act and informally (Chapters 2 and 4). Chapter 3 explains by reference to a quantitative and qualitative analysis the main outcomes of that process and how themes of consultation influenced the proposals. Appendix H then provides detailed replies to each consultation response, indicating the extent to which any comment has affected the proposals. These Appendices can be navigated according to a methodology described in Chapter 5 of this report.

Consultation report should provide feedback to those who have contributed to the consultation to inform them of the results of the consultation exercise and to inform them how the information received by EDF Energy has been used to shape and influence the proposals, along with how any outstanding issues will be addressed (para 98 CLG's 'Guidance on pre-application consultation').

See above.






As with the consultation, different audiences will require different levels of information. It is recommended that promoters make the consultation report available to consultees. However, this may not be the most appropriate format to provide feedback to the various consultee groups and bodies (paras 99-100 CLG's 'Guidance on pre-application consultation').

Promoters should therefore consider producing a summary report aimed at the local community setting out headline findings and how they have been addressed, together with a link to the full consultation report for those interested (para. 100 CLG's 'Guidance on pre-application consultation').

This consultation report includes an executive summary, the text of which will be made available to the local community with a link to the full report via the Project website.

Promoter should make a judgment as to whether the consultation report provides sufficient detail on the relevant impacts for consultees with technical information (para. 100 CLG's 'Guidance on pre-application consultation').

EDF Energy considers that this report provides substantial information on the relevant impacts of the proposals for consultees with technical information. The detailed responses of EDF Energy to all comments raised during the consultation are set out in Appendix H.






CLG's 'Planning Act 2008: Guidance for Local Authorities', March 2010.

In most cases, promoters will need to discuss the preparation of the SoCC with local authorities over a longer period than the minimum requirements set out in the Act (para. 38 CLG's ' Guidance for Local Authorities').

Topics which could be considered at such discussions could include the size and coverage of the proposed consultation exercise and the design, format and timing of consultation (para. 40 CLG's ' Guidance for Local Authorities').

Where the advice of a local authority is not followed, in practice the promoter will need to present its reasons to the IPC (para. 41 CLG's ' Guidance for Local Authorities').

EDF Energy took into account CLG's 'Guidance for Local Authorities' following its publication in March 2010. In particular, EDF Energy had regard to the guidance on how to most effectively carry out consultation with the local authorities in respect of the SoCC.

On a number of occasions, EDF Energy held informal discussions with the local authorities outside of the statutory 28 days for consultation on the SoCC to help inform the preparation of the draft SoCC for formal consultation. Although this guidance was published after the consultation on SoCC 1, the consultation with the local authorities was carried out in a manner that reflected much of the spirit of this guidance.

The discussions with local authorities covered a wide range of topics including those referred to in the guidance.

Whilst EDF Energy has sought to agree an approach to community consultation with the relevant authorities, it has not always been able to follow their advice in all respects. An explanation for any differences is set out in Chapter 1.






HM Code of Practice on Consultation, July 2008

1. Consultation should take place at a stage when there is scope to influence the policy outcome.

2. Consultation should normally last for at least 12 weeks.

3. Consultation documents should be clear about the process, what is being proposed, the scope to influence and the expected impacts and benefits of the proposals.

4. Consultation exercises should be accessible to all and clearly targeted at those people it is intended to reach.

5. The burden of consultation should be kept to a minimum.

6. Consultation responses should be analysed carefully and clear feedback provided to participants.

7. Those running consultations should seek guidance in how to run an effective consultation exercise.

EDF Energy’s pre-application consultation programme has taken into account the seven key consultation criteria in the following ways:

1. All stages of the consultation process were undertaken when there was still scope to influence the plans.

2. In total, EDF Energy has undertaken more than 30 weeks of formal pre-application consultation: nine weeks during Stage 1; more than 12 weeks during Stage 2; more than four weeks during the Stage 2 Update consultation period and four weeks for the consultation on Junction 24 and Highways Improvements. In addition, informal consultation has continued outside of the formal stages.

3. The scope of the consultation and the expected impacts and benefits have been clearly outlined in the consultation documentation.

4. EDF Energy has sought to make the consultation accessible to all, and to target it at those most affected by its proposals, by using a wide variety of consultation and communication techniques and holding events close to the proposed development sites.

5. EDF Energy has sought to co-ordinate its events and activities with related consultations wherever possible to minimise the burden of consultation.

6. All consultation responses have been carefully analysed, recorded and responded to in this consultation report; EDF Energy has also provided direct feedback where appropriate and through a variety of communication techniques.

7. EDF Energy has sought advice on running an effective consultation exercise from the three Somerset local authorities within whose boundaries its development is proposed, as well as other bodies including, for example, Planning Aid South West.










Local Authority Statements of Community Involvement.

The adopted SCIs of SCC, WSC and SDC were taken into account by EDF Energy in designing its pre-application consultation process.

In particular, the majority of the consultation techniques suggested by WSC and SDC for major planning applications were deployed. Account was taken of the need to engage with hard-to-reach groups and the outcome of the consultation process has been reported back to the community.






1.3 Related Consultation

1.3.1 There were a number of related consultations that took place during the overall consultation period for the Hinkley Point C Project. Where possible, every effort was made to coordinate the consultations to avoid confusion among the public and consultation fatigue. Those consultations most closely related to the Hinkley Point C Project are explained below.

a) Strategic Siting Assessment Nominations

1.3.2 In the White Paper on Nuclear Power (January 2008), the Government set out its view that it is in the public interest that new nuclear power stations should play a role in the UK’s future energy mix alongside other low-carbon sources of electricity and that energy companies be allowed the option of investing in new nuclear power stations. The Government also set out a number of “facilitative actions” that it would undertake to reduce the regulatory and planning risks associated with investment in new nuclear power stations.

1.3.3 The SSA was a process for identifying and assessing sites that are strategically suitable for the deployment of new nuclear power stations by the end of 2025, the Government’s target. The aim of the Department for Business, Enterprise and Regulatory Reform (BERR)’s SSA consultation in July 2008 was to present, and seek the views of interested parties on, the proposed:

process for inviting and accepting nominations for sites;

process for assessing nominated sites; and

criteria for assessing sites for potential new nuclear power stations.

1.3.4 Hinkley Point was mentioned by EDF Energy as a potential site in response to the invitation to nominate sites issued by BERR in January 2009.

b) Government National Policy Statement Consultation

1.3.5 The Government published its draft Nuclear NPS for consultation early in November 2009. The draft Nuclear NPS was part of a number of technology-specific draft NPSs for energy that, together with the draft Overarching National Policy Statement for Energy (EN-1), clearly set out the Government’s ambitions for the delivery of major new low carbon energy infrastructure, including new nuclear power stations, by 2025. The draft Nuclear NPS listed a number of sites as being potentially suitable for the development of new nuclear power stations by 2025, including EDF Energy’s land at Hinkley Point C, and invited views on whether these sites should be identified for this purpose.

1.3.6 A first round of public consultation on the draft Nuclear NPS opened on 9 November 2009 and closed on 22 February 2010. As part of the consultation process, the Department of Energy and Climate Change (DECC) organised a number of national and local events to publicise the draft Nuclear NPS and to enable questioning of officials and provide opportunities for people to make their views known.




1.3.7 Two specific consultation events were held by DECC in the vicinity of Hinkley Point. These were at Bridgwater on 19 to 21 November 2009 (shortly after publication of the draft Nuclear NPS) and a supplementary meeting at Stogursey, close to the Hinkley Point C site, on 27 January 2010. EDF Energy had no direct involvement in these events, although representatives of EDF Energy were present and DECC was supplied with copies of EDF Energy’s Stage 1 public consultation materials so these could be made available to the public attending their events.

1.3.8 EDF Energy published its Stage 1 ‘Initial Proposals and Options’ documentation shortly after publication of the draft Nuclear NPS. The EDF Energy consultation therefore took place against the background of a draft national policy suggesting that Hinkley Point is potentially suitable for new nuclear development. All EDF Energy’s Stage 1 consultation events were timed to take place after DECC’s own local consultation event near Hinkley Point on the draft Nuclear NPS. However, a supplementary consultation event subsequently arranged by DECC in Stogursey in late January 2010 did take place after the close of EDF Energy’s Stage 1 consultation.

1.3.9 A second round of consultation was undertaken by DECC on revised drafts of the NPSs for energy, including the Overarching Energy NPS and the Nuclear NPS, from 18 October 2010 to 24 January 2011. The consultation focused on the changes made to the draft NPSs and the related Appraisals of Sustainability following the previous consultation and Parliamentary scrutiny. Three consultation events were organised in Bristol (29 November 2010), Manchester (30 November 2010) and London (2 December 2010). Officials from DECC also attended meetings organised by local authorities and local interest groups over the consultation period; the most local to Hinkley Point was a Bridgwater meeting on 12 January 2011. This consultation took place after EDF Energy’s Stage 2 ‘Preferred Proposals’ consultation, which ran from 9 July to 4 October 2010 and before its Stage 2 Update consultation, which ran from 25 February to 28 March 2011.

1.3.10 On 23 June 2011, the Government laid before Parliament for approval a final set of the six draft NPSs for energy, including the Overarching Energy NPS and the Nuclear NPS. On 18 July 2011, the House of Commons debated and approved the NPSs then on 19 July 2011, the Secretary of State for Energy and Climate Change designated the NPSs under the Act. The Nuclear NPS, taken together with the Overarching Energy NPS, provides the primary basis for decisions taken by the IPC on applications for development consent for nuclear power generation with a capacity of more than 50 megawatts on a site listed in the Nuclear NPS.

1.3.11 The timing of publication of EDF Energy’s proposals and the sequencing of the consultation events was important in helping to explain to stakeholders and the local community the difference between the Government’s consultation on the need for nuclear power stations and the principle of whether or not Hinkley Point is suitable for new nuclear development, and EDF Energy’s consultation on proposals for how such development could take place.

c) National Grid Hinkley Point C Connection Project

1.3.12 National Grid is currently in the process of consulting on its plans to provide a new high-voltage transmission connection between Bridgwater and Seabank near




Avonmouth, together with modifications and upgrades to the overhead lines in the vicinity of Hinkley Point.

1.3.13 This infrastructure is required to connect the proposed nuclear power station at Hinkley Point C, and other planned electricity generation projects in the South West of England, to the National Grid high-voltage electricity transmission system.

1.3.14 As with EDF Energy, National Grid is consulting prior to the submission of a separate DCO application to the IPC (or any successor body).

1.3.15 Stage 1 of National Grid’s consultation on two broad overhead line route corridors started on 12 October 2009 and closed on 22 January 2010, a parallel process to EDF Energy’s own Stage 1 consultation. National Grid’s consultation period was extended from the original 12 weeks by a further two weeks at the beginning of January 2010. This period of consultation was subsequently extended until 23 July 2010 to allow National Grid to provide further information and receive additional feedback on its proposals. On 29 September 2011, National Grid announced its preferred route corridor from Avonmouth to Bridgwater.

1.3.16 National Grid and EDF Energy are separate companies consulting on separate but related proposals. In order to minimise any public confusion about these related consultations, EDF Energy co-ordinated some of its consultation activities with National Grid where there was geographical overlap between the projects.

1.3.17 Given the linear nature of National Grid’s proposals, its consultation covered many local communities between Avonmouth and Bridgwater that are not directly affected by EDF Energy’s plans at Hinkley Point C. The geographic overlap between EDF Energy’s and National Grid’s consultations was largely confined to communities between Bridgwater and Hinkley Point, in the area where National Grid’s proposals predominantly involve upgrading existing overhead lines and the connection arrangement to the proposed new substation.

1.3.18 EDF Energy and National Grid held a joint public exhibition on their respective plans in Stogursey on 2 December 2009. In addition, at the other EDF Energy Stage 1 exhibitions that were outside the National Grid consultation area, a small display of unstaffed exhibition boards was also provided. The National Grid consultation was also referenced in EDF Energy newsletters and on its consultation website.

1.3.19 National Grid held further public consultation events in June 2010 and had a small, staffed exhibit at all of EDF Energy’s Stage 2 ‘Preferred Proposals’ public exhibitions in July 2010. During EDF Energy’s Stage 2 Update and Junction 24 and Highways Improvements consultations, National Grid was not undertaking any of its own consultation and there was therefore no need to co-ordinate consultation events.

1.3.20 In addition, National Grid is a regular attendee of the HPC Community Forum (see Chapters 3 and 4).

1.3.21 EDF Energy believes that the co-ordination with National Grid was important in helping the public to understand the links between the two projects and the issues on which each organisation was consulting.




d) Environment Agency’s Consultations

1.3.22 The Environment Agency (EA) undertook a consultation on the Generic Design Assessment (GDA) of two new nuclear reactor designs (UK EPR submitted by EDF and AREVA NP, and AP1000 submitted by Westinghouse) from 28 June to 18 October 2010.

1.3.23 In order to inform the public and make the EA’s consultation as accessible as possible to those interested in the proposals for Hinkley Point C, the EA had a staffed stand at EDF Energy’s Stage 2 ‘Preferred Proposals’ exhibitions in July 2010.

1.3.24 EDF Energy also included an article provided by the EA in its November 2010 newsletter announcing the end of the EA's consultation and what the next steps would be.

1.3.25 The EA is also a regular attendee at EDF Energy’s Community Forum meetings for Hinkley Point C and provided updates at key stages of the GDA process. For example, at the request of the EA, a specific agenda item on the GDA consultation process was included for discussion at the Community Forum meeting held on 8 July 2010. The EA also gave a presentation on the licence applications and consultation at the Community Forum meeting on 3 March 2011.

1.3.26 The EA also set up a dedicated website for the Hinkley Point C Project in 2011, which EDF Energy advertised in its April/May 2011 newsletter.

1.3.27 EDF Energy has made three applications under the Environmental Permitting Regulations. The permits will be necessary in due course to allow the proposed Hinkley Point C power station to make small, well controlled liquid and gaseous radioactive discharges and dispose of solid radioactive wastes to licensed storage or disposal sites (the Radioactive Substances Regulation Permit), to undertake test running of its stand-by diesel generators (the Combustion Activity Permit), and to discharge cooling water and non-radioactive liquid effluents (the Water Discharge Activity Permit).

1.3.28 The applications were made in late July 2011 for the Radioactive Substances Regulation Permit and Combustion Activity Permit applications and late September 2011 for the Water Discharge Activity Permit application. The EA has begun consulting on these applications and its consultation is expected to continue into December 2011. To assist with this consultation, EDF Energy hosted the Environmental Permit applications' documents on its consultation website for the public to access. The EA may engage in additional consultation on its draft decision.

e) Councils’ Planning Consultations

1.3.29 EDF Energy was made aware of a number of other relevant planning consultations being undertaken by the local authorities around the same time as its different stages of consultation on the Hinkley Point C Project.

1.3.30 At its Stage 1 consultation on Initial Proposals and Options, these included:




Sedgemoor District Council’s consultation on its Local Development Framework, Core Strategy Preferred Options. Public consultation started on 30 September 2009 and closed on 24 November 2009.

Somerset County Council’s consultation on its Minerals and Waste Development Framework, Core Strategy Preferred Options that closed in November 2009.

The North Devon and Somerset Coastal Advisory Group, supported by the EA, undertook public consultation on the draft North Devon and Somerset Shoreline Management Plan from 9 October 2009 through to 8 January 2010. Consultation events in the vicinity of Hinkley Point took place during October 2009.

1.3.31 EDF Energy was aware of a number of related local authority consultations at a similar time to its Stage 2 consultation on ‘Preferred Proposals’:

Sedgemoor District Council published its proposed submission Core Strategy, part of its Local Development Framework, on 28 September 2010 for public consultation for a six-week period.

West Somerset Council and Sedgemoor District Council, through the Community Council for Somerset, undertook their own consultation during Summer 2010 with local communities in the vicinity of the Hinkley Point C and associated development sites, in relation to EDF Energy’s plans. This consisted of ‘preparatory community engagement’ with local communities in early July 2010 on EDF Energy’s process and timetables. Further community support meetings were held in September 2010, plus four targeted theme meetings on housing/accommodation, transport, environment and community wellbeing.

1.3.32 For the Stage 2 ‘Update on and Proposed Changes to Preferred Proposals’ consultation, EDF Energy was aware that West Somerset and Sedgemoor District councils were consulting on a draft Hinkley Point Nuclear Supplementary Planning Document from 1 March until 12 April 2011, with consultation events in the area from 7 – 17 March 2011.

1.3.33 For the Junction 24 and Highways Improvements consultation: ‘Proposed Changes to the Preferred Proposals including Junction 24 and Highway Improvements in the Bridgwater Area’ consultation, EDF Energy was not aware of any other, related consultations.

1.3.34 Where possible, EDF Energy’s consultation events were arranged to avoid clashes with these related consultations, in particular in respect of events taking place in the vicinity of Hinkley Point.

f) EDF Energy Preliminary Works Applications

1.3.35 In order to enable the completion of a new nuclear power station at Hinkley Point C as quickly and efficiently as possible, subject to approval from the IPC, EDF Energy submitted preliminary applications to the appropriate planning authorities prior to submission of its DCO application to the IPC.

1.3.36 Consultation by EDF Energy on preliminary works applications for Hinkley Point C took place during Stages 1 and 2, as well as in the intervening period.




1.3.37 This consultation on the preliminary works applications was combined with the formal DCO application consultation stages due to their close relationship with the overall Project and to minimise any potential confusion or consultation fatigue.

1.3.38 Originally, the proposed preliminary works consisted of three elements:

erection of a temporary jetty to enable bulk materials to be transported by sea;

securing the site with a fence and sea wall; and

Site Preparation Works: making the site ready for the main works by clearing the vegetation, installing construction drainage infrastructure, terracing the site and installing the haul routes and new site accesses, among other things.

1.3.39 Following the Stage 1 consultation, however, the scope of the preliminary works proposals was amended. The sea wall was taken out and included in the DCO application and the fence was included within the Site Preparation Works application.

1.3.40 The Site Preparation Works planning application was submitted to West Somerset Council on 26 November 2010. The application had previously been the subject of an EIA scoping exercise carried out by the council in May 2010.

1.3.41 West Somerset Council undertook its own consultation on the application between 6 December 2010 and 12 January 2011. The Council held two public meetings – at Stogursey on 4 January 2011 and at Cannington on 5 January 2011. The consultation was extended to the 31 January 2011 following requests by consultees.

1.3.42 Following the close of this initial consultation period and taking account of all the issues and requests for clarification raised by statutory bodies and members of the public, as well as by the Council’s own technical team, the Council wrote to EDF Energy on 11 March 2011 requesting further information and clarification. EDF Energy submitted its response on 26 April 2011. West Somerset then conducted a second round of consultation on the submitted information. Taking account of the Easter bank holidays and Royal Wedding bank holiday, this consultation was to close on 20 May 2011 but was extended until 31 May 2011 following requests from consultees.

1.3.43 West Somerset Council resolved to grant planning permission for the Site Preparation Works at Committee on 28 July 2011, subject to conditions. Consent for the proposed site preparation works is also being sought through the draft DCO.

1.3.44 Applications for the proposed temporary jetty were submitted on 10 December 2010 to the Marine Management Organisation (MMO) for a Harbour Empowerment Order under the Harbours Act 1964 to the Department for Energy and Climate Change (DECC) on 14 December 2010 for a Transport and Works order under the Transport and Works Act 1992. At the same time, EDF Energy also submitted applications to the MMO for two licences under the Food and Environment Protection Act 1985 for the jetty. The applications are scheduled for consideration at a public inquiry opening on 15 November 2011. The inquiry is anticipated to last two to three weeks.






1.3.45 Following submission, the applications were subject to statutory consultation by the MMO and DECC, during which time members of the public, amenity groups, councils and other stakeholders were invited to consider the application documentation and provide any comments on these to the respective organisations.

1.3.46 The nature of the representations received was varied and, in response, EDF Energy prepared and submitted in June 2011 an addendum to the ES, which included further environmental information where necessary as well as information for clarification purposes. In preparing the Environmental Statement Addendum, EDF Energy consulted various stakeholders who submitted representations including the local councils, the Environment Agency, English Heritage and others. At the same time, EDF Energy also published Habitats Regulations information and amendments to the Harbour Empowerment Order.

1.3.47 The temporary jetty is a crucial part of EDF Energy’s transport strategy for the construction of Hinkley Point C, as it will enable the majority of bulk material required during the construction phase to be brought directly to the site without having to use the local road network. As such, it has also been included in EDF Energy’s DCO application to the IPC.

1.3.48 Consultation statements were submitted in support of the preliminary works applications. These statements summarised EDF Energy’s pre-application consultations, outlining the key issues raised/comments received and EDF Energy’s responses to these issues/comments. Copies of these documents can be found at Appendix B and are also available from West Somerset Council and the MMO. Links to these documents are available on EDF Energy’s project website: http://hinkleypoint.edfenergyconsultation.info/hinkley-info/preliminary-works/

g) Related Consultations: Summary

1.3.49 Table 1.7 below sets out details of the relevant consultations on national, regional, county and local level planning policy that have occurred since November 2009.

1.3.50 Table 1.8 provides details of consultations on planning applications on other projects. Both tables identify the relationship with the consultation by EDF Energy on the Hinkley Point C Project.


Table 1.7: Planning Policy Consultations (November 2009 to current)

Policy Document Responsible Body

Status Next Stage

(Anticipated) Date of Adoption

Details of Consultation Relationship with HPC Project and EDF Energy’s Consultation

National Planning Policy

National Policy Statements

Draft Overarching NPS for Energy (EN-1)

Draft NPS for Nuclear Power Generation (EN-6)

Draft Electricity Networks NPS (EN-5)

Department of Energy and Climate Change

Superseded N/A N/A Published for consultation from 9 November 2009 to 22 February 2010.

The consultation coincided with EDF Energy’s Stage 1 consultation (16 November 2009 to 18 January 2010).

Revised draft Overarching NPS for Energy (EN-1)

Revised draft NPS for Nuclear Power Generation (EN-6)

Revised draft Electricity Networks NPS (EN-5)

Department of Energy and Climate Change

Superseded N/A N/A The revised drafts of the energy NPSs were published for public consultation from 18 October 2010 to 24 January 2011.

Final versions of the energy NPSs were laid before Parliament for approval on 23 June 2011. The NPSs were subsequently designated on 19 July 2011.

Primary policy documents against which the Hinkley Point C Project DCO application will be determined.

The final designated Nuclear NPS re-affirms Hinkley Point as a potentially suitable site for the deployment of new nuclear power stations by the end of 2025.

National Planning Policy Framework

National Planning Policy Framework (NPPF)

Department for Communities and Local Government

Formal consultation on NPPF (25 July to 17 October 2011)

2012 A draft of the NPPF was published for consultation on 25 July 2011.

The consultation coincided with EDF Energy’s Junction 24 and Highways Improvements consultation (1 July to 12 August 2011).

National planning policy document.







Status Next Stage



Planning Policy Statements/Guidance

Planning for a Low Carbon Future in a Changing Climate


Post-consultation

Adoption End 2010 (still awaited)

The consultation paper was published for public consultation from 9 March 2010 to 1 June 2010.


Planning for a Natural and Healthy Environment


Post-consultation

Adoption End 2010 (still awaited)

The consultation paper was published for public consultation from 9 March 2010 to 1 June 2010.


Sub-Regional Planning Policy

Draft North Devon and Somerset Shoreline Management Plan 2

North Devon and Somerset Coastal Advisory Group

Post-consultation

Adoption Autumn 2010 (still awaited)

The draft management plan was published for public consultation from 9 October 2009 to 8 January 2010.

Sub-regional policy document.

The consultation coincided with EDF Energy’s Stage 1 consultation (16 November 2009 to 18 January 2010).

Severn Estuary Flood Risk Management Strategy

Environment Agency

Post-consultation

Adoption Likely 2012 The draft strategy was published for public consultation from 24 January 2011 to 18 March 2011.

Sub-regional policy document.

The consultation coincided with EDF Energy’s Stage 2 Update consultation (25 February to 28 March 2011).

Somerset County Council Policy

Somerset’s Future Transport Plan 2011-2026

Somerset County Council

Adopted N/A February/ March 2011

The consultation draft of the plan was published for public consultation from 29 November 2010 to 7 January 2011.

On 16 February 2011, Somerset County Council resolved to adopt the Future Transport Plan.

County level policy document.





Status Next Stage



On 28 March 2011, the Cabinet Member for Strategic Planning and Economic Development decided to adopt the Schedule of Policies, Transport and Development documents, and the Implementation Plan for 2011/2012.

Rights of Way Improvement Plan


Pre-consultation

Formal consultation on draft plan

TBC On 5 April 2011 the Somerset County Council Cabinet Member, Strategic Planning and Economic Development, approved the Draft Rights of Way Improvement Plan 2 for public consultation


Somerset Waste Core Strategy


Draft for consultation

Formal consultation on the pre-submission document

Autumn 2012 The ‘Waste Planning: Issues and Options (II)’ was published for public consultation from 16 March 2011 to 11 May 2011.


The consultation overlapped with EDF Energy’s Stage 2 Update consultation (25 February 2011 to 28 March 2011).

Local Planning Policy

West Somerset Council Planning Policy

Core Strategy West Somerset Council

Draft for consultation

Formal consultation on the preferred strategy (likely release September 2011)

April 2013 The Core Strategy Options Paper was published for public consultation from 29 March 2010 to 24 May 2010.

Local planning policy document.





Status Next Stage



Williton Village Masterplan

West Somerset Council

Post-consultation

Formal consultation on draft masterplan

TBC The draft Williton Village Masterplan was published for public consultation from 10 June 2011 to 22 July 2011.


The consultation coincided with EDF Energy’s Junction 24 and Highways Improvements consultation (1 July to 12 August 2011).

Sedgemoor District Council Planning Policy

Core Strategy Sedgemoor District Council

Post-consultation

Adoption Likely October 2011

The Core Strategy Preferred Options was published for consultation from 30 September to 18 December 2009.

The Core Strategy Proposed Submission was published for consultation from 28 September 2010 to 22 November 2010.

An addendum to the Core Strategy in respect of a preferred housing area of search at Burnham-on-Sea and Highbridge was published for consultation from 23 November 2010 to 18 January 2011.

Changes prior to submission, proposed as a result of the consultation process were endorsed by Sedgemoor District Council’s Executive Committee on 9 February 2011.

The Core Strategy Proposed Submission version was submitted to the Secretary of State on 3 March 2011.

An Examination in Public was held from 24 May 2011 to 3 June 2011.


The Preferred Options consultation coincided with EDF Energy’s Stage 1 consultation (16 November 2009 to 18 January 2010).

The Proposed Submission consultation coincided with EDF Energy’s Stage 2 consultation (9 July 2010 to 4 October 2010).





Status Next Stage



West Somerset Council and Sedgemoor District Council Joint Supplementary Planning Guidance

Hinkley Point C Project Joint Supplementary Planning Document

West Somerset Council and Sedgemoor District Council

Post-consultation

Adoption October 2011 The document was published for public consultation from 1 March 2011 to 12 April 2011.


The consultation coincided with EDF Energy’s Stage 2 Update consultation (25 February 2011 to 28 March 2011).

Other Sedgemoor District Council Planning Documents

Bridgwater Gateway Design Principles

Sedgemoor District Council

Adopted N/A March 2011 Following Sedgemoor District Council’s Executive adoption of the Design Principles report on 9 February 2011, the document was released for a limited consultation with key partners and consultees before being adopted by the Full Council on 30 March 2011.


The consultation coincided with EDF Energy’s Stage 2 Update consultation (25 February 2011 to 28 March 2011).


Table 1.8: Planning Applications/Other Project Consultations (November 2009 to current)

Scheme Name Planning Application Details Status Details of Consultation Relationship with HPC Project

Planning Permissions/Applications

Somerset County Council Planning Application

Enabling Works Proposed remediation of built development area east at Hinkley Point to include the re-use of existing stockpiled materials, construction of temporary areas of hardstanding including a temporary helipad, creation of temporary segregation and stockpile areas and erection of temporary contractor office facilities (Ref. 3/32/10/025).

Application submitted by EDF Energy on 17 August 2010.

Application considered at Planning Committee on 6 January 2010.

Planning permission granted on 5 August 2010.

Public consultation completed as part of planning application process.

Within Hinkley Point C Project site.

Application considered during EDF Energy’s Stage 1 consultation (16 November 2009 to 18 January 2010).

West Somerset Council Planning Applications

Site Preparation Works Hinkley Point C site clearance, earthworks, provision of earth retaining structures, deep excavations, provision and relocation of drainage infrastructure, the provision and operation of plant and machinery, site establishment works, and other associated works. (Ref. 3/32/10/037).

Application submitted by EDF Energy on 26 November 2010.

Application considered at Planning Committee on 28 July 2011 (resolved to grant planning permission subject to conditions and the completion of a Section 106 legal agreement).



Application considered during EDF Energy’s Stage 2 Update consultation (25 February 2011 to 28 March 2011) and Junction 24 and Highways Improvements consultation (1 July 2011 to 12 August 2011).

Hinkley Point C Environmental Monitoring Applications

Several applications for: temporary excavation of trenches to investigate the depth and nature of the subsoil above the rock; ecological improvements (construction of badger setts); primary survey network (permanent markers); and bat barn.

Various planning applications submitted by EDF Energy.



Various applications considered during Hinkley Point C pre-application consultation exercise.







Sedgemoor District Council Planning Applications

North East Bridgwater Land off A38, Bristol Road and A39, Bath Road and generally bounded by M5 Motorway and railway line, including habitat creation area to the east of the M5, Bridgwater. Mixed use development to provide, inter alia, up to 2,000 dwellings, commercial services centre, retail floorspace, employment development, community facilities, trade units and car showrooms, sports and recreation facilities. (Ref. 09/08/00017).

Application submitted by a third party on 22 December 2008.

Application considered at Development Control Committee on 30 September 2009.

Planning permission granted on 2 July 2010.


‘Bridgwater A’ associated development site within the development boundary for the Hinkley Point C Project.

Steart Coastal Management Project (Trial section of embankment)

Land at OS Field No. 0002 and OS Field No. 0005 at, Steart Peninsula, Steart Drove, Steart, Bridgwater. Advance works in relation to creation of intertidal habitat including formation of trial embankment (area D), borrow pit and creation of freshwater habitat (area B). (Ref. 47/10/00009).

Application submitted by a third party on 24 November 2010.

Planning Permission granted 2 February 2011.


Project of regional environmental significance considered cumulatively with the Hinkley Point C Project in the ES.

Bridgwater Gateway Land to the south-west of Stockmoor Distributor Road and north-west of, Taunton Road, North Petherton, Bridgwater. Formation of a mixed-use development to include employment floor space, public house, hotel, freight staging facility, petrol station and a 'park and ride' facility. (Ref. 37/10/00116).

Application submitted by a third party on 23 December 2010.

Application considered at Development Control Committee on 26 April 2011. Resolved to defer the application for approximately two months to continue discussions and negotiations in relation to a number of issues.

Application considered at Development Control Committee on 19 July 2011, where it was resolved to refuse planning permission.


Alternative ‘Junction 24’ associated development site within the development boundary.






‘Construction Skills Centre’ Training Facility

The Downs, Rodway, Cannington, Bridgwater, TA5 2LS. Change of Use of agricultural land to training facility including provision of classroom block, plant storage buildings and training tower. (Ref. 13/11/00005).

Application submitted by a third party on 10 March 2011.

Application considered at Development Control Committee on 12 April 2011.

Planning permission granted on 4 May 2011.


Facility to provide job related training for HPC Project and other construction projects.

Application considered during EDF Energy’s Stage 2 Update consultation (25 February 2011 to 28 March 2011).

Bridgwater College ‘Arts Centre’

Land to the north east of, College Way, Bridgwater, TA6 4TZ. Erection of building to form performing arts centre to include a 350 seat flexible auditorium, a dance studio with associated changing, technical and teaching spaces, a small cafe, public amenities and parking. (Ref. 08/11/00093).

Application submitted by a third party on 25 May 2011.

Application to be determined.


Application site situated in close proximity to the ‘Bridgwater C’ associated development site.

Other Applications

MMO Applications

Temporary Jetty Harbour Empowerment Order to enable the construction of a temporary jetty at Hinkley Point. (Ref. DC9229).

Application submitted by EDF Energy on 10 December 2010.

Public Inquiry arranged to start from 15 November 2011.

Target for determination April 2012.


Within Hinkley Point C Development Site.






Temporary Jetty Applications under the Food and Environment Protection Act 1985 for licences to install piles etc. in the sea bed to support the jetty and to carry out dredging and dispose of dredging spoil. (Ref. DC9228 and DC9235).


Public inquiry arranged to start from 15 November 2011.



Within Hinkley Point C Development Site.


Department of Energy and Climate Change Application

Temporary Jetty Order under the Transport and Works Act 1992 to allow the compulsory acquisition of land and interests in, on and over land to enable the temporary jetty to be constructed. (Ref. TWA/10/APP/07).


Public Inquiry arranged to start from 15 November 2011.



Within Hinkley Point C Project Development Site.


Office for Nuclear Regulation – Nuclear Site Licence

HPC Nuclear Site Licence Application submitted by EDF Energy on 29 July 2011.

NNB GenCo application to the Office for Nuclear Regulation (ONR) for a Nuclear Site Licence to install and operate a nuclear installation at its site located at Hinkley Point pursuant to the Nuclear Installation Act 1965.

Licence application submitted on 29 July 2011.

No consultation required by licensing process.

Being considered by ONR. Pre-requisite for the construction and operation of nuclear safety-related parts of the development.





Environment Agency Permits

Environmental Permit applications by EDF Energy to the Environment Agency (EA).

NNB GenCo EDF Energy application to the Environment Agency for Environmental Permits.

discharges to controlled waters during construction of HPC Development Site (23/9/11);

discharges to controlled waters during operation of the HPC Development Site (23/9/11);

discharges of radioactive substances during operation of the HPC Development Site (29/7/11); and

operation of combustion activities during operation of the HPC Development Site (29/7/11).

Submission is pending on the following:

discharges to controlled waters during the construction phase of the development (Combwich Wharf);

discharge of sewage effluent into controlled waters (Cannington park and ride);

discharge to controlled waters (Williton park and ride);

discharge of sewage effluent into controlled waters (Junction 23 park and ride and freight management facility);

discharge of sewage effluent into controlled waters (Junction 24 park and ride and freight management facility);

ed waters discharges to controll(Bridgwater A campus);

a waste operation (Williton); and

discharge to controlled waters (Junction 24 park and ride and freight management facility).

Undergoing EA consultation process.

Permits required for the construction and subsequent operation of the facility.





Other Projects

Steart Coastal Management Project

N/A – Pre-Planning Planning application anticipated to be submitted by a third party in autumn 2011.

The Steart Scoping Consultation Document was published for consultation from 23 March 2010 to 20 April 2010.


Bristol Port Company – Steart Compensatory Habitat

N/A – Pre-Planning Planning application anticipated to be submitted by a third party in 2011.

Bristol Port Company held a consultation event on 18 January 2011.



CHAPTER 2: CONSULTATION PROCESS



CONTENTS

2. CONSULTATION PROCESS..........................................................................................3

2.1 Introduction......................................................................................................................3

2.2 Consultation with the Local Community and the General Public .....................................3

2.3 Consultation with Statutory Consultees .........................................................................75

2.4 Exceptions/Departures ..................................................................................................86

2.5 Next Steps.....................................................................................................................90

TABLES Table 2.1: EDF Energy New Nuclear Press Releases relating to the HPC Project ......................6

Table 2.2: Details of Consultation Newsletters...........................................................................22

Table 2.3: Details of Stakeholder and Public Meetings at Stage 1.............................................30

Table 2.4: Details of Additional Community Meetings ................................................................31

Table 2.5: Details of Stakeholder and Public Meetings at Stage 2 ............................................32

Table 2.6: Details of Exhibition Previews and presentations at Stage 2 Update ........................34

Table 2.7: Details of Meetings at Stage 2 Update ......................................................................34

Table 2.8: Junction 24 and Highways Improvements consultation events .................................35

Table 2.9: Exhibition Details for SSA consultation .....................................................................36

Table 2.10: Exhibition Details for ‘Initial Options and Proposals’ consultation............................37

Table 2.11: Exhibition Details for Stage 2 ‘Preferred Proposals’ consultation............................39

Table 2.12: Exhibition Details for Stage 2 Update consultation..................................................42

Table 2.13: Exhibition details for Junction 24 and Highways Improvements Consultation .........43

Table 2.14: Downloads of Translated Documents......................................................................54

Table 2.15: Visitors to Consultation Website..............................................................................54

Table 2.16: Dates of Community Forum Meetings and Agenda Items .......................................58

Table 2.17: Dates of Transport Forum Meetings and Agenda Items..........................................61

Table 2.18: Dates of MSNF Meetings and Agenda Items ..........................................................63

Table 2.19: Groups/Organisations represented at the Stakeholder Workshops.........................64

Table 2.20: Groups/Organisations Represented at Stage 2 Stakeholder Workshops................66

Table 2.21: Groups/Organisations Represented at Focus Groups.............................................72

Consultation Report – Chapter 2 Consultation Process | October 2011 1



2 Consultation Report – Chapter 2 Consultation Process | October 2011


FIGURES Figure 2.1: Advertisement for pre-SSA Nomination Consultation ................................................7

Figure 2.2: Advertisement for Stage 1 .........................................................................................8

Figure 2.3: Poster Advertising Additional Exhibition ....................................................................9

Figure 2.4: SoCC Advertisement for Stage 2 ............................................................................10

Figure 2.5: Poster Advertising the Exhibitions ...........................................................................11

Figure 2.6: Poster Advertising Additional Stage 2 Exhibitions ...................................................13

Figure 2.7: SoCC Advertisement for Stage 2 Update ................................................................14

Figure 2.8: Advertisement for Junction 24 and Highways Improvements consultation ..............15

Figure 2.9: SoCC Advertisement for Junction 24 and Highways Improvements consultation ...16

Figure 2.10: Section 48 Advertisement for Stage 2....................................................................18

Figure 2.11: Section 48 Advertisement for Stage 2 Update ......................................................19

Figure 2.12: Section 48 Advertisement Junction 24 and Highway Improvements consultation .20

Figure 2.13: Photograph from Cannington Exhibition (28 November 2009)...............................37

Figure 2.14: Photograph from Angel Place Exhibition (16 July 2010) ........................................39

Figure 2.15: Photograph from Cannington Exhibition (4 March 2011) .......................................41

Figure 2.16: Photograph from Sedgemoor Auction Centre Exhibition (11 July 2011) ................43

Figure 2.17: Community Forum Meeting (25 February 2010) ....................................................57


2. CONSULTATION PROCESS

2.1 Introduction

2.1.1 This chapter provides information on how EDF Energy consulted with the local community, general public, statutory consultees and other relevant stakeholders on its proposals at each stage of its consultation:

Stage 1 on ‘Initial Proposals and Options’ (16 November 2009 to 18 January 2010)

Stage 2 on Preferred Proposals (9 July 2010 to 4 October 2010)

Stage 2 Update: ‘Update on and Proposed Changes to Preferred Proposals’ (25 February 2011 to 28 March 2011)

Junction 24 and Highways Improvements: Proposed Changes to the Preferred Proposals including M5 Junction 24 and Highway Improvements in the Bridgwater Area (1 July 2011 to 12 August 2011).

2.1.2 This chapter also sets out and explains exceptions and departures to consultation guidance issued under section 50 of the Planning Act 2008 (the Act) and provides details of the next steps.

2.2 Consultation with the Local Community and the General Public

2.2.1 This section sets out the consultation approach and tools that were used throughout the pre-application consultation exercise to ensure the local community (under section 47 of the Act) and the general public (under section 48 of the Act) were kept informed of the progress of EDF Energy’s proposals and had the opportunity to comment on those proposals. It provides detail of how the consultations were advertised, the consultation methods used and attendance details.

2.2.2 EDF Energy also undertook extensive engagement and informal consultation with local communities and key stakeholders outside of the formal consultation periods. This took the form of drop-in sessions in respect of site investigation works, home visits and meetings with local residents and representatives of EDF Energy at its Bridgwater office as well as responding to letters, emails and telephone calls. Engagement with local authority officers was almost continuous. Information on this informal consultation, up to the point of submission of the DCO application, is provided in Chapter 4 of this report.

2.2.3 However, this chapter does include details of a number of meetings and other events that, although they took place outside the formal periods of consultation, EDF Energy considers to have been part of an integrated sequence of meetings. It is therefore difficult to separate these meetings out from those that took place during the formal periods.




2.2.4 EDF Energy did not limit the scope of its discussions with stakeholders simply to comply with formal consultation requirements. Instead, EDF Energy has encouraged discussions on a continuous basis to help inform the HPC Project as it has evolved. EDF Energy has also recognised the usefulness of engaging in constructive dialogue that may have begun during a formal consultation period but continued into an informal period to meet the public’s expectation of ongoing liaison.

a) Consultation Approach

2.2.5 At each stage, EDF Energy undertook local community consultation in line with a published Statement of Community Consultation (SoCC), as outlined in Chapter 1 of this consultation report.

2.2.6 The first stage of consultation, on ‘Initial Proposals and Options’, set out EDF Energy’s broad early plans for the new nuclear power station and associated development. The second stage, on ‘Preferred Proposals’, was supported by more detailed information. The Stage 2 Update and Junction 24 and Highways Improvements consultations supplemented the earlier consultations and invited comments on material changes to the preferred proposals. The local community was consulted at each stage of this consultation. The general public (under section 48 of the Act) was consulted from Stage 2 onwards.

2.2.7 The deadline for comments for Stage 1 was initially set for 11 January 2010 but this was subsequently extended to 18 January 2010 as a result of poor weather, which caused one of the public exhibitions to be postponed and re-arranged. A further period of grace beyond this deadline was given to allow for the receipt of postal responses via the freepost facility. All comments received after 1 April 2010 were therefore treated as late responses.

2.2.8 The deadline for responses to the Stage 2 consultation was 4 October 2010. A further period of grace beyond this deadline was given to allow for the receipt of postal responses via the freepost facility. All comments received after 9 November 2010 were therefore treated as late responses.

2.2.9 The deadline for responses to the Stage 2 Update consultation was 28 March 2011. A further period of grace beyond this deadline was given to allow for the receipt of postal responses via the freepost facility. All comments received after 5 April 2011 were therefore treated as late responses.

2.2.10 The deadline for responses to the Junction 24 and Highways Improvements consultation was 12 August 2011. A further period of grace beyond this deadline was given to allow for the receipt of postal responses via the freepost facility. All comments received after 16 August 2011 were therefore treated as late responses.

2.2.11 Late responses were taken into account by EDF Energy, although they did not raise any significant new issues from those already raised during the formal consultation periods. All late responses, with the exception of those for the J24 and Highways Improvements consultation period, were included in the batch of stakeholder comments that are replied to in Appendix H. Those late responses received beyond the submission deadline for the J24 and Highways Improvements consultation were




taken into consideration for the DCO application submission, but could not be included in this report.

2.2.12 Details of the zones of consultation and the way in which different people were targeted are set out in Chapter 1 and later in this chapter.

b) Consultation Tools

i. Media Relations

2.2.13 Coverage was sought and obtained through the local and regional media (newspapers, online, TV and radio) at each stage of consultation to raise awareness of EDF Energy’s proposals for Hinkley Point C (HPC) and associated development, the consultation events and the process for people to submit their comments.

2.2.14 EDF Energy kept the local and regional media informed regularly through media releases and one-to-one updates with journalists, beginning in October 2008 when a press release was issued on EDF Energy’s public consultation on the Strategic Site Assessment (SSA) nomination of its site at Hinkley Point. Use of the media enabled wider coverage, complementing other consultation methods used, such as the newsletter and letters, and ensuring that those stakeholders in the inner, middle and outer consultation zones (see Chapter 1) were informed of each stage of consultation and details of public exhibitions.

2.2.15 At each stage the media was informed that a period of formal consultation was due to begin and was provided with an overview of the proposals.

2.2.16 In addition, media releases were used to provide an update on other issues associated with EDF Energy’s proposals, including carrying out of investigative works, submission of the temporary jetty and Site Preparation Works applications and supplier days. See Table 2.1 for a list of relevant EDF Energy press releases produced throughout the overall consultation period.

2.2.17 As well as issuing a regular flow of press release stories, EDF Energy also placed a number of feature articles in national and local press. These included a full-page article in the Western Daily Press and Western Morning News, articles in an EDF Energy-sponsored Green Guide in South West newspapers and online editions, and articles in an energy supplement published in the New Statesman magazine.

2.2.18 Media coverage of the consultation and related issues was an important outcome of utilising press releases over this period – a strategy confirmed by the fact that in an October 2010 ICM poll, 66% of people stated they were aware of the EDF Energy consultation through newspaper coverage, whilst 46% also attributed their awareness to television (see Appendix E).

2.2.19 The EDF Energy press office also received hundreds of national and local media enquiries, all of which were responded to, providing further information about the consultation process.




Table 2.1: EDF Energy New Nuclear Press Releases relating to the HPC Project (see Appendix C)

Consultation Stage

Media Work/Press Releases Date of Release

Pre-Stage 1 EDF Energy begins public consultation on its Hinkley Point nuclear plans

14/10/08

Pre-Stage 1 Public have their say at EDF Energy exhibitions on new nuclear power at Hinkley Point

19/11/08

Pre-Stage 1 Public consultation statement released 19/01/09

Pre-Stage 1 EDF Energy to nominate site at Hinkley Point 19/03/09

Pre-Stage 1 EDF Energy to carry out investigative works at Hinkley Point 01/09/09

Stage 1 EDF Energy to consult local people on plans for new nuclear build at Hinkley Point

15/11/09

Stage 1 EDF Energy extends response deadline to first stage of Hinkley public consultations

11/01/10

Stage 1 Consultation on ‘Initial Proposals’ closes 21/01/10

Stage 2 EDF Energy launches Stage 2 of its consultation on new nuclear build at Hinkley Point

25/06/10

Stage 2 EDF Energy unveils ‘Preferred Proposals’ for HPC and sets out how local feedback played key role in shaping plans

08/07/10

Stage 2 Independent research demonstrates support for HPC 15/10/10

Pre-Stage 2 Update

EDF Energy submits local planning application for preparatory works at HPC site

30/11/10

Pre-Stage 2 Update

EDF Energy submits an application for a temporary jetty at HPC 15/12/10

Stage 2 Update

5,000 Somerset people predicted to find work on HPC construction, as EDF Energy prepares to consult on changes and further details to its ‘Preferred Proposals’

15/02/11

Stage 2 Update

EDF Energy to provide £100 million of lasting community investment for HPC, including £20 million Community Fund

24/02/11

Stage 2 Update

EDF Energy encourages local people to take part in HPC consultation

23/03/11

Junction 24 and Highways Improvements consultation

EDF Energy launches local consultation on updated HPC proposals for alternative park and ride site near M5 Junction 24 and additional highway improvements in the Bridgwater Area

01/07/11

ii. Advertisements (section 47)

2.2.20 EDF Energy used local press advertisements to publicise the local community consultation processes and promote events. In addition, posters were used at targeted locations when deemed necessary. The times, dates and venues of the public exhibitions were advertised to reach a wide local audience and give those interested in the proposals advance notice of the consultation events.

2.2.21 For the formal stages of consultation, a number of these press advertisements took the form of the formal Statement of Community Consultation (SoCC). Section 47 of the Act requires each SoCC to be published in a locally circulating newspaper and




EDF Energy ensured that the main consultation events were publicised through the SoCC advertisements (see Chapter 1).

Pre-Stage 1

2.2.22 Advertisements showing the times and locations of EDF Energy’s public exhibitions were displayed in the following weekly newspapers from 28 to 31 October 2008: Bridgwater Mercury (28 October), Bridgwater Star (28 October), Burnham and Highbridge Weekly News (28 October), Somerset County Gazette (30 October), Bridgwater Times (30 October) and West Somerset Free Press (31 October) (see Figure 2.1). At this stage and Stage 1, EDF Energy had not defined the areas for its associated developments and, as such, advertised in newspapers covering West Somerset, Sedgemoor and Somerset.

Figure 2.1: Advertisement for pre-SSA Nomination Consultation (not to scale - see Appendix C for larger scale version)

Stage 1

2.2.23 SoCC advertisements with details of the public consultation process were placed in the week commencing 16 November 2009 in the following weekly newspapers: Bridgwater Mercury (17 November), Burnham and Highbridge News (17 November), Somerset County Gazette (19 November), Bridgwater Times (19 November), and West Somerset Free Press (20 November). The Bridgwater Star, which was advertised in pre-Stage 1, was no longer in publication.




2.2.24 Further advertisements with details of the Stage 1 ‘Initial Options and Proposals’ consultation events were placed in the week commencing 23 November 2009 in the following weekly newspapers: Bridgwater Mercury (24 November), Somerset County Gazette (26 November), Bridgwater Times (26 November), West Somerset Free Press (27 November) and Burnham and Highbridge News (27 November) (see Figure 2.2).

Figure 2.2: Advertisement for Stage 1 (not to scale - see Appendix C for larger scale version)

2.2.25 In order to increase awareness, following an addition to the previously advertised events, posters advertising an extra exhibition at Cannington were sent to Cannington Parish Council for distribution in the week commencing 21 December 2009 (see Figure 2.3). It was agreed that the local parish council was best placed to know the optimum locations for these posters.




Figure 2.3: Poster Advertising Additional Exhibition (not to scale - see Appendix C for larger scale version)

Stage 2

2.2.26 At Stage 2, EDF Energy had refined its plans and identified potential sites for associated development. As such, the public exhibitions were advertised, through the SoCC advertisements, in newspapers circulated in areas likely to be affected by its proposals.

2.2.27 The SoCC advertisements, which included details of the initial public exhibitions planned for the Stage 2 ‘Preferred Proposals’ consultation, were placed in the following newspapers in the week commencing 29 June 2010: Bridgwater Mercury (30 June), Somerset County Gazette (2 July) and West Somerset Free Press (3 July) (see Figure 2.4).




Figure 2.4: SoCC Advertisement for Stage 2 (not to scale - see Appendix A for larger scale version)




2.2.28 Following informal feedback on the usefulness of using posters to advertise events, an increased number compared to Stage 1 were used to advertise most of the exhibitions at Stage 2 (see Figure 2.5). These were sent to the following organisations for placement the week beginning 28 June 2010:

Parish councils in the inner and middle zones of consultation.

West Somerset Council and Sedgemoor District Council.

Tourist information offices in Bridgwater, Burnham-on-Sea, Axbridge and Minehead.

All libraries in Somerset.

Figure 2.5: Poster Advertising the Exhibitions (not to scale - see Appendix C for larger scale version)




2.2.29 Additional events were put into the consultation schedule after the initial advertisements and posters were displayed. Further advertisements were therefore produced with details of the additional Stage 2 public exhibitions in supermarket car parks in Bridgwater and at tourist locations in Minehead and Burnham-on-Sea. These were placed in the following locally circulated newspapers from 13 to 17 August 2010: Somerset Gazette (13 August), West Somerset Free Press (14 August) and Burnham and Highbridge News (17 August).

2.2.30 In addition, posters advertising these extra exhibitions (see Figure 2.6) were sent to the following organisations for display the week beginning 2 August 2010:

Parish councils in the inner and middle zones of consultation.

West Somerset Council and Sedgemoor District Council.



2.2.31 The following tourist organisations in Minehead and Burnham-on-Sea were also sent copies of the posters after confirmation was received that they would be happy to display the information on their notice boards:

Butlins;

Pontins;

Haven in Burnham;

Hoseasons;

Home Farm Holiday Park;

Warren Farm Holiday Centre;

Blue Anchor Railways Museum/West Somerset Railway;

West Somerset Sports and Leisure Centre;

West Somerset Garden Centre;

Doniford Bay; and

Lakeside Holiday Village.




Figure 2.6: Poster Advertising Additional Stage 2 Exhibitions (not to scale - see Appendix C for larger scale version)

Stage 2 Update

2.2.32 As at Stage 2, SoCC advertisements that included details of the public exhibitions planned for the Stage 2 Update consultation, were placed in the following newspapers week commencing 14 February 2011: Bridgwater Mercury (15 February), Somerset County Gazette (17 February) and West Somerset Free Press (18 February). See Figure 2.7.




Figure 2.7: SoCC Advertisement for Stage 2 Update (not to scale - see Appendix A for a larger scale version)





2.2.33 Due to the timing of the Junction 24 and Highways Improvements consultation, which included an informal period of community consultation (1 to 14 July 2011) before the publication of the SoCC, the public consultation events were advertised in the Bridgwater Mercury (5 July 2011) and Somerset Gazette (7 July 2011) (see Figure 2.8).

Figure 2.8: Advertisement for Junction 24 and Highways Improvements consultation (not to scale - see Appendix C for larger scale version)




2.2.34 SoCC advertisements that included details of the public exhibitions planned for the formal stage of consultation were placed in the following newspapers: Somerset Gazette (14 July 2011) and Bridgwater Mercury (19 July 2011) (see Figure 2.9).

Figure 2.9: SoCC Advertisement for Junction 24 and Highways Improvements consultation (not to scale - see Appendix A for larger scale version)

iii. Advertisements (Section 48)

2.2.35 Due to the multi-stage approach of EDF Energy’s consultation on its proposals for HPC and associated developments over a prolonged period, it was not felt to be appropriate to consult with the wider public until the proposals were sufficiently




advanced for the most effective dialogue. Section 48 consultation therefore started at the Stage 2 ‘Preferred Proposals’ stage once proposals had been sufficiently developed.

Stage 2

2.2.36 In accordance with the requirements of Regulation 4 of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 (APR Regs), Stage 2 section 48 advertisements were placed in the London Gazette and Daily Telegraph on 9 July 2010 and in the Somerset Gazette on 8 July 2010 and 15 July 2010 (see Figure 2.10). These advertisements outlined the Stage 2 consultation process and explained how the general public could obtain detailed information and respond to the consultation.




Figure 2.10: Section 48 Advertisement for Stage 2 (not to scale – see Appendix A for larger scale version)

Stage 2 Update

2.2.37 Stage 2 Update advertisements were placed in the Somerset Gazette in the weeks beginning 21 February 2011 and 28 February 2011 and in the London Gazette and Daily Telegraph on 25 February 2011. In addition to those publications previously used, from Stage 2 Update onwards EDF Energy also placed advertisements in Fishing News and Lloyd’s List. At Stage 2 Update, this was on 25 February 2011 (see Figure 2.11).




2.2.38 The advertisements outlined the Stage 2 Update consultation, explained how the general public could obtain the consultation document and how they could respond.

Figure 2.11: Section 48 Advertisement for Stage 2 Update (not to scale - see Appendix A for a larger scale version)





2.2.39 Advertisements for the Junction 24 and Highways Improvements consultation were placed in the Somerset Gazette on two consecutive weeks (30 June 2011 and 7 July 2011) and in the London Gazette, Daily Telegraph, Fishing News and Lloyds List on 1 July 2011 (see Figure 2.12). The advertisements outlined the consultation, explained how the general public could obtain the consultation document and how they could respond.

Figure 2.12: Section 48 Advertisement Junction 24 and Highway Improvements consultation (not to scale - see Appendix A for a larger scale version)




iv. Community Newsletters

2.2.40 Newsletters have formed a key role in communicating with the local community as the pre-application consultation has progressed. They have played a central role in the consultation strategies of each stage; advertising consultation activities, encouraging feedback and outlining the prevailing proposals (see Appendix C). Outside of the formal consultation periods, the newsletters have continued to inform the local community of the progress of the HPC Project, activities on site and general involvement by EDF Energy with the community.

2.2.41 EDF Energy has produced a regular newsletter on its proposals as part of its commitment to keep local people and stakeholders informed of progress (see Table 2.2). All newsletters have been four pages, A4 size and in colour, with the exception of the March 2011 edition, which was two pages, A4 size and in colour.

2.2.42 A distribution list was compiled and reviewed at the end of each stage of consultation and was updated accordingly. The database of recipients was also updated to include those who had participated in the consultation to ensure they were kept informed of developments within the HPC Project.

2.2.43 The newsletters were also made available to download from the HPC Project website and hard copies were available at the EDF Energy Bridgwater office from April 2009. Copies of the newsletters produced prior to the submission of the application to the IPC are available to view in Appendix C.

2.2.44 Between October 2008 and DCO application submission, 15 community newsletters were distributed. This engagement will continue post-submission.






Table 2.2: Detai onsultls of C ation Newsletters

Reason for Newsletter

Date Content Distribution/Availability

Pre-Stage 1

To announce the start of the pre-SSA nomination consultation

October 2008

About EDF Energy

The purpose of the consultation

Information on the site

Proposed project timeline

Key consultation issues: community, SSA, national criteria, local criteria and Environmental Impact Assessment

Footpaths on site

Details of the public consultation and how to have your say

Update on EDF Energy and British Energy’s consultation events

Details of how to contact the HPC Project team and comment on EDF Energy’s plans

By post to all households within approximately a 5-mile radius of Hinkley Point, covering the relevant parishes in both West Somerset and Sedgemoor

With free newspapers or via solus distribution in the key centres of population between a 5 and 10-mile radius of Hinkley Point. This included: Bridgwater; Burnham-on-Sea; Cannington; Watchet and Williton

to By post to stakeholders upa 15-mile radius from Hinkley Point

To view at some of the main public libraries and council offices

To pick up at the public exhibitions

To update on the pre-SSA nomination consultation process to highlight the results and provide further information

December 2008

Details on the results of the consultation

Information about the office EDF Energy planned to open in Bridgwater in 2009

Analysis of the questionnaire results

Key issues and EDF Energy’s initial response

Update on site investigation

Project timeline

Update on the proposed acquisition by EDF Energy of British Energy

Details of how to contact the HPC Project team and comment on EDF Energy’s plans

As above






To outline EDF Energy’s site nomination for new nuclear build at Hinkley Point C

April 2009 Details of site nomination

te – transportation Site updaand accommodation

Update on Environmental Impact Assessment

Update on key issues underway – ecological, landscape, archaeology, geological and air quality

Details on Bridgwater College as South West hub for national nuclear skills academy

Update on EDF Energy in the South West

Details of the new EDF Energy office in Bridgwater

Contact details for commenting on the proposals

By post to all households within approximately a 5-mile radius of HPC covering the relevant parishes in both West Somerset and Sedgemoor

With free newspapers or via solus distribution in the key centres of population between a 5 and 10-mile radius of Hinkley Point. This included: Bridgwater; Burnham-on-Sea; Cannington; Watchet; and Williton

By post to stakeholders up to a 15-mile radius from Hinkley Point

By post to those who responded to the previous consultation

To update on the site nomination and next steps

July 2009 Update on the land nominated at HPC

Update on the Government’s draft Nuclear National Policy Statement (NPS)

Outline timeline for HPC consultation

Summer/Autumn site activity – offshore and onshore

Update on EDF Energy activities in the community – carbon reduction fair at West Somerset Community College and meetings for the local community with EDF Energy’s project manager

Update on Centrica’s plans to invest in the next generation of nuclear power stations

Frequently asked questions


As above






Stage 1

To announce the start of consultation on EDF Energy’s proposals for HPC and outline the approach

October 2009

Announcement of multi-stage consultation, starting with Initial Proposals and Options

Outlining key elements of Initial Proposals and Options consultation

Outlining other consultation activity relating to Hinkley Point – by National Grid and South West Planning Aid

Overview of preparatory works

Update in the community: Cannington Village meeting; Otterhampton Parish Council meeting and Weston-super-Mare Town Council meeting

Update on investigative site works

Details of nuclear new build Community Forum



Approximately 3,500 households within the inner zone (approximately a 5-mile radius of Hinkley Point) and Cannington by post

Approximately 1,020 stakeholders (from the inner, middle and outer consultation zones) by post

Over 32,500 households primarily in the middle zone (including Bridgwater, Burnham-on-Sea, Cannington, Watchet and Williton) by solus distribution

Libraries in Somerset

West Somerset, Sedgemoor and Somerset Council offices

Tourist information offices in Bridgwater, Burnham-on-Sea, Axbridge and Minehead

Available online on the consultation website

Available as hard cop ies from the Bridgwater office

To provide more information on EDF Energy’s ‘Initial Proposals and Options’ and give details of the Stage 1 consultation events

November 2009

Details of the Initial Proposals and Options consultation

Information about the new power station and likely layout and buildings/ infrastructure required

Illustration of the areas proposed for associated developments

Potential community benefits

Update on preliminary works

Details of public exhibitions – times and venues

Contact details and how to ‘have your say’

As above

Pre-Stage 2

To thank people for their responses to the ‘Initial Proposals and Options’ consultation and update them on the next steps for the HPC Project

March 2010

Overview of number of consultation responses received during Stage 1 and EDF Energy’s commitment to publish an interim consultation report on the results of the Stage 1 consultation during the ‘Preferred Proposals’ consultation

Details of the next stage of consultation

Update on site investigation

Approximately 3,500 households within the inner zone (approximately a 5-mile radius of Hinkley Point) and Cannington by post


Posted to those who responded to Stage 1 consultation






works

Showcasing jobs in the low-carbon economy at Taunton and West Somerset Careers Fair


Contact details for the proposals



Available as hard copies from the Bridgwater office

Stage 2

To announce the overall timing of the ‘Preferred Proposals’ consultation and give an overview of EDF Energy’s most recent activity in the community

June 2010 Announcement on the timing of the Stage 2 consultation – 9 July 2010 to 4 October 2010

Overview of the consultation strategy and timetable

Next steps in the planning process

Update on what was happening on site

Update on latest activity in the community – Nether Stowey May Fair, West Somerset Community College Student Workshop, Homes in Sedgemoor ‘Worklessness’ Event, Supplier Day; Update on off-site investigations

New nuclear power stations – the coalition Government’s position

Bridgwater staff update – David Eccles to head Bridgwater office

Timing/venues for public exhibitions on ‘Preferred Proposals’

Contact details and how to arrange a home visit or pre-order a translated document

Approximately 11,400 households within the inner zone (approximately a 5-mile radius of Hinkley Point and a 0.5 mile radius of all associated development sites) and Cannington by post*









*The inner consultation zone was amended at Stage 2 to include households within 0.5 miles of all the associated development sites.

To provide details of EDF Energy’s ‘Preferred Proposals’ for HPC and a summary of the key changes

July 2010 Outline of key changes and ‘Preferred Proposals’

at Stage 1 Key issues raised on ‘Initial Proposals and Options’ and EDF Energy’s response

Consultation timeline and exhibition details

Details of how to arrange a

Approximately 11,400 households within the inner zone (approximately a 5-mile radius of Hinkley Point and a 0.5 mile radius of all associated development sites) and Cannington by post. Approximately 1,020 stakeholders (from the inner,






home visit or the translation/interpretation service

Contact details and how to participate

middle and outer consultation zones) by post





Pre-Stage 2 Update

To provide an update on the HPC Project following the Stage 2 consultation

November 2010

Update on Stage 2 consultation responses and next steps

Update on independent research on local views of HPC

Project update on preliminary and investigation works

End of Environment Agency’s reactor consultation and next steps

Overview of job opportunities for local people – supplier chain events and recruitment consultants in action

Details of Government’s consultation on draft Nuclear NPS

Update on EDF Energy in the community – the Somerset Green Community Challenge; Bridgwater Town Hall relaunch and scheme to provide spare wood for fuel in Stogursey

Contact details

Approximately 11,900 households within the inner zone (approximately a 5-mile radius of Hinkley Point and a 0.5-mile radius of all associated development sites) and Cannington by post*


Posted to those who responded to Stage 1 and 2 consultations




*The newsletter mailing was further amended to ensure inclusion of new housing development in the North Petherton area.

Stage 2 Update

To explain that EDF Energy would be consulting on material changes made to its ‘Preferred Proposals’ and

February 2011

Overview of update on and proposed changes to ‘Preferred Proposals’: what will be consulted on and times/venues for exhibitions

Update on jobs and skills –employment brokerage scheme, apprenticeships and training and Construction

Approximately 12,000 households within the inner zone (approximately a 5-mile radius of Hinkley Point and a 0.5 mile radius of all associated development sites) and Cannington by post*

Approximately 1,020 stakeholders (from the inner,






give details of the public exhibitions

Skills Centre

Details of new Energy Skills Centre opened by Secretary of State for Energy and Climate Change

Makeover for Nether Stowey Primary School’s nature reserve

Launch of Stogursey Parish lengthsman scheme

Update on reactor design

Update on applications for site preparation works and temporary jetty

Contact details

middle and outer consultation zones) by post

Posted to those who responded to Stages 1 and 2 consultations







*The newsletter was sent to those who received it previously, and the postal distribution was extended to include the households within 0.5 miles of the new associated development site at Williton proposed for a park and ride facility

A consultation special providing details on the proposed changes to the ‘Preferred Proposals’ for Hinkley Point C

February/March 2011

An overview of the proposed changes being consulted on

The need for nuclear power

Vision for HPC

Key changes since the ‘Preferred Proposals’ in the following key categories – jobs, community, accommodation, construction working hours, transport, HPC main site

Reminder of the exhibition dates/venues, home visits and translation/ interpretation service

Consultation questions

Contact details and how to ‘have your say’

Approximately 12,000 households within the inner zone (approximately a 5-mile radius of Hinkley Point and a 0.5-mile radius of all associated development sites) and Cannington by post Approximately 1,020 stakeholders (from the inner, middle and outer consultation zones) by post

Posted to those who responded to Stages 1 and 2 consultations








Pre-Junction 24 and Highways Improvements Consultation

To thank those who participated in the consultation and provide an update on recent activity

April/May 2011

Thanks for comments and details on ongoing engagement

Results of investment poll – legacy investment welcome

Japan update – safety is paramount

Thousands of trees planted as screening

Environment Agency – related consultation

Somerset schools step up to sustainability challenge

Science TV schools’ film project

Contact details

Approximately 12,000 households within the inner zone (approximately a 5-mile radius of Hinkley Point and a 0.5 mile radius of all associated development sites) and Cannington by post Approximately 1,020 stakeholders (from the inner, middle and outer consultation zones) by post

Posted to those who responded to Stages 1, 2 and 2 Update consultations





To provide an update on the Site Preparation Works application and EDF Energy in the community

June 2011 Update on planning application submitted to West Somerset Council for site preparation works

Nuclear update following interim report from Dr Weightman

Primary school children help relocate plants from the site

Update on the Stogursey lengthsman scheme

EDF Energy at the Bath and West Show

Nuclear focus during Easter 2011 for 50 secondary school pupils from Somerset

Somerset Chamber of Commerce urges support for site preparation works

to play mNuclear ajor role in meeting UK carbon reduction targets

Contact details

Approximately 12,000 households within the inner zone (approximately a 5-mile radius of Hinkley Point and a 0.5-mile radius of all associated development sites) and Cannington by post Approximately 1,020 stakeholders (from the inner, middle and outer consultation zones) by post

Posted to those who responded to Stages 1, 2, and 2 Update consultation








Junction 24 and Highways Improvements Consultation

To provide details on EDF Energy’s consultation on Junction 24 and Highway Improvements

July 2011 Proposed changes near M5 Junction 24 and Highway Improvements in the Bridgwater area

Temporary jetty update

Pied wagtail chooses unusual nesting spot

Power station’s unexpected visitor seals escape bid (an Atlantic grey seal)

Cowslips given new home

Winner of Somerset Green Schools Challenge

Keeping an eye on EDF Energy plans (update on the Community, Transport and Main Site Neighbourhood Forums)

Weekly drop-ins for Stogursey residents

Blueprint for new nuclear power

EDF Energy teams up with Jobcentre Plus

Contact details

Approximately 12,000 households within the inner zone (approximately a 5-mile radius of Hinkley Point and a 0.5 mile radius of all associated development sites) and Cannington by post


Posted to those who responded to Stages 1, 2 and 2 Update consultations





Available online on theconsultation website


v. Stakeholder and Public Meetings

Throughout the consultation on its proposals for HPC, EDF Energy met with stakeholders and local people as part of the formal consultation and at key stages of the HPC Proje

2.2.45

ct, as part of its commitment to liaise and consult with local communities.

2.2.46

iled responses are provided by topic in the Schedule of Responses in Appendix H.

2.2.47 detailed

interest in the development of a new nuclear power station at Hinkley Point.

Issues raised at each meeting have been taken into consideration as part of the consultation on proposals for HPC and associated developments. They have largely been captured in formal submissions from key stakeholders, the local community and members of the wider public. Chapter 3 of this report contains EDF Energy’s responses to issues raised, organised by theme. More deta

Pre-Stage 1

During the pre-SSA nomination consultation, EDF Energy arranged a programme of meetings with key statutory and non-statutory stakeholders likely to have a


2.2.48 The programme started with an invitation to key stakeholders to visit the EDF Energy HPC site in October 2008. Those key stakeholders unable to attend the site visit were subsequently offered the opportunity of meeting separately.

2.2.49 Meetings held from October to December 2008 included briefings to members of Stogursey Parish Council, Williton Parish Council, Cannington Parish Council, Bridgwater College and the West Hinkley Action Group.

2.2.50 As part of the agreement to co-ordinate consultation events with British Energy (prior to its acquisition), EDF Energy was represented at each of the five public meetings organised by British Energy to publicise its plans for Hinkley Point. These meetings were held at Nether Stowey; Cannington; Bridgwater; Combwich and Stogursey.

2.2.51 Additional meetings were held by EDF Energy during 2009, before the Stage 1 consultation, including with Taunton Deane Borough Council, Wembdon Parish Council, Somerset Economic Leaders’ Group and South West Chambers of Commerce. This was the start of a meeting programme that EDF Energy continued throughout its pre-application consultation.

Stage 1

2.2.52 During the formal Stage 1 consultation period, EDF Energy gave a series of presentations on its ‘Initial Options and Proposals’ followed by a question and answer session to local stakeholder groups (Table 2.3). There were 18 meetings held, which were attended by approximately 600 people.

Table 2.3: Details of Stakeholder and Public Meetings at Stage 1

Date Stakeholders Approximate Attendance

24 November 2009 Kilve Parish Council 6

24 November 2009 Watchet, Williton and Quantocks Area Panel 20

27 November 2009 Councillors from West Somerset Council, Sedgemoor District Council and Somerset County Council

10

1 December 2009 Cannington Parish Council 10

3 December 2009 Otterhampton Parish Council 30

5 December 2009 Williton Village Hall Steering Committee 3

7 December 2009 Burnham-on-Sea and Highbridge Town Council 37

8 December 2009 Stogursey Parish Council 40

8 December 2009 Quantocks Parish Cluster 15

14 December 2009 Nether Stowey Parish Council 30

15 December 2009 Minehead and District Chamber of Trade and Commerce 15

16 December 2009 Stogursey Parish Council 30

22 December 2009 Sampford Brett Parish Council 40

4 January 2010 Williton Parish Council 100

4 January 2010 Bridgwater Town Council 10

8 January 2010 Shurton and Burton Residents site visit 40







14 January 2010 Nether Stowey Parish Council 70

27 January 2010 Stockland Bristol Parish Council 75

2.2.53 EDF Energy organised the site visit of 8 January 2010 listed above at the residents’ request. This provided the opportunity for residents to ask members of the HPC Project team detailed questions about the proposals. There was a high level of interest in the Site Preparation Works, in particular the location of the construction fence and landscaping.

2.2.54 The Stockland Bristol Parish Council meeting on 27 January 2010 was originally due to take place during the Stage 1 consultation period but had to be rearranged due to adverse weather conditions.

2.2.55 EDF Energy also attended events organised by Planning Aid South West in Burnham-on-Sea, Bridgwater and Stogursey at the beginning of November 2009. The purpose of these events was to explain the consultation process and how local people could find out more information and comment on the proposals for HPC.

Pre-Stage 2

2.2.56 Following the close of the Stage 1 consultation on 18 January 2010, EDF Energy continued to consult with or engage the local community about its proposals for HPC and associated developments.

2.2.57 Meetings with the community (Table 2.4) were held at the Hinkley Point B Training and Induction Centre to discuss, in particular, the proposed HPC Development Site and site preparation works.

Table 2.4: Details of Additional Community Meetings


19 April 2010 Shurton, Burton, Knighton and Wick Residents’ Meeting 40

7 June 2010 Shurton, Burton, Knighton and Wick Residents’ Meeting 40

2.2.58 At the request of local residents, EDF Energy organised a meeting on 19 April 2010 (where approximately 40% of those invited attended) (Table 2.4) to discuss in more detail the proposals for the preliminary works at the HPC Development Site. EDF Energy welcomed this opportunity for local residents to highlight their concerns so they could be taken into account, where possible, in line with EDF Energy’s approach to consultation and design improvement.

2.2.59 At a follow-up meeting on 7 June 2010, EDF Energy presented revised plans and proposals for the HPC Development Site and Site Preparation Works and obtained further feedback from local residents.

2.2.60 During the period before Stage 2 and in order to help develop its proposals, EDF Energy carried out a programme of investigative works/studies on the HPC


Development Site and at the proposed associated development sites. EDF Energy notified residents living in the areas of the investigative works by letter and held drop-in sessions prior to some of the main investigative works to enable local people to meet with members of the HPC Project team and discuss the activities taking place.

Stage 2

2.2.61 EDF Energy held five general briefing meetings prior to the start of its formal consultation on ‘Preferred Proposals’ (6 to 8 July 2010) and 30 meetings during the consultation with key local stakeholder groups, including parish councils, the majority of which were open to members of the public. Approximately 830 people attended these consultation meetings.

Table 2.5: Details of Stakeholder and Public Meetings at Stage 2 (including five meetings prior to the start of Stage 2)


6 July 2010 Sydenham Tenants’ and Residents’ Association (pre-Stage 2 briefing)

7

7 July 2010 Cannington Parish Council (pre-Stage 2 briefing) 3

7 July 2010 Sedgemoor District Council (pre-Stage 2 briefing) 22

8 July 2010 West Somerset Council (pre-Stage 2 briefing) 22

8 July 2010 Community Forum (pre-Stage 2 briefing) 40

12 July 2010 Sedgemoor District Council’s Community Scrutiny Committee

15

15 July 2010 Bridgwater Challenge Partnership Board 10

16 July 2010 Quantocks Parish Cluster 32

20 July 2010 Cannington Parish Council 175

20 July 2010 North Petherton Parish Council 5

27 July 2010 Kilve Parish Council 8

2 August 2010 Williton Parish Council 5

2 August 2010 Burnham on Sea and Highbridge Town Council 20

4 August 2010 West Hinkley Action Group 4

5 August 2010 Otterhampton Parish Council 150

11 August 2010 Meeting with representative from Ashley Road Residents’ Association

1

16 August 2010 Bridgwater Rotary Club 17

18 August 2010 Otterhampton Drop-in 15

19 August 2010 Bridgwater Town Council 10

24 August 2010 Watchet, Williton and Quantocks Area Panel 30

25 August 2010 Stogursey Parish Council 9

2 September 2010 Stogursey Village Meeting 55

4 September 2010 Sedgemoor Tenants Voice Conference 30

6 September 2010 Stogursey Parish Council 10







6 September 2010 Wembdon Parish Council 13

8 September 2010 Women’s Institute 30

13 September 2010 West Quantoxhead Parish Council 11

14 September 2010 Chilton Trinity Parish Council 10

20 September 2010 Nether Stowey Parish Council (Major Projects Committee) 8

24 September 2010 Enmore Parish Council 6

27 September 2010 Over Stowey Parish Council 5

27 September 2010 Holford Parish Council 14

28 September 2010 Sedgemoor Area Planning Group 4

28 September 2010 Combwich Sailing Club 3

30 September 2010 Community Forum 30

2.2.62 A meeting was also arranged with Barry Town Council on 29 September 2010; however, the Council had a clash with another meeting and declined EDF Energy’s offer to rearrange the meeting.

Pre-Stage 2 Update

2.2.63 EDF Energy continued to hold meetings with local stakeholder groups prior to the Stage 2 Update consultation. These included meetings with Watchet Chamber of Trade, Stogursey Parish Council, Otterhampton Parish Council and Vale of Glamorgan Council. A representative from EDF Energy also gave a presentation and answered questions at the Severn Estuary Forum.

2.2.64 EDF Energy also held informal consultation meetings with residents of Shurton, Burton, Knighton and Wick to canvas opinions on potential voluntary property price support and noise mitigation schemes (see Chapter 4 for more information).

Stage 2 Update

2.2.65 For the Stage 2 ‘Update on and Proposed Changes to Preferred Proposals’ consultation, EDF Energy invited members of Williton Parish Council, North Petherton Town Council, Bridgwater Town Council, Otterhampton Parish Council, Stogursey Parish Council, Cannington Parish Council and Puriton Parish Council to attend exhibition previews.

2.2.66 The invitations were sent to individual parish/town councillors on EDF Energy’s database and via the parish and town clerks but although the events were organised, the opportunity was not always taken up by the invitees.

2.2.67 Details of the exhibition previews are provided in Table 2.6 below and show that approximately 56 parish and town councillors attended the previews.


Table 2.6: Details of Exhibition Previews and presentations at Stage 2 Update


25 February 2011 West Somerset, Sedgemoor District and Somerset County Council Councillors and Officers Presentation

20

26 February 2011 Williton Councillor Exhibition Preview 6

28 February 2011 Bridgwater Councillor South Exhibition Preview 0

1 March 2011 Otterhampton Councillor Exhibition Preview 8

2 March 2011 Stogursey Councillor Exhibition Preview 10

3 March 2011 Bridgwater North Councillors Exhibition Preview 0

4 March 2011 Cannington Exhibition Preview 12

2.2.68 EDF Energy also gave a presentation on the proposals to West Somerset Council, Sedgemoor District Council and Somerset County Council on 25 February 2011 (see Table 2.6).

2.2.69 In addition to the exhibition previews, EDF Energy also responded to requests for additional meetings from key stakeholder groups to discuss the proposals. Details of these meetings are provided in Table 2.7 below.

Table 2.7: Details of Meetings at Stage 2 Update


3 March 2011 Bridgwater Civic Society 15

14 March 2011 Nether Stowey Parish Council 10

21 March 2011 Exmoor Tourist Association 30

2.2.70 A meeting of EDF Energy’s Community Forum was held on 3 March 2011, attended by 27 members, where the Stage 2 Update consultation was considered. EDF Energy also attended a meeting of Stogursey Parish Council on 24 February 2011 when the Stage 2 Update consultation was discussed.


2.2.71 EDF Energy continued to hold meetings with key local stakeholder groups following the close of the Stage 2 Update consultation, prior to the consultation on ‘Proposed Changes to the Preferred Proposals including M5 Junction 24 and Highway Improvements in the Bridgwater Area’. These included meetings with Wembdon, Cannington, Otterhampton and North Petherton Parish Councils, Williton Town Council, Bridgwater Town Council and Bridgwater Chamber of Commerce.


2.2.72 During the consultation on ‘Proposed changes to the Preferred Proposals including M5 Junction 24 and Highway Improvements in the Bridgwater area’, EDF Energy responded to requests for additional meetings from key stakeholder groups to discuss the proposals. They met with approximately 116 at eight meetings during the consultation period. These are detailed in Table 2.8 below.




Table 2.8: Junction 24 and Highways Improvements consultation events


6 July 2011 Meeting with Wembdon Parish Council 1

11 July 2011 SDC Labour Group 13

12 July 2011 Bridgwater Town Council 12

18 July 2011 Wembdon PC Meeting 29

19 July 2011 Minehead Town Council 25

27 July 2011 Bridgwater Challenge 10

3 August 2011 SDC Conservatives 2

3 August 2011 Puriton Parish Council 24

vi. Public Exhibitions

2.2.73 At each stage of consultation, EDF Energy held public exhibitions in the areas most likely to be affected by the proposals being consulted upon.

2.2.74 All of the chosen exhibition venues had suitable access for those with disabilities and sufficient space to cope with anticipated numbers. The exhibitions were held over a sufficiently long period of time, during the evenings or at weekends to make it possible for those with children, or who were working, to attend.

2.2.75 At each exhibition there were exhibition boards with information about the proposals, supporting documentary material and representatives from EDF Energy and its project team in attendance to answer questions and discuss the issues and opportunities with attendees. EDF Energy ensured that subject matter experts relevant to the issues at each location attended. Exhibitions were often attended at director level to emphasise the degree of importance placed on this consultation channel, and as part of a genuine desire for directors to hear comments first-hand.

2.2.76 At each stage of consultation the exhibition boards and supporting material were available to download from the HPC Project website. A static exhibition was also available to view at EDF Energy’s Bridgwater office during the formal periods for Stage 1, Stage 2, Stage 2 Update and Junction 24 and Highways Improvements Consultations.

2.2.77 A questionnaire was provided in hard copy at the exhibitions and was available to fill in electronically at the HPC Project website www.edfenergyconsultation.info. The questionnaires can be viewed in Appendix C of this report.

Pre-Stage 1

2.2.78 As part of its consultation prior to the SSA nomination process, EDF Energy held four public exhibitions (see Table 2.9 below) that were attended by approximately 275 people. Representatives of British Energy were present at all of the events and had their own display and consultation literature.




Table 2.9: Exhibition Details for SSA consultation

Times Date Venue

Midday-20:00 Thursday 6 November 2008 The Princess Theatre, Burnham-on-Sea

10:00-16:00 Saturday 8 November 2008 Danesfield School, Williton

14:00-20:00 Wednesday 12 November 2008 Victory Hall, Stogursey

10:00-16:00 Saturday 15 November 2008 Bridgwater Town Hall, Bridgwater

2.2.79 EDF Energy also provided a number of its exhibition boards and some written material at British Energy’s public meetings held at Nether Stowey, Cannington, Bridgwater, Cannington and Stogursey. Representatives from EDF Energy and other members of the HPC Project team attended these events and EDF Energy also gave a brief presentation on its plans for Hinkley Point.

2.2.80 A series of exhibition boards were displayed at EDF Energy’s pre-Stage 1 exhibitions providing an overview of the site and key issues, which can be seen in Appendix C. The headings of the boards are provided below:

Meeting Our Energy Challenges: The electricity generation gap and the need for security of supply.

EDF Energy and Hinkley Point: Information on the Company and its commitment to community engagement.

EDF Energy’s Hinkley Point Site: The opportunities for the site and explaining EDF Energy’s relationship with British Energy.

Public Consultation: EDF Energy’s consultation on the scope of the Environmental Impact Assessment (EIA) and the criteria laid down by the Government as part of its SSA for new nuclear power stations.

What We Are Consulting On: Inviting views on the local and site-specific views as well as social and economic benefits.

The Technology: Details of the EPR and explaining the Generic Design Assessment (GDA) process.

Safety and Security: EDF Energy’s experience and safety record.

Managing Waste: information on waste and storage.

Key Local Issues and Benefits: Including traffic and transport, the construction process, safety and security, power lines, jobs and the economy, the facility, environmental and reinstatement of the site.

Proposed Timeline: A provisional timeline for planning and construction.

Have Your Say: How to comment on the proposals.

Stage 1

2.2.81 Ten public exhibitions were arranged at different locations within the inner (within 5 miles of the site) and middle (5 to 10 miles of the site) zones of consultation at




different times to provide those interested with a range of opportunities to attend. Figure 2.13 shows the Cannington exhibition held in November 2009.

Figure 2.13: Photograph from Cannington Exhibition (28 November 2009)

2.2.82 An independent market research company, MSS Research, was also commissioned to conduct exit interviews with a random sample of visitors leaving the public exhibitions to gather their views on the consultation process.

2.2.83 Initial feedback from MSS Research’s research was generally positive, but revealed some dissatisfaction from those attending the Cannington exhibition on 28 November 2009, who felt the venue was too crowded and, therefore, that they were not able to see all the exhibition material or discuss the proposals with members of EDF Energy’s project team. Although the village hall is used for many community events in Cannington and had been considered as having an adequate capacity, the level of demand and the results of the independent research led to the decision to provide an additional exhibition in Cannington Village Hall from 10:00 to 19:00 on Tuesday 5 January 2010, which was attended by 101 people. Further information on MSS Research exit interviews can be viewed in Appendix C of this report.

2.2.84 An exhibition for workers at Hinkley Point A and B stations was also planned from 15:30 to 18:00 on Wednesday 6 January 2010. As a result of adverse weather conditions, this was rearranged for Thursday 28 January 2010 in the Hinkley Point B Induction and Training Centre.

2.2.85 More than 1,200 people attended the public exhibitions for EDF Energy’s Stage 1 ‘Initial Proposals and Options’ consultation. See Table 2.10 below.

Table 2.10: Exhibition Details for ‘Initial Options and Proposals’ consultation

Times Date Venue Approximate Attendance

10:00-16:00 Saturday 28 November 2009 Cannington Village Hall 402

14:00-20:00 Wednesday 2 December 2009 Stogursey Village Hall 138

14:00-20:00 Thursday 3 December 2009 Otterhampton Village Hall 78

10:00-16:00 Saturday 5 December 2009 Danesfield School, Williton 283







11:00-19:00 Monday 7 December 2009 North Petherton Community Centre

47

14:00-20:00 Wednesday 9 December 2009 The Exchange, Express Park, Bridgwater

37

14:00-20:00 Friday 11 December 2009 Princess Theatre, Burnham-on-Sea

33

Midday-18:00 Monday 14 December 2009 EDF Energy’s Bridgwater office 42

10:00-19:00 Tuesday 5 January 2010 Cannington Village Hall 101

15:30-18:00 Thursday 28 January 2010 Hinkley Point B Training Centre 47

2.2.86 A series of exhibition boards were displayed, providing the following information:

Introduction: Why nuclear? Why Hinkley Point? Related consultations.

This Consultation: Details about what EDF Energy is consulting on and a draft timeline for pre-application consultation and submission of the DCO application to the IPC.

HPC Power Station: The power station, technology and waste management, construction, landscape and wildlife after construction, and footpaths.

Associated Development: Location of the search areas, Cannington bypass options initial assessment, strategy for workers accommodation, park and ride, freight handling facilities, Combwich Wharf, road improvements and other works.

In the Community: Community benefits, jobs, training and legacy from associated development.

Preliminary Works: Temporary jetty, sea wall and on-site preparation work.

Making your Views Known: Ways in which to respond to EDF Energy’s consultation and the draft timeline for the Government’s and National Grid’s consultations.

2.2.87 The full set of exhibition boards is available to view in Appendix C.

2.2.88 In addition to the boards, the exhibitions also included a physical model of the proposed power station at HPC, a DVD showing the construction of a European Pressurised Water Reactor (UK EPR) and copies of the Stage 1 Proposal Summary Document and other display materials.

Stage 2

2.2.89 A total of 18 exhibitions were held at the beginning of the Stage 2 consultation at a variety of locations within the inner, middle and outer consultation zones (see Table 2.10).

2.2.90 The public exhibitions in Cannington and Williton were held on a Saturday and the main exhibition in Bridgwater was held in the shopping area to ensure a good


pedestrian footfall and to target a wider demographic. Figure 2.14 shows the Angel Place exhibition in Bridgwater held in July 2010.

2.2.91 A specific preview exhibition was held on 8 August 2010 at Bridgwater College, Cannington 2010 for members of EDF Energy’s HPC Community Forum. An extra public exhibition was also held on 7 September 2010 in the Sedgemoor Auction Centre near Junction 24 of the M5 once it became clear that some residents living on a new housing development (Stockmoor Village) in the vicinity of this proposed associated development site had not received copies of the EDF Energy newsletter advertising the exhibition schedule. EDF Energy also held public exhibitions in Minehead and Burnham-on-Sea in the August 2010 holiday period, specifically to target visitors to the area, and in the car parks of two major supermarkets in Bridgwater in September 2010, with the specific aim of enhancing engagement with women and younger people.

2.2.92 Workplace exhibitions were also arranged for staff at the Hinkley Point A and B stations and for staff at the headquarters offices of Somerset County, West Somerset and Sedgemoor District councils.

Figure 2.14: Photograph from Angel Place Exhibition (16 July 2010)

Table 2.11: Exhibition Details for Stage 2 ‘Preferred Proposals’ consultation


10:00-15:00 Wednesday 7 July 2010 Hinkley Point A and B Stations 199

Midday-14:00 Thursday 8 July 2010 Somerset County Council Preview 120

16:00-18:00 Thursday 8 July 2010 Community Forum Preview 40

Midday-15:00 Friday 9 July 2010 Sedgemoor District Council Preview 70

Midday-15:00 Friday 9 July 2010 West Somerset Council Preview 23

10:00- 16:00 Saturday 10 July 2010 Bridgwater College, Cannington 207

Midday-18:00 Monday 12 July 2010 North Petherton Community Hall 68







14:00-20:00 Tuesday 13 July 2010 Otterhampton Village Hall, Combwich 81

14:00-20:00 Wednesday 14 July 2010

Stogursey Victory Hall 124

14:00-20:00 Thursday 15 July 2010 The Exchange Express Park, Bridgwater

40

09:00-18:00 Friday 16 July 2010 Angel Place Shopping Centre, Bridgwater

300

10:00-16:00 Saturday 17 July 2010 Danesfield School, Williton 68

14:00-20:00 Monday 19 July 2010 Princess Theatre, Burnham-on-Sea 57

10:00-16:00 Thursday 19 August 2010

Pier Street South Car Park, Burnham-on-Sea

28

10:00-16:00 Friday 20 August 2010 Summerland Car Park, Minehead 87

Midday-20:00 Tuesday 7 September 2010

Auction Centre, Junction 24 68

10:00-18:00 Wednesday 8 September 2010

Morrisons Car Park, Bridgwater 61

10:00-16:00 Saturday 11 September 2010

Asda Car Park, Bridgwater 119

2.2.93 Approximately 1,760 people attended the exhibitions for EDF Energy’s Stage 2 ‘Preferred Proposals’ consultation.


This Consultation: details of the consultation and how to make views known.

HPC Power Station: power station proposals, public rights of way and proposed construction timeline.

HPC Power Station (continued): landscaping and wildlife and temporary on-site accommodation.

Associated Development: accommodation and transport strategies.

Cannington Proposals.

Williton Proposals.

Bridgwater Proposals: Bridgwater A (Innovia site) and Bridgwater C (Bridgwater and Albion Rugby Football Club).

Motorway Junctions: Junction 23 and 24 proposals.

Combwich Wharf Proposals.

Community – Our Commitment: economic development; low carbon future; education, employment and skills; housing/accommodation and community wellbeing.


2.2.95 The full set of exhibition boards are available to view in Appendix C.

2.2.96 In addition to the boards, the exhibitions also included a physical model of the proposed power station at HPC, a DVD showing an interactive fly-through of the proposed HPC site and associated development sites, a full suite of supporting documentation and summaries of the Stage 2 Proposals, Environmental Appraisal and Stage 1 Interim Consultation Report.

2.2.97 The interactive fly-through model of the proposed development was played on a loop at the Stage 2 exhibitions and, later, at other presentations and at the Bridgwater office. It depicted an 800km2 area of Somerset between Puriton, to the east of the M5; Williton in west Somerset and Bridgwater to the south, incorporating all of EDF Energy’s proposals for Hinkley Point C, including the associated development.

2.2.98 The objective of the model was to make the proposals accessible through a visual representation of the HPC Project. Its interactivity allowed local residents, and other stakeholders, to view the proposed developments from the vantage point of their own homes or a particular location. The model was available at all Stage 2 consultation exhibitions and was well received, with a specialist technician on hand to take people to their desired location.

2.2.99 The model has since been updated to reflect the final proposals in the DCO application. It will be made available post-submission to provide an up-to-date representation of the proposals.

Stage 2 Update

2.2.100 Seven public exhibitions, in the areas most likely to be affected by the proposed changes, and two workplace previews were arranged for staff at Hinkley Point A and B during the Stage 2 Update consultation period (see Table 2.12). Figure 2.15 shows EDF Energy at the Bridgwater College exhibition in Cannington held in March 2011.

Figure 2.15: Photograph from Cannington Exhibition (4 March 2011)




Table 2.12: Exhibition Details for Stage 2 Update consultation


10:30-12:30 Thursday 24 February 2011 Hinkley Point B, Canteen 130

14:30-16:30 Thursday 25 February 2011 Hinkley Point A, Canteen 135

Midday-16:00 Saturday 26 February 2011 Danesfield School, Williton 60

14:00-20:00 Monday 28 February 2011 Auction Centre, Junction 24 60

14:00-20:00 Tuesday 1 March 2011 Otterhampton Village Hall 130

14:00-20:00 Wednesday 2 March 2011 Stogursey Victory Hall 75

14:00-20:00 Thursday 3 March 2011 The Exchange, Express Park, Bridgwater

35

14:00-20:00 Friday 4 March 2011 Bridgwater College, Cannington

150

10:00-16:00 Saturday 5 March 2011 Angel Place, Bridgwater 375

2.2.101 Approximately 1,150 people attended the exhibitions for EDF Energy’s Stage 2 Update.


This Consultation: details of the consultation and how to make views known.

Local Jobs and Economy: employment brokerage, local college skills investment, apprenticeships for local people, supply chain and attracting economic development and tourism to Somerset.

Associated Development: key changes to accommodation and transport strategies.

Accommodation Strategy: existing accommodation, purpose-built accommodation, housing fund and new housing.

Transport Strategy: highway improvements and bypass proposals.

The Workforce: working hours and workers code of conduct.

Main Site: update and key changes to main site and on-site campus.

Cannington: update and key changes to park and ride and bypass.

Williton: update and key changes park and ride.

Bridgwater Accommodation: update and key changes Bridgwater A and C.

M5 Motorway Junctions: update and key changes at Junctions 23 and 24.

Combwich Wharf: update and key changes to laydown area and access road.

Community Impacts and Benefits: community fund, health and wellbeing, emergency services and security, environmental mitigation and local mitigation.




2.2.103 The full set of exhibition boards are available to view in Appendix C.

2.2.104 A document outlining the proposed changes was available in hard copy for everyone who attended the exhibition and was available to download from the HPC Project website, along with six draft strategy documents on accommodation, associated development construction, HPC construction, freight management, construction phase waste and workforce profile.


2.2.105 Three public exhibitions were held in the Bridgwater area at locations close to the alternative site being considered at M5 Junction 24 and the proposed highway improvements (see Table 2.13).

2.2.106 As there were no amendments to the proposals for the main HPC Development Site, it was decided that workplace exhibitions (at Hinkley Point A and B) were not appropriate at this stage. However, the exhibitions were advertised through newsletters delivered to the Hinkley Point A and B sites.

2.2.107 Figure 2.16 shows EDF Energy at the exhibition at Sedgemoor Action Centre, Bridgwater held on 16 July 2011.

Figure 2.16: Photograph from Sedgemoor Auction Centre Exhibition (11 July 2011)

Table 2.13: Exhibition details for Junction 24 and Highways Improvements Consultation


Midday-20:00 Monday 11 July 2011 Sedgemoor Auction Centre, Junction 24

141

10:00-16:00 Saturday 16 July 2011 Angel Place Shopping Centre, Bridgwater

272

Midday-20:00 Thursday 21 July 2011 Bridgwater Town Hall 60




2.2.108 Approximately 473 people attended the exhibitions for EDF Energy’s Junction 24 and Highways Improvements Consultation.

2.2.109 A series of exhibition boards was displayed, providing an overview of the consultation, the latest on the proposals, details of the alternative site plans and proposed highways improvements. The full set of exhibition boards are available to view in Appendix C.

vii. Questionnaire

2.2.110 EDF Energy used questionnaires throughout the consultation process as one of the routes for the local community and general public to feed back their views on the proposals for HPC and associated developments.

2.2.111 Separate questionnaires were also used to encourage feedback on EDF Energy’s property price support scheme for the local community near to the main HPC Development Site. However, as this scheme does not form part of the DCO application, the questionnaire responses are not detailed in this report. Issues raised about this scheme through the formal DCO consultation process are, however, responded to by EDF Energy in Chapter 3 and 4.

2.2.112 A health action plan questionnaire was also used with residents of Shurton, Burton, Knighton and Wick as part of EDF Energy’s proposals for HPC. Details can be found in the Health Impact Assessment.

2.2.113 At Stages 1 and 2 of the consultation, the questionnaires contained a mixture of specific questions and comments boxes in order to generate qualitative and quantitative responses on EDF Energy’s overall proposals. Each questionnaire provided space for respondents to make any comments that they wished in addition to the specific questions posed by EDF Energy. There was no requirement for respondents to answer all or any of the questions – they could simply make a comment if this was their preference.

2.2.114 For the Stage 2 Update and Junction 24 and Highways Improvements consultations, questionnaires were produced with themed comment boxes, into which respondents were invited to submit their views and suggestions on the proposed changes. There were no quantitative questions, as these were not part of the main stages of consultation but an update to previously published proposals.

2.2.115 Each questionnaire was available in hard copy at the public exhibitions and in the EDF Energy Bridgwater office (from Stage 1 onwards), and electronically to complete on the HPC Project website.

2.2.116 At each stage EDF Energy produced information summarising its proposals, and the questionnaires were designed to elicit respondents’ views after they had reviewed this information. The individual questions inviting comments were also contained in the relevant section of these documents to prompt feedback from local community and public consultees.

2.2.117 A unique reference number was allocated to each completed questionnaire at all stages of the pre-application consultation under the Act. This referencing system




enables respondents to track their comments (see Appendix H). Details on how to use this public reference tracking system are available in Chapter 5 in this report.

2.2.118 An analysis of comments received at all stages of the pre-application consultation under the Act, and EDF Energy’s responses, are also available in Appendix H of this report.

2.2.119 The results of the questionnaires were analysed and reviewed after each stage of consultation and helped EDF Energy shape its final proposals for the HPC Project.

Pre-Stage 1

2.2.120 Before formal pre-application consultation on plans for HPC began in 2009, EDF Energy undertook a consultation in 2008 on the prospect of a new nuclear build programme at Hinkley Point.

2.2.121 As part of this consultation, a questionnaire was provided for respondents consisting of three questions followed by a comments box. This can be viewed in Appendix C.

2.2.122 The results of this consultation were reported in a Public Consultation Statement (see Appendix B), which was available to download from the HPC Project website throughout formal consultation on EDF Energy’s proposals for HPC.

Stage 1

2.2.123 At Stage 1, EDF Energy sought comments and views on its ‘Initial Proposals and Options’ and the questionnaire can be viewed in Appendix C.

2.2.124 As well as being available in hard copy at the exhibitions, in the EDF Energy Bridgwater office and on the website (www.edfconsultation.info), laptops were also set up at the exhibitions so that people could fill in questionnaires electronically if preferred.

2.2.125 The questionnaire was designed to be answered once consultees had reviewed the information in the Proposal Summary Document or at the exhibitions. The questions posed were specifically designed to seek feedback from respondents on the various key options that EDF Energy was considering and to assist in developing its Preferred Proposals for the HPC Project. It also provided an opportunity for respondents to make any points that they wished about the proposals. The questions covered the following issues:

The landscape buffer proposed on the southern boundary of the HPC Development Site to minimise the potential impact of the construction site on nearly residents.

Restoration options at the end of the construction phase.

The strategy for public rights of way across the site during construction.

Initial proposals for managing traffic and accommodation during the construction phase.




The proposed bypass for Cannington and options to the east or west of the village.

The different accommodation options for construction workers including worker campuses proposed (on-site, in Cannington, in Williton and in Bridgwater) and existing options including guesthouses and caravan parks.

The proposed park and ride options in Cannington, at Junctions 23 and 24 of the M5 motorway and near Williton.

The proposed freight handling facilities adjacent to some of the park and ride sites (at Junctions 23 and 24, and near Williton) and at Combwich.

EDF Energy’s general approach to community benefits and specific suggestions.

Training and business options.

EDF Energy’s proposals for undertaking, at its own risk, preliminary works to get the site ready for construction.

2.2.126 There were a total of 11 questions but respondents were advised that they did not have to answer all of these and, if they preferred, could just submit comments in the space provided at question 12.

Stage 2

2.2.127 At Stage 2 EDF Energy sought views on its ‘Preferred Proposals’. The questionnaire used for this stage of consultation can be viewed in Appendix C.

2.2.128 As well as being available in hard copy at the exhibitions, in the Bridgwater office and on the website, laptops were also available so that people could fill in questionnaires electronically at the exhibitions, if preferred.

2.2.129 The questionnaire was designed to be answered with the information presented in EDF Energy’s ‘Preferred Proposals: Summary’ document or at the public exhibitions. The questions posed were specifically designed to seek feedback from respondents on key aspects of the ‘Preferred Proposals’ and to help EDF Energy refine its proposals and consider the need for material changes to the plans prior to submission of the DCO application.

2.2.130 There were a total of 12 questions which people were invited to answer. However, as at Stage 1, if respondents preferred they could just submit an overall comment in the box at the end of the questionnaire. In addition, people were invited to give their views on specific subjects by putting their comments in the box after each question, whether or not they had chosen specifically to answer that question.

2.2.131 The questions covered the following issues:

Proposed arrangement and landscaping of the HPC Development Site.

Reduction in the amount of land to be used during construction in the southern part of the HPC Development Site in response to concerns from local residents.




Preliminary works to prepare the HPC Development Site and build a temporary jetty for the delivery of bulk materials.

Overall accommodation strategy – for local and non-local workers including proposals for accommodation campuses.

Overall transport strategy – increased traffic movements during construction and EDF Energy’s management approach using park and ride and freight logistics facilities.

Proposed Cannington western bypass.

Plans for a temporary park and ride facility on the A39, south of Cannington, for visitors to the HPC Development Site and workers from Bridgwater and other nearby settlements.

Plans for a temporary park and ride facility on the A39, west of Williton, for workers from Minehead and other nearby settlements.

Plans to accommodate non-local workers in accommodation campuses – proposed campuses at Bridgwater Innovia site (up to 1,075 places), Bridgwater and Albion Rugby Football Club (up to 150 places) and HPC (up to 700 places).

Plans for Junction 23 of the M5 motorway – a park and ride facility for workers and a freight logistics facility.

Plans for Junction 24 of the M5 motorway – a park and ride facility for workers and a freight logistics facility.

Plans to bring in as much of the construction material as possible by sea – including large components – refurbishing Combwich Wharf and providing an associated freight logistics/storage area.

Stage 2 Update

2.2.132 At this stage EDF Energy sought views on the proposed material changes to its ‘Preferred Proposals’ for the HPC Project. The questionnaire used at this stage can be viewed at Appendix C.

2.2.133 The questionnaire was available in hard copy form at the exhibitions, in the Bridgwater office and on HPC Project website. However, laptops were not provided for people to fill out the questionnaires electronically at the exhibitions at this stage because of a lack of demand for this facility during the Stage 1 and Stage 2 consultations.

2.2.134 The questionnaire was designed to be answered with the information presented in EDF Energy’s ‘Update on and proposed changes to the Preferred Proposals’ consultation document

2.2.135 The questions were directly related to the material changes proposed to the ‘Preferred Proposals’ and were designed to seek feedback from respondents so that EDF Energy could consider the need for further refinements prior to the submission of its DCO application.




2.2.136 There were a total of six comments boxes following questions asking about the following key proposed areas of change:

The workforce and employment, skills and business engagement.

Accommodation proposals.

Community mitigation and benefits.

Working hours proposals.

Changes to the transport proposals.

Changes to the main site plans.

2.2.137 Those preferring to submit an overall comment were referred to the general comment section at the end of the questionnaire.


2.2.138 At this stage EDF Energy sought views on an alternative site for the proposed park and ride and freight management facility near Junction 24 of the M5 and additional highway improvements in the Bridgwater area. The questionnaire can be viewed at Appendix C.

2.2.139 The questionnaire was available in hard copy form at the exhibitions, in the Bridgwater office and on the HPC Project website and was designed to be answered with the information presented in EDF Energy’s ‘Proposed Changes to the Preferred Proposals including M5 Junction 24 and Highway Improvements in the Bridgwater Area’ consultation document.

2.2.140 As with the Stage 2 Update consultation, the questions were directly related to the material changes proposed and were designed to seek feedback from respondents on those issues so that EDF Energy could consider the need for further refinements prior to the submission of its DCO application.

2.2.141 There were a total of three comment boxes:

Do you have any comments on our proposals for the use of the ‘Somerfield’ site near M5 Junction 24?

Do you have any comments on our additional proposals for highway improvements in the Bridgwater area?

Do you have any other comments?

2.2.142 In this way, those preferring to submit an overall comment could do so without having to complete the whole questionnaire.




viii. EDF Energy’s Bridgwater office

2.2.143 EDF Energy opened an office in King Square, Bridgwater in April 2009. The office is used as a local base for EDF Energy staff working on the plans for nuclear new build at Hinkley Point and was also designed as a contact point for the local community.

2.2.144 The exhibition panels, model and consultation documents were on display in the office during all stages of consultation under the Act.

2.2.145 Between stages, information continued to be available to visitors including hard copies of newsletters. The office also had exhibits that demonstrated electricity generation and the workings of a pressurised water reactor in a simple and accessible way. In addition, the digital fly-through of the proposals used at Stage 2 was available to view.

2.2.146 The office was open Monday to Friday, 09:00 to 17:00 (excluding bank holidays), where staff were available to respond to queries face-to-face and by phone and to guide visitors through the proposed plans.

2.2.147 Outside of normal opening hours, the office was staffed by EDF Energy contact centre staff, who managed out-of-hours calls.

2.2.148 The office was fully accessible and provided a seating area for visitors with a complementary drinks vending machine and drinking water. In November 2010, the office introduced a freephone number in addition to the office phone number, which was advertised in all consultation documents.

2.2.149 The office was also used by the Environment Agency to help raise awareness of its own consultation in relation to HPC.

ix. Consultation Documentation

2.2.150 At each stage of consultation EDF Energy produced consultation documents in order to provide consultees with information on the proposals and to help inform their responses. In order to make the information as accessible as possible for the local community and general public, at Stages 1 and 2 for which large amounts of technical information were made available, EDF Energy also produced summary documents to highlight the key issues being considered.

Stage 1

2.2.151 EDF Energy produced a Proposal Summary document of its ‘Initial Proposals and Options’ as part of its formal Stage 1 consultation, which also provided details of the consultation process and exhibitions (see Appendix C).

2.2.152 This was distributed to:

Approximately 100 residents in Shurton and Burton by hand.

Approximately 1,020 stakeholders (including those in the middle and outer consultation zones as well as the wider region) by post.





West Somerset, Sedgemoor and Somerset council offices.


It was also available at meetings, exhibitions and EDF Energy’s Bridgwater office.

2.2.153 The Proposal Summary Document was also available to download from the HPC Project website.

2.2.154 The full Stage 1 ‘Initial Proposals and Options’ consultation document was available to download from the website.

2.2.155 The full consultation document was also available for viewing in hard copy and on CD for use on home computers at:


West Somerset, Sedgemoor and Somerset Council offices.


EDF Energy exhibitions.

EDF Energy’s Bridgwater office.

Stage 2

2.2.156 EDF Energy produced the following three summary documents as part of its suite of Stage 2 ‘Preferred Proposals’ consultation material:

Stage 2 Summary Document: summarised the ‘Preferred Proposals’, and provided details of the consultation process, exhibitions and key changes made as a result of Stage 1 consultation (see Appendix C).

Environmental Appraisal Summary Document: a plain English summary of the Environmental Appraisal that set out the current understanding of the likely environmental impacts of the proposals (see Appendix C).

Stage 1 Consultation Report Summary: a summary of the Interim Stage 1 Consultation Report (see Appendix B).

2.2.157 They were distributed to:

Elected representatives including the local MP, Somerset County, West Somerset and Sedgemoor district councillors, and some parish councillors.

All parish councils in West Somerset and Sedgemoor District council areas.

All public libraries in Somerset.





All tourist information centres in West Somerset and Sedgemoor (Bridgwater, Burnham-on-Sea, Dunster, Dulverton National Park, Minehead, Porlock, Somerset-M5 and Watchet).

2.2.158 These summary documents were also made available at all meetings, exhibitions and workshops, and in the EDF Energy Bridgwater office, both in hard copy and on a DVD.

2.2.159 The full Stage 2 ‘Preferred Proposals’ consultation suite of documents was available for download from the consultation website. This was also provided on a DVD, which was available to take away at meetings, exhibitions and EDF Energy’s Bridgwater office. Due to the large number of documents in the suite, a navigation document (see Appendix C) was provided to aid understanding of where people could find more detailed information.

2.2.160 Full details of the ‘Preferred Proposals’ in hard copy and on DVD and the full Interim Stage 1 Consultation Report were also available for viewing at:

Bridgwater, Burnham-on-Sea, Frome, Nether Stowey, Taunton and Yeovil libraries.


EDF Energy exhibitions.

EDF Energy’s Bridgwater office.

Stage 2 Update

2.2.161 The Stage 2 Update consultation document presented a number of material changes to the Stage 2 ‘Preferred Proposals’.

2.2.162 Due to the focused nature of the consultation, this significantly smaller document was written with the intention of being accessible for the public as well as statutory consultees and other relevant stakeholders. Therefore it was not considered necessary to produce additional summary documents of the proposals.

2.2.163 The consultation document was distributed to:



All tourist information offices in Sedgemoor and West Somerset council areas.

2.2.164 It was also available at meetings, exhibitions and EDF Energy’s Bridgwater office.

2.2.165 The Stage 2 Update document was also available to download from the HPC Project website.




2.2.166 Supplementary draft strategy documents were also available on the website and included:

Draft accommodation strategy.

Draft overview of associated development construction.

Draft overview of HPC construction.

Draft freight management strategy.

Draft construction phase waste strategy.

Draft workforce profile report.

Proposed red line plans.


2.2.167 The Junction 24 and Highways Improvements consultation document presented an alternative site for the Junction 24 park and ride and freight management facility as well as new and updated highway improvements in the Bridgwater area.

2.2.168 As at the Stage 2 Update consultation, due to the focused nature of the consultation, this significantly smaller document was written with the intention of being accessible for the public as well as statutory and other relevant stakeholders. Therefore it was not considered necessary to produce additional summary documents of the proposals.

2.2.169 The consultation document was distributed to:



All tourist Information offices in Sedgemoor and West Somerset Council areas.

2.2.170 It was also available at meetings, exhibitions and EDF Energy’s Bridgwater office.

2.2.171 The consultation document was also available to download from the HPC Project website.

2.2.172 Supplementary documents including Preliminary Environmental Information on the proposed changes and red line plans of the proposed highway improvements were also available on the HPC Project website, at the public exhibitions and at EDF Energy’s Bridgwater office.

x. Website

2.2.173 EDF Energy established a project-specific website for HPC on 13 October 2008, which was developed as a portal reached via the EDF Energy public consultation website. The website can be accessed both via the portal or by a separate website address.




2.2.174 The website address for the HPC Project was initially set up as www.edfconsultation.info, but in October 2010 the address was updated to www.edfenergyconsultation.info. Both addresses continue to direct people to the correct website.

2.2.175 The website provided a central point from which to access information about the process and proposals and to enable participation in the consultation via an online questionnaire.

2.2.176 As the consultation advanced, the website expanded and subsequent sections/subsections were developed to present the information in a structured format.

2.2.177 An archive was also created in order to preserve information from previous stages of the consultation and to enable visitors to revisit past information.

2.2.178 To create greater access to key information, large links were prominently placed on each web page to the primary document at each stage and translated versions, as well as to the central EDF Energy consultation website.

2.2.179 Information on the website included:

Information in respect of the preliminary works at the HPC site.

Public consultation – SoCCs, consultation documents, exhibition boards, newsletters, Community Forum agendas and minutes, Transport Forum agendas and minutes, and Main Site Neighbourhood Forum agendas and minutes.

Community projects.

Key benefits – jobs, skills and training; tender opportunities and accommodation.

Newsroom – press releases and newsletters.

Skills and training information.

Links – national government, regional government; local authorities, other consultations and other links.

Contact details.

2.2.180 For each stage of the consultation, there were details provided of the public consultation, supporting documentation and the opportunity to respond electronically by filling in a questionnaire online or by sending comments by email.

2.2.181 Translations of the ‘Stage 2 Preferred Proposals Summary’ and a summary of the Stage 2 Update consultation documents were available in Bengali, Chinese, Polish and Portuguese. These were linked to an icon of the relevant national flag on each of the pages of the website to aid access by speakers of other languages.




2.2.182 These languages were agreed following advice from Somerset Racial Equality Council (SREC) and were available from Stage 2 following EDF Energy’s decision to engage with hard-to-reach groups at the ‘Preferred Proposals’ Hard-to-reach stage.

2.2.183 As can be seen from Table 2.14, numbers of downloads of the translations were small, although Polish downloads at Stage 2 were higher than for the other languages. At Stage 2 Update, Portuguese was the most downloaded translation.

Table 2.14: Downloads of Translated Documents

Language Stage 2 Preferred Proposals Summary

Stage 2 Update on and Proposed Changes to the Preferred Proposals

Bengali 3 4

Chinese 3 5

Polish 11 4

Portuguese 4 6

2.2.184 Due to the limited nature of the Junction 24 and Highways Improvements Consultation, a translation and interpretation service was available on request only. This was publicised in the newsletter, on the website and at the public exhibitions. However, the service was not requested at this stage of consultation.

2.2.185 Table 2.15 summarises traffic to the project website during the different consultation stages, both in terms of unique visitors at each stage and visits to the public consultation page. Unique visitors are defined as hits on the website from different IP addresses and so may not necessarily represent different individuals. As can be seen, hits to the website increased significantly during Stage 2, which may be in part due to increased awareness of the availability of the information portal as the consultation progressed.

Table 2.15: Visitors to Consultation Website

Stage of Consultation Unique Visitors

Pre-Stage 1 (13/10/08 up to 15/11/09) 9,958

Stage 1 and pre-Stage 2 (16/11/09 up to 8/7/10) 24,486

Stage 2 and pre-Stage 2 Update (9/7/10 up to 24/2/11) 51,322

Stage 2 Update and pre-Junction 24 consultation (25/2/11 up to 30/6/11)

15,932

Junction 24 consultation (01/07/11 up to 12/08/11) 17,302

Pre-submission (13/08/11 up to 28/09/11) 15,956

c) Market Research

2.2.186 In order to ensure the consultation was effective at each main stage of consultation, and to establish if any additional tools were required in order to enable all those interested in the proposals to participate, MSS Research (an independent market research company) was commissioned to conduct exit interviews with a random sample of visitors leaving the public exhibitions to find out what they thought of the consultation process.




Stage 1

2.2.187 Initial feedback from MSS Research was generally positive but revealed some dissatisfaction that the venue for the Cannington exhibition on 28 November 2009 was too crowded, so an additional exhibition in Cannington Village Hall was held from 10:00 to 19:00 on Tuesday, 5 January 2010. Appendix D provides details of the exit interviews.

2.2.188 A summary of the conclusions from the exit interviews carried out at the public exhibitions is provided below:

A positive reaction overall to the consultation process and communication.

Many people were initially made aware of the consultation process via newsletter/home mailing or a local press article; there were some apparent significant differences in media impact in different venues.

There were very high ratings of the information at the exhibition being easy to follow, with the information boards/panels most likely to be viewed and all visitors rating them as very or quite useful.

Printed paper materials were well rated by those who viewed them, although just over a quarter had not yet formed an opinion about them at the time they were interviewed.

The scale model was also well rated overall; and the computer film was viewed by about half the visitors and was well rated.

Not being interested or not having enough time were the main reasons for not viewing one or more of the information areas/items.

Although only one in five visitors completed a questionnaire at an exhibition, the majority of those interviewed said they would complete one at some point in the near future.

Almost all visitors spoke with an EDF Energy staff member, and the rating of staff helpfulness was very high.

Nearly three quarters of visitors said that as a result of their visit to the exhibition they were now better informed about the proposals than before their visit.

There was above-average representation of older people (those over 45 years) and men at the public exhibitions and an under-representation of younger people (those under 45 years old) and women compared with the population as a whole.

Attendance at public exhibitions in Bridgwater was lower than near the site at Cannington and in Williton despite the larger population of the town.

Stage 2

2.2.189 MSS Research was commissioned to undertake further exit interviews of those attending the Stage 2 public exhibitions to assess reactions to the consultation process and to see whether the new locations for some of the exhibitions had helped to encourage greater attendance amongst younger people and women.




2.2.190 This further research focused on women and younger people, as the original MSS Research undertaken at Stage 1 indicated that these groups had been under-represented at the public exhibitions. Additionally, in their joint response to consultation on SoCC 2 in June 2010, the local authorities specifically identified women and younger people as hard-to-reach groups with whom they believed EDF Energy should make further efforts to engage in its Stage 2 consultation.

2.2.191 A summary of the conclusions of this research is shown below:

There was a positive reaction overall to the consultation process and the means of communication.

Visitors to the exhibitions were a mix of genders across all ages, although the bias towards males and mid to older age group visitors remained.

Nearly two thirds of visitors spent more than 15 minutes at the exhibition, but the average dwell time was significantly less in the exhibitions held at tourist locations and in supermarket car parks.

Many confirmed they had been initially aware of the consultation process via newsletter/home mailing or a local press advert or article.

Visitors to the exhibitions held at tourist locations and in supermarket car parks were far more likely to have noticed the exhibition in the car park or just be passing.

The majority of visitors rated the information at the exhibitions as easy to follow.

Nearly all spoke to an EDF Energy staff member and, of these, more than two thirds rated them as very helpful and the rest as quite helpful.

More than eight out of 10 visitors felt that they were either much better informed or a little better informed as a result of their visit.

2.2.192 It was apparent from the MSS Research at the Stage 2 public exhibitions that many residents in the new housing development close to the EDF Energy site near Junction 24 of the M5 had not received copies of the newsletter advertising the consultation process. This was due to the fact that, at the time of identifying stakeholders on the proposals, the new housing development had not yet been included on the Royal Mail database, which was used as the basis for the newsletter mailings.

2.2.193 As a result, EDF Energy held an additional public exhibition near the Junction 24 site, and all the residents of these new housing developments were hand-delivered an invitation to this event. This event took place from 12:00-20:00 on Tuesday 7 September 2010 at Auction Centre. The postal distribution list for the EDF Energy HPC newsletter was also updated to include these new homes.




Stage 2 Update and Junction 24 and Highways Improvements Consultations

2.2.194 EDF Energy decided not to commission further independent market research into the profiles of those attending its public exhibitions during the Stage 2 Update and the Junction 24 and Highways Improvements Consultations for two key reasons:

the previous research undertaken at Stages 1 and 2 provided a very clear profile of those who could be expected to attend such consultation events (and the local demographic profile had not changed); and

the scope of these further consultations was limited to material changes to the Stage 2 ‘Preferred Proposals’ and were not re-consultations on the HPC Project as a whole. It was considered to be disproportionate to commission further research for limited consultations.

d) Fora

i. Community Forum

2.2.195 The EDF Energy HPC Community Forum was established in 2009, prior to the start of the Stage 1 consultation. This Community Forum was designed to provide a mechanism for regular discussion between EDF Energy, representatives of the local community and other key stakeholders on the development of new nuclear power at Hinkley Point during the planning and construction process, as well as general matters relating to EDF Energy’s interests in the area (see Table 2.16).

Figure 2.17: Community Forum Meeting (25 February 2010)




2.2.196 The purpose of the Community Forum is to:

allow EDF Energy to keep the local community and key stakeholders informed of relevant issues throughout the planning and construction period;

enable community representatives and other relevant stakeholders to ask EDF Energy questions, raise issues of interest and feed back views from their organisations; and

help EDF Energy to understand the views of the local community and stakeholders, and thereby help minimise the impacts and maximise the benefits of new nuclear development at Hinkley Point.

2.2.197 The first Community Forum took place on 30 September 2009 and was attended by 35 representatives from local groups and organisations with a broad range of interests including: local councillors; Bridgwater College; the Environment Agency; Bridgwater Bay Wildfowl Association; Somerset Trust Badger Group; Stop Hinkley; West Hinkley Action Group; National Farmers’ Union and RAC Foundation.

2.2.198 At this first meeting, EDF Energy confirmed that it would seek an independent person to chair future meetings of the Forum. EDF Energy subsequently appointed Alan Ladd to take on this role. Mr Ladd is a semi-retired businessman based in Taunton who spent much of his career working for AgustaWestland, the Anglo-Italian helicopter company based in Yeovil. He is currently chairman of the Trustees of the AgustaWestland pension fund. He chaired his first meeting of the Forum in November 2009 and remains the Chairman.

2.2.199 The secretariat of the Forum is provided by PPS Group, which managed parts of the public consultation programme on behalf of EDF Energy. Draft minutes are circulated for comment to those attending after each meeting of the Forum and the approved minutes are published on the HPC Project website, together with the agendas.

2.2.200 At the inaugural meeting, the Forum agreed terms of reference to guide its future work. These were as follows:

“To consider and advise on issues that might affect the local community and key stakeholders as a result of EDF Energy’s activities in the vicinity of Hinkley Point, principally those arising from the proposed development of new nuclear power on land adjacent to the existing power stations.”

2.2.201 The terms of reference of the Forum were reviewed at the meeting held on 3 March 2011, and the following additional sentence was added to the existing terms of reference as follows:

“Consideration of issues relating to new nuclear power development in general is not within the scope of this forum.”






Table 2.16: Dates of Community Forum Meetings and Agenda Items

Date Agenda Items

30 September 2009 Terms of reference and membership of the Forum

HPC update

Public consultation and the IPC

Consideration of subjects for discussion at future Forum meetings

12 November 2009 IPC process

SoCC and EDF Energy’s Stage 1 consultation: Initial Proposals and Options

Related consultations

10 December 2009 Stage 1 consultation – IPC proposals

Stage 1 consultation – preliminary works

Engagement with hard-to-reach groups

25 February 2010 National Policy Statements – update

Stage 1 consultation – initial feedback

Stage 2 consultation

Engagement with hard-to-reach groups

20 May 2010 Stage 2 consultation programme/SoCC

Investigation works

Preliminary works

8 July 2010 Stage 2 consultation (including exhibition preview)

Environment Agency: Generic Design Assessments consultation

30 September 2010 HPC update

Stage 2 consultation and the role the IPC would play in reviewing the consultation process

Consideration of subjects for discussion at future Forum meetings

9 December 2010 Consultation on Community Health Action Plan

Update on investigative works

Preliminary works applications

Next steps in the planning process

Presentation on MSS Research’s findings on consultation (PPS)

3 March 2011 Stage 2 Update consultation (including exhibition preview)

Preliminary and investigative works

Terms of reference and membership of the Forum

Environment Agency Engagement Plans for HPC

12 May 2011 Japan and report of the UK’s Chief Nuclear Inspector

Stage 2 Update consultation outcome

Preliminary and investigative works

Transport Forum meetings

Main Site Neighbourhood Forum meetings

7 July 2011 Junction 24 and Highways Improvements Consultation

Investigative and site preparation works

Office for Nuclear Regulation and nuclear site licence process

Transport Forum meetings, 24 May and 28 June 2011

Main Site Neighbourhood Forum meeting, 18 May and 15 June 2011

Report on registration of Forum members

15 September 2011 Emergency procedures and evacuation plans

Site preparation works

Transport Forum meeting, 26 July 2011




Date Agenda Items

Main Site Neighbourhood Forum meetings, 20 July and 17 August

Registration of Forum members

2.2.202

entre and Bridgwater College, Cannington. This decision was reviewed at the meeting held on 12 May 2011, when the Forum

2.2.203

anisations known to have an interest in the development of new nuclear power at Hinkley Point. The full list of those invited to attend was discussed at this

2.2.205 meeting, various organisations that have expressed an interest in participating in the work of the Forum have subsequently been invited to attend its

2.2.206 At the meeting held on 3 March 2011, the Forum agreed to establish a more formal

2.2.207 Although members of the public without affiliation to a member organisation are not

2.2.208 progressed through its pre-application stages, EDF Energy felt that it would be appropriate to establish site-specific sub-committees that could

ore depth than was possible at meetings of the whole

2.2.209

d the Main Site Neighbourhood Forum, have since been established (see

Standing agenda items at each meeting include matters arising from the previous meeting, any other business and the date and venue of the next meeting. At the inaugural meeting, the Forum agreed to rotate the venue for meetings between Hinkley Point B Training and Induction C

decided to continue to alternate its meetings between Hinkley Point and Cannington.

Membership of the Community Forum has been flexible and has evolved over time, ensuring the community is properly represented at all times. The membership has consisted of representatives from the local community and relevant stakeholder organisations with an interest in development at Hinkley Point, together with relevant statutory agencies and local authorities.

2.2.204 For the inaugural meeting of the Forum in September 2009, EDF Energy invited a wide range of organisations to send representatives to the meeting including: West Somerset, Sedgemoor District and Somerset County Councils; relevant parish and town councils; statutory agencies; local community groups; objector groups; and other org

meeting, and a number of additions were suggested to the list of those eligible to attend future meetings.

Since the inaugural

meetings. Attendance at meetings has varied but is normally in the range of 25 to 35 people.

system for membership. All existing member organisations have been asked to complete a registration form and new applications to join will be considered by the Forum as a whole.

invited to attend the Community Forum, anyone wishing to observe the meetings has been allowed to do so, most recently with the prior agreement of the Chairman.

As the HPC Project

consider issues in mCommunity Forum.

The principle of establishing subject specific sub-committees was agreed by the Community Forum at its meeting on 3 March 2011. Two such forums, the Transport Forum anfollowing sections).




ii.

2.2.210 A rgy to have a sounding board within the local community where it could test its detailed proposals for mitigating transport impacts. The Transport Forum has helped to fulfil

2.2.211

“To consider and advise on transport issues arising from the development

2.2.212 aries EDF Energy is proposing development, the local

authorities, highway authorities, emergency services and other groups with specific y Forum, Alan Ladd

2.2.213 ort Forum are circulated to members of the t website with the agendas. Meetings

are normally ith the exception of August 2011 due to the summer holidays (see a items at each meeting include matters arisi ther business and the date and venue of the

Table 2.17: D enda Items

Transport Forum

s the transport plans for HPC developed, it became a priority for EDF Ene

this role.

The terms of reference of the Transport Forum were agreed at the initial scoping meeting on 8 February 2011 as follows:

of HPC, particularly but not exclusively in relation to local roads, and to represent the views of key stakeholders and local communities interested in EDF Energy’s transport plans.”

Membership of the Transport Forum comprises representatives of parish/town councils within whose bound

local transport interests. As with the main Communitindependently chairs the Transport Forum.

Minutes of the mCommunity Forum and posted on the projec

eetings of the Transp

held on a monthly basis, wTable 2.17). Standing agend

ng from the previous meeting, any onext meeting.

ates of Tra sport Forum Meetings and Agn

Date Agenda Items

22 February 2011 (scoping meeting)

Membership

Terms of reference

Chairmanship

Preliminary works

HGV routing through Cannington

HGV routing through Bridgwater

C182 parking

C182 safety improvements

Horse crossing, Wick

Speed restrictions on the C182

Emergency access, Shurton Lane

Next meeting and agenda items

22 March 2011 Membership of the Forum

Memorial junction, Cannington

Parking on the C182

Combwich junction

Claylands Corner junction

Shurton junction

Horse crossing at Wick

Otterhampton junction




Date Agenda Items

Speeding on the C182

HGVs in Bridgwater

y/A39 TaBridgwater – A38 Broadwa unton Road

Bridgwater – Cannon/Cross Rifles junction

Bridgwater – Bristol Road/Wylds Road junction

Bridgwater – Wylds Road/The Drove

Bridgwater – Western Way/Chilton Street

Bridgwater – Quantock roundabout

A39 Sandford Corner junction

Williton buses

Emergency access road, Shurton

Next meeting and agenda

19 April 2011 Membership of the Forum

Road freight and parking at Combwich

C182 and Cannington improvements

nts – update Bridgwater improveme

Timeline of highway improvements

24 May 2011 Membership of the Forum

Cannington improvements

C182 improvements

Combwich lay down area

Williton buses

Bridgwater improvements

Cycling and walking

28 June 2011 C182 improvements

Cannington Mitigation Package

Early years

Bridgwater improvements

Timeline and programme of highway works

26 July 2011 J24/Bridgwater Highways Improvements Consultation

C182 improvements


27 September 2011 C182 improvements

Cycling provision


iii. Main Site Neighbourhood Forum

As detailed plans for the development site have evolved, and in view of the planning application to West Somerset Council to undertake Site Preparation Works, EDF Energy felt that it would be useful to have a regular sounding board with the local communities most directly affected by construction on the main HPC Development Site. The Main Site N

2.2.214

eighbourhood Forum (MSNF) fulfils this role.

main HPC development site, specifically those in the settlements of

2.2.215 At the inaugural meeting on 5 April 2011, the MSNF agreed the following terms of reference:

”To consider and advise on all issues affecting local residents living closest to the




Shurton, Burton, Knighton, Wick and Stolford, including but not necessarily limited to on-site construction activities, control of any on-site accommodation campus, traffic, parking, noise, lighting, landscaping, mitigation and property price support.”

2.2.216 Membership of the MSNF comprises: representatives of those settlements closest to on, two from Burton, one from

ton, one from Wi om Stolford); two additional representatives from rsey Parish Coun

ice ir of the Hinkley Point Site Stakeholder Group.

2.2.217 An independent haired meetings since July 2011, ok esentative. Ms Rozee is a retired

planning inspec ity as a volunteer for Planning Aid in England rid HPC Connection Community Forum.

2.2.218 Agendas and irculated to all members of the Fo ebsite with the

a eet ee Table 2.18). Standing agenda items a g from the previous meeting, any other business xt meeting.

the main HPC Development Site (two from ShurtKnighStogu

ck, and one frcil; one West Somerset councillor representing Quantock Vale

ward; an off r of West Somerset Council; and the Cha

person, Leonora Rozee OBE, has cwhen she to over from an EDF Energy repr

tor who chairs the MSNF in her capac. She also chairs the National G

draft minutes of the MSNF are cCommunity gendas. M

rum and, once agreed, are posted on the project wings are normally held on a monthly basis (st each meeting include matters arisinand the date and venue of the ne

Table 2.18: Dates of MSNF Meetings and Agenda Items

Date Agenda Items

5 April 2011 Terms of reference and membership

Mitigation and property price support

Enterprise centre

Emergency access road

Footpaths and bridleways

18 May 2011 Chairmanship of the MSNF

Air and noise monitoring proposal

Dissemination of information

Future items for discussion

15 June 2011 Main Site Neighbourhood Support Scheme update

Site preparation works update


20 July 2011 Main Site Neighbourhood Support Scheme update

Noise and air quality monitoring update


Enterprise centre update


17 August 2011 Main Site Neighbourhood Support Scheme update



Feedback on Health Survey Questionnaire






Date Agenda Items

21 September Site preparation works update

Communications with local people

Main Site Neighbourhood Support Scheme update




e) Workshops

2.2.219 EDF Energy held stakeholder workshops during the period of consultation prior to

how suitable the HPC site was for new nuclear development.

2.2.221 EDF Energy took the view that its plans for HPC se the stakeholder workshop as a

consultation tool. Engaging wit atutory consultees at in the development of the proposals

was felt to be a good way of helping EDF Energy to refine the detail of its proposals prior to submission of

Pre-Stage 1

2.2.222 As part of its consulta omination, EDF Energy held workshops in Cannington, Taunton, We late November/early December 2008. A w or Barry (South Wales) but due to low attendance the f fing and

n meeting, w s the opportunity to give their ns for Hink were within the outer nd further afield to participate in the

consultation process.

2.2.223 Local councillors and representatives from key local stakeholder groups attended the workshops. Details of a iewed in Table 2.19. Where more than one representative att ts.

EDF Energy’s SSA nomination for Hinkley Point (pre-Stage 1) and at the Stage 2 consultation on EDF Energy’s ‘Preferred Proposals’. Both stages were considered to be where the workshop format would work best in pre-application consultation. The workshops allowed more detailed discussions of some of the key issues of interest to local stakeholders. They also provided a qualitative response to supplement the responses received through the questionnaires. Following each workshop, a report highlighting the key issues and discussion points was sent to attendees for review and sign off.

2.2.220 The pre-SSA nomination consultation process considered whether Hinkley Point was a suitable site for new nuclear development against a range of local, regional and national criteria. EDF Energy decided that a series of geographically based stakeholder workshops would therefore help to identify

During the Stage 2 consultation,were sufficiently advanced and detailed to u

h a mixture of statutory and non-stat a fairly advanced stage in a workshop form

its DCO application.

tion prior to the SSA nston-super-Mare and Minehead in

orkshop was also planned format was amended and the event became a brie

discussio hich offered local stakeholderviews on future placonsultation zone a

ley Point. Most of the locations so allowed stakeholders from

ttendance can be vended, this is marked in bracke




Table 2.19: Groups/Organisations represented at the Stakeholder Workshops

Workshop Attendees

Somerset County Council (4)

Cannington Parish Council (4)

Stogursey Parish Council (3)

West Hinkley Action Group (2)

Somerset Association of Local Councils


National Skills Academy

Stockland Bristol Parish Council

Cannington

(24 November 2008)

Liberal Democrat Parliamentary Candidate for North Somerset

Taunton Deane Borough Council (4)

Norton Fitzwarren Parish Council

Parrett Drainage Board


Somerset PCT

Taunton

(28 November 2008)

South Western Ambulance Service

North Somerset Council (2)

The Environmental Network for North Somerset (2)

North Somerset Liberal Democrats

Mendip Society

Port of Bridgwater

Weston-super-Mare

(1 December 2008)

GVA Grimley on behalf of Highways Agency

Vale of Glamorgan Council (2)

Penarth Town Council

Vale of Glamorgan

(2 December 2008)

Barry Town Council

West Somerset Council (6)


West Somerset Strategic Partnership

Minehead and District Chamber of Commerce

Stogumber Parish Council

Minehead

(9 December 2008)

Representing Ian Liddell-Grainger MP

2.2.224 The agenda for each workshop, which lasted approximately two hours, was broadly as follows:

Introduction – the facilitator explained the workshop objectives, process and timetable and introduced members of the HPC Project team.

Warm-up exercise – the facilitator asked participants to put on post-it notes the benefits and problems that they felt the existing power station had brought to the




local community. He then highlighted the key themes and invited initial discussion.

Presentation – a presentation was given of EDF Energy’s HPC proposals and results of the consultation process to date.

Workshop groups – attendees were divided into groups to discuss: environment; transport; infrastructure and community.

Workshop groups – feedback and discussion.

tage 2

2.2.225 Energy undertook stakeholder workshops to gain a better understanding of local views on its ‘Preferred Proposals’, which formed an integral part of the consultation

2.2.226 re in September 2010 in the Vale of Glamorgan, Minehead, Taunton, Weston-super-Mare and Bridgwater to give stakeholders in the middle and outer consultation zones a further opportunity to discuss the proposals with representatives from E roject team.

2.2.227 Local councillors and representatives from key local stakeholder groups attended the workshops, which wer 20:30 on weekday evenings. To ensure there was capacity for everyone interested, EDF Energy asked that each organisation only send rkshop. However, in some cases organisations sent more than one representative and this is marked in brackets in Table 2.20 below.

Table 2.20: Groups/Org at Stage 2 Stakeholder Workshops

Summary – of the key issues raised during the workshop.

S

At Stage 2, EDF

strategy for this stage.

The workshops we held

DF Energy and the HPC P

e held from 18:30 to

one representative to the wo

anisations Represented

Workshop Attendees

Vale of Glamorgan Council

Penarth Town Council

Vale of Glamorgan

(9 September 2010)

Association of Severn Estuary Relevant Authorities

Butlins

CBI

Forum 21

Minehead Chamber of Trade

Minehead Hotels Association

Minehead Town Council

RAC Foundation

Somerset Chamber of Commerce


West Somerset College

Minehead

(13 September 2010)





Workshop Attendees

West Somerset Group Ramblers Association

West Somerset Ramblers

Avon and Somerset Constabulary

Bishops Lydeard Parish Council

Business Link

Devon County Council

High Sheriff of Somerset

Hinkley Point Retired Employees Association

Sedgemoor District Council (2)


Somerset Education Business Partnership (2)

South Gloucestershire Council

South Somerset District Council

Taunton Deane Borough Council (2)

Taunton

(14 September 2010)


Arup

Avon and Somerset Police (2)

Cheddar Parish Council

Environmental Network, North Somerset (2)

Locking Parish Council

North Somerset Council

South West NHS

Weston-super-Mare

(15 September 2010)

Weston College

Avon and Somerset Police (4)

Bridgwater Bay Wildfowl Association

Bridgwater Ladies Luncheon Club

Bridgwater Town Council

Bridgwater Without Parish Council

Bristol City Council

Hotel Lead for the West of Somerset


Somerset Community Health


Bridgwater

(16 September 2010)

Somerset Racial Equality Council

Residents from Withiel Drive, Chads Hill, Cannington High Street and Putnell Cottages

Save Cannington Action Group

Brymore School

Cannington (bypass)

27 September 2010

Cannington Parish Council




2.2.228 The agenda for each workshop was broadly as follows:

Introduction – the workshop process and timetable and introduced members of

Presentation – a presentation was given of EDF Energy’s Preferred Proposals for opments.

, three of whom were students from Brymore School.

2.2.232

were also taken to ensure the consultation process was accessible to those with disabilities, people whose first

2.2.233 id South West on the SoCC helped to inform the strategy for engaging

with hard-to-reach groups and assisted with the identification of such groups.

2.2.234 ement with hard-to-

reach groups.

2.2.235

the HPC Project team.

HPC and associated devel

Workshop groups – attendees were divided into groups to discuss: economy and community; transport and accommodation; and site-specific issues.

Workshop groups – feedback and discussion.

Summary – the facilitator summarised the key issues raised during the workshop.

2.2.229 An additional (Cannington bypass specific) workshop was held on 27 September 2010 for representatives of local community groups and residents most likely to be affected by the bypass proposals. The workshop was attended by 48 people

2.2.230 The Cannington bypass workshop followed a similar format to the previous workshops, with the exception that this workshop group focused solely on the bypass and potential issues and solutions.

2.2.231 Feedback from these workshops is summarised in Chapter 3 of this report.

f) Hard-to-Reach Groups

EDF Energy has sought to engage with hard-to-reach groups in affected communities and has liaised with the Somerset local authorities to help identify relevant groups and their representatives. Steps

language is not English, and those who had difficulty attending consultation events.

The process of consulting, both formally and informally, with the local authorities and Planning A

Pre-Stage 1

Initial discussions with the local authorities and Planning Aid South West about the first draft SoCC helped to identify opportunities for early engag

As a result, before the official consultation period began, EDF Energy met with Sydenham Neighbourhood Planning Group (19 October 2009), which represents one of the most deprived wards in Somerset and is located in Bridgwater, to discuss its proposals for HPC. Two representatives from Planning Aid South West, three members of the Planning Group and a Somerset County councillor (who was also a Bridgwater Town councillor) attended the meeting.




2.2.236 A presentation was given covering the future consultation in the local area and the Community Energy Saving Programme. The Sydenham Neighbourhood Planning Group posed questions and raised points about EDF Energy’s ‘Initial Proposals and Options’.

Stage 1

2.2.237 EDF Energy took a strategic decision that it would not hold specific consultation events for hard-to-reach groups during Stage 1 consultation on its ‘Initial Proposals and Options’ between 16 November 2009 and 18 January 2010.

2.2.238 gthy

o hold groups during Stage 2 of the consultation, when the

plans were sufficiently well advanced. It was felt this would make the most of the en

2.2.239 EDF Energy and its representatives did, however, meet with Sedgemoor District Council and Homes for Sedgemoor on 30 November 2009 to discuss engagement with hard-to-reach groups during the pre-application consultation process. This

2.2.240 consultation through:

nd s to suit different peoples’ availabilities.

document on the proposals and making

2.2.241 EDF Energy held a series of meetings and events designed to improve engagement with hard-to-reach groups within communities affected by the

of lanning Aid South West, whilst

others resulted from approaches made to or by EDF Energy. The key events were:

This decision was taken because it was felt they would be unlikely to engagecontinuously in a series of events held at different stages throughout a lenconsultation process. EDF Energy concluded that it would be preferable tspecific events for hard-to-reach

limited opportunities for engagement, rather than during Stage 1 consultation whonly preliminary proposals and options were available. The SoCC was published in November 2009, and explained EDF Energy’s intention to hold focus groups with hard-to-reach groups during the Stage 2 consultation.

meeting agreed that EDF Energy would work with Homes for Sedgemoor on engagement in deprived areas of Bridgwater and identified the Federation of Equality and Diversity in Somerset (FEDS) as a group that should be engaged.

Efforts were made to facilitate engagement by hard-to-reach groups in the Stage 1

Encouraging attendance at public exhibitions by holding them during the day ain the evening as well as at weekend

Inviting representatives of hard-to-reach groups to attend meetings of EDF Energy’s Community Forum.

Providing full information about the consultation on the HPC Project website.

Preparing a clear, non-technical summary it available in public libraries, council offices and tourist information centres.

Providing a telephone information line and Freepost service.

Pre-Stage 2

During this period

development of HPC. Several of these meetings and events arose directly outinformal discussions with the local authorities and P




Meeting with the FEDS on 13 January 2010 to discuss engagement with hard-treach groups – a representative of FEDS was subsequently invited to attend meetings of the Community Forum.

o-

and governors of Brymore School in

porting activities might be included in EDF Energy’s

engagement with hard-to-reach groups at the EDF Energy HPC

r n Trust and the Smallpeice Trust to discuss how the two organisations

discuss how EDF

Meetings with the Somerset Racial Equality Council (SREC) on 28 April and 18 May 2010 to discuss how EDF Energy could engage effectively with ethnic

ommunity Forum, to provide an interpretation and translation service and to help facilitate a focus group on the

-to-reach

dents at Bridgwater College to

denham Tenants’ and Residents’ Association on 6 July 2010

2.2.242 EDF Energy’s plans for engagement with hard-to-reach groups in the Stage 2 consultation period.

Meeting with the South West Regional Employment and Skills Partnership on 26 January 2010 to discuss skill needs for the HPC Project.

Meeting on 27 January 2010 with the staff Cannington to discuss their concerns.

Meeting with Somerset Leisure Ltd on 27 January 2010 to discuss how health and well-being, physical and sfuture plans.

Presentation to the Board of the Somerset College of Arts and Technology in Taunton on 5 February 2010 to discuss EDF Energy’s skill requirements for the HPC Project.

Discussion onCommunity Forum meeting on 25 February 2010.

Meeting facilitated by EDF Energy on 22 March 2010 between the BridgwateEducatiocould work together for mutual benefit.

Meeting with Jobcentre Plus in Bridgwater on 26 March 2010 to Energy could support the ‘Backing Young Britain’ initiative and other similar campaigns.

EDF Energy attendance at an event for workless young people held in Bridgwater on 6 April 2010 organised by Homes in Sedgemoor, Sedgemoor District Council and Jobcentre Plus.

minority groups in Bridgwater and other areas of Somerset. As a result of these meetings, SREC was invited to join the C

HPC Project.

Meeting with the Corporate Research and Consultation Manager at Somerset County Council on 19 May 2010 to discuss engagement with hardgroups.

Workshop held on 23 June 2010 with mature stuconsider the impacts and potential benefits of the HPC Project.

Meeting with the Syto discuss the HPC Project.

These meetings helped to refine and target




Stage 2

2.2.243 The Stage 2 consultation programme as a whole was enhanced further to facilitate

ation of the Preferred Proposals Summary document into Bengali, Chinese, Polish and Portuguese. EDF Energy was advised by the SREC

Making provision for other summary consultation material to be translated and

ition venues and opening times were accessible to all sections of the community.

newsletters and on the project website.

ach groups were invited to attend EDF Energy’s Community Forum meetings, specifically groups representing the

2.2.244 During the Stage 2 consultation process, EDF Energy also took specific steps to

Intending to exhibit at the Disability Somerset exhibition on 17 September 2010,

visitors through the existing network of tourist information offices.

2.2.245

Bridgwater Summer Fair (18 July 2010) and Bridgwater Fair (1 October 2010) and positively encouraged suggestions through the Community Forum

engagement with hard-to-reach groups by:

Providing for transl

that these were the minority languages most used in the county.

made available in large print format on request.

Ensuring the exhib

Home visits by EDF Energy staff, particularly for those with limited mobility who were directly affected by the proposals. This service was advertised in the

Ensuring representatives of hard-to-re

disabled, ethnic minorities and faith groups.

engage with hard-to-reach groups by:

Holding exhibitions targeting women, younger people and visitors to the area in supermarket car parks in Bridgwater, Minehead and Burnham-on-Sea during the summer holidays.

however, this event was cancelled by the organisers.

Holding focus groups targeted at members of the SREC, job seekers, tourist accommodation providers and working parents between the ages of 25 and 45 (see Chapter 3).

Undertaking a survey of tourists in Minehead over two days in the summer holidays to gain a better understanding of their knowledge of the proposals and whether these would impact on future holidays in the area (see Chapter 3).

Ensuring the public exhibitions were advertised to

Inviting representatives of local faith groups to attend meetings of EDF Energy’s nuclear new build Community Forum.

EDF Energy also committed to participating in other events organised locally that would assist engagement with hard-to-reach groups (for example Nether Stowey Fair (1 May 2010),

and in other meetings with community stakeholders.




Stage 2 Update

2.2.246 The scope of the Stage 2 Update consultation was limited to material changes to the w that

ents for hard-to-reach groups during the Stage 2

2.2.247 ommunity and the public who responded to the Stage 1 and 2 consultations, including representatives of hard-to-reach groups, were

2.2.248 consultation document were also translated into Bengali, Chinese, Polish and Portuguese and made available to download from the HPC

t for the visually impaired and home visits offered to those with mobility issues as during the Stage 2

2.2.249 Additio -to-reach groups in e Stage tion inc

s by holding these in the evening and well a y;

each groups to attend meetings of EDF

making the consultation document available in public libraries, council offices and

providing a Freephone information line and Freepost service.

2.2.250 DF Energy ople

Stage 2 ‘Preferred Proposals’. As a result, EDF Energy took the strategic vieholding specific consultation evUpdate consultation would be disproportionate, as EDF Energy was not seeking to re-consult on the HPC Project as a whole.

Instead, all members of the local c

notified directly of the Stage 2 Update consultation.

Key sections of the

Project website. A translation and interpretation service was available if required and advertised through the newsletter and on the HPC Project website. A large print version of the consultation document was also available on reques

consultation.

nal efforts made to facilitate 2 Update consulta

engagement by hardluded:

th

encouraging attendance at public exhibitionat weekends as s during the working da

inviting representatives of hard-to-rEnergy’s Community Forum;

providing full information about the consultation on the project website;

tourist information centres; and

i. Focus Groups

As part of its commitment to consult with hard-to-reach groups, Eundertook focus groups at Stage 2 to ensure the views of specific groups of pewere ascertained at the preferred proposals stage (see Table 2.21).

Table 2.21: Groups/Organisations Represented at Focus Groups

Date Focus Group Attendance

20 September 2010 Black, minority and ethnic groups in Somerset

15

21 September 2010 Working parents 14

23 September 2010 Accommodation providers 18

28 September 2010 Job seekers 4




2.2.251 held in Cannington and Bridgwater from 18:00 to 20:00, with the exception of the job seekers’ focus group, which was held from 13:00 to

2.2.252 ways:

black, minority and ethnic groups in Somerset were recruited through Somerset

job seekers were recruited through notices in Jobcentre Plus branches in Somerset.

2.2.253

2.2.254

e 1

2.2.256 West Somerset Community College and Danesfield

2.2.257 EDF Ene ave a presentation and then divided attendees into discussion groups. As at the Bridgwater College workshop in 2009, students were

All the focus groups were

15:00.

The focus groups were recruited in the following

Racial Equality Council;

working parents were recruited through a market research company:

accommodation providers were recruited through EDF Energy’s database of potential accommodation providers in the area, which included hotels and bed and breakfasts; and

The focus groups lasted approximately two hours and after attendees had been given a brief overview of the proposals they were invited to discuss the potential impacts and benefits of HPC and its associated developments.

ii. Youth Engagement

As part of EDF Energy’s commitment to consult with future generations living and working in the area around HPC and the associated developments, EDF Energy held a number of youth focused consultation events.

Pre-Stag

2.2.255 EDF Energy held a workshop at Bridgwater College on its initial proposals on 20 October 2009. Forty-four college students attended this event. A presentation was given by EDF Energy to explain the proposals for nuclear new build at Hinkley Point. The students were then divided into groups and given maps, Post-it notes, flipchart paper and pens to record their views. A spokesperson from each group presented back their key findings to the other groups for further discussion.

Pre-Stage 2

EDF Energy held a workshop in Minehead on 23 March 2010 attended by approximately 25 students fromSchool, at which the possible impacts and benefits on younger people of the development of a new nuclear power station at Hinkley Point were considered.

rgy representatives g

then divided into groups and given maps, post-it notes, flipchart paper and pens to record their views. A spokesperson from each group then presented back their key findings to the other groups for further discussion.




Stage 2

EDF Energy held exhibitions in supermarket car parks in Bridgwater, Minehead and Burnham-on-Sea during the summer holidays of 2010 to make the consultation as accessible as possible to younger people in the area. Further engagement with local schools took place at the beginning of the academic year 2010/

2.2.258

2011. EDF Energy wrote to King Alfred School (Highbridge); West Somerset Community College (Minehea e Community College (Bridgwater); East Bridgwater Community School (Bridgwater); Haygrove School (Bridgwater); Chilton Trinity

2.2.259

Pre-Stage 2 Update

2.2.260 During this period Robert Blake Science School in Bridgwater responded to the

ensure that young people are included in decision-making that affects their local community.

ger people in the Minehead area. This work is described in the following sections.

Advisors was conducted at West 25 March 2011. The scope of the

Project in general rather than the material changes date consultation. The Young Advisors organised and

2.2.262

consultation focused on five key themes: Housing, Transport, Employment, Social Integration and Legacy. The team devised a range of methods to gather the views of young people, using interactive participatory exercises conducted by the Young Advisors and designed to engage students quickly.

d); Robert Blak

Technology College (Bridgwater); Danesfield Church of England School (Williton) and Brymore School (Cannington) inviting them to make educational visits to EDF Energy’s Bridgwater office.

The Robert Blake Community College took up this offer in November 2010 (see section below).

invitation to undertake an educational visit to EDF Energy’s Bridgwater office. A workshop for 12 students aged between 13 and 14 was held on 19 November 2010 to consider the HPC Project. Following presentations from the EDF Energy team, the students discussed a wide range of issues relating to the HPC Project. EDF Energy was also informed at this time by Somerset County Council of the Minehead Young Advisors (part of the Young Advisors, a national charity), whose purpose is to

An initial meeting was held on 16 February 2011 with a representative of the Minehead Young Advisors, following which EDF Energy commissioned the group to undertake consultation on its plans for the HPC Project with youn

Stage 2 Update

2.2.261 The initial fieldwork by the Minehead YoungSomerset Community College between 17 andconsultation was the HPC proposed in the Stage 2 Upran a consultation on the plans for HPC with students at the college. The consultation involved assemblies, focus groups, open sessions and a plenary event on 25 March 2011 that was attended by representatives of EDF Energy.


Due to the success of the Minehead Young Advisors’ consultation above, a similar consultation was commissioned with young people in the Bridgwater area in June 2011. The




2.2.263 These included: ‘knowledge pong’, dressing-up boxes, a ‘buckets and balls’ exercise, optical illusions, large-scale maps and a money box exercise. Some limited information was also provided to students about the development.

2.2.264 The Young Advisors’ reports and recommendations were sent to EDF Energy in April

2.3

2.3.1 Statutory consultees and other relevant stakeholders were consulted by EDF Energy

2.3.2 In addition to this formal statutory consultation, many of these statutory consultees consulted on an informal basis in

e

2.3.3 section 42 of the Act is provided in Appendix

2.3.4 ry als in order to receive technical input and information

at an early stage. This was built upon during the Stage 2, Stage 2 Update and ments consultations.

police authority.

se se

2011 and July 2011 (see Chapter 4 and Appendix C).

Consultation with Statutory Consultees1

a) Scope of Consultation

on its proposals for the HPC Project during all stages of formal consultation, asrequired by the Act and supplementary regulations and guidance.

and other relevant stakeholders were additionally the form of liaison meetings, forums and more focussed topic based discussions (seChapter 4).

A list of all consultees consulted underG.

i. Statutory Consultees

Stage 1 consultation offered the opportunity for engagement with statutoconsultees on the initial propos

Junction 24 and Highways Improve

2.3.5 For these consultations, statutory consultees have been defined as:

Those relevant prescribed bodies in Schedule 1 of the APR Regulations such as the Environment Agency, Natural England, the relevant parish council and the relevant

The Marine Management Organisation (MMO).

Each relevant local authority defined as the county and district council in whoarea the application land is situated and any county and district councils whoboundaries adjoin those councils.

Each person who is an owner, lessee, tenant or occupier of land, persons with an interest in the land or with the power to sell/convey or release it, and persons who would or might be entitled to make a claim under section 10 of the Compulsory Purchase Act 1965 or Part 1 of the Land Compensation Act 1973 – hereafter

1 Note – covers landowners




referred to collectively as ‘landowners and significantly affected persons’ for the purposes of this report.

ii. Other Relevant Stakeholders

2.3.6 Guidance published by the Department for Communities and Local Government in

2.3.7 make an important contribution to the development of its proposals

for the HPC Project, which included bodies specific to the nuclear industry. These ere consulted during all formal stages of consultation

and were adapted at each stage of consultation in order to generally encompass a

e amendments at each stage explained in the sections below.

2.3.8 In particular, in addition to consulting with the local authorities specified in the legislation, EDF Energy also consulted with Bristol City Council, South

2.3.9

cils to the extent that they were not already prescribed statutory consultees. These were identified partly due to their proximity to the HPC and associated development sites,

b) Consultation Approach

September 2009 entitled 'Planning Act 2008 – Guidance on pre-application consultation' (CLG’s Pre-application Guidance) sets out the circumstances in which it might be appropriate to consult more widely than with the bodies specified in the legislation:

“For each sector there are a range of bodies in addition to those specified either on the face of the Act or in secondary legislation that may also be able to make an important contribution. These will include national and regional stakeholders. Promoters are therefore encouraged to consult widely on proposals.”

EDF Energy therefore also consulted with other relevant stakeholders who it believed might be able to

other relevant stakeholders w

wider group of bodies as the detailed proposals were developed. The full list of statutory consultees and other relevant stakeholders consulted is contained in Appendix G, with th

Gloucestershire Council and the Vale of Glamorgan Council who, although they do not share a boundary with a local authority in which the application land is situated, may be indirectly affected by the proposals due to their geographical location.

Other relevant stakeholders with whom EDF Energy consulted included Government bodies, local interest groups, business organisations and environmental groups. EDF Energy also consulted with additional relevant town and parish coun

from expressions of interest from the councils, and at the request of Sedgemoor District and West Somerset councils. It should be noted that there is difficulty in separating out the consultation undertaken with the town and parish councils under section 42 of the Act from local community consultation carried out under section 47 of the Act. Therefore, although their roles as statutory consultees and other relevant stakeholders under section 42 is fully acknowledged and taken into account, details of consultation undertaken with them are described in the Local Community section of this chapter.

2.3.10 At each stage of formal consultation there was a different level of information and approach for statutory consultees, as EDF Energy developed its proposals and took on board feedback.




Stage 1

The pro2.3.11 posals set out in the Stage 1 Consultation Document fell into two broad categories: first, those elements which were already preferred and likely to remain un clear po hange as e to co and co

2.3.12 Th osals fo et the needs of different stakeholders consulted. ultation had the advantage of

2.3.13 EDF Energy, which resulted in a

further an

pplication

2.3.15

s of the consultation strategy were maintained.

rstanding of the way the preferred proposals were progressing.

changed, for example the reactor design and the location of the proposed nuwer station; and, secondly, those which were more likely to be subject to c a result of ongoing technical and environmental studies, and in responsnsultation. In the latter category, options for development were presentednsultees were encouraged to make particular comment on these areas.

Stage 2

e Stage 2 Consultation Documentation set out EDF Energy’s preferred propr the HPC Project in a wide-ranging set of reports and plans designed to me

This conssignificantly higher levels of information being available as a result of ongoing technical and environmental studies. In addition, feedback from consultees was instrumental in enabling EDF Energy to amend and produce preferred proposals, particularly in relation to those options presented at Stage 1, which had been likely to be subject to change.

Stage 2 Update

As a result of feedback and further studies, certain material changes to the Stage 2 ‘Preferred Proposals’ were considered necessary by

d more focused Stage 2 Update consultation.

2.3.14 EDF Energy’s approach to consultation on significant changes made after and as a result of Stage 2 is based on paragraph 78 of CLG's Pre-application Guidance, which states:

“It may be necessary from time to time for a promoter to proceed with project options significantly different from those consulted on (for example because new information arises which renders all previous options unworkable or invalid for some reason). Where a proposed achanges to such a degree that the legitimacy of the consultation may be in question, promoters should consult the community again on the new options. In such circumstances promoters should supply consultees with sufficient information to enable them to fully understand the nature of the change (but not necessarily the full suite of consultation documents), and allow at least 28 days for consultees to respond.”

EDF Energy did not believe that it was either necessary or appropriate to re-consult on the HPC Project as a whole, as only certain elements of the proposals presented at Stage 2 were changed. However, EDF Energy still wished to ensure that consultees had an opportunity to provide feedback on these matters in a way thatensured that the principle

2.3.16 In addition, draft strategy documents were provided to help give consultees greater context when considering the proposals at Stage 2 Update and an unde





de as a result of the potential site becoming available and further transport studies being undertaken following the Stage 2 Update

2.3.18 resented at the Stage 2 and Stage 2 Update consultations, EDF Energy

considered it necessary to conduct additional consultation with a limited focus.

2.3.19 ll prescribed consultees and MMO, local authorities and landowners and

. were

on.

2.3.20 statutory consultees and other relevant

2.3.21 ent (EDF Energy, November

detail to ensure that consultees could provide their assessment of likely impacts.

2.3.22 osals and Options’ for both the HPC Development Site and the associated development sites. Additionally, the Environmental Status Report (in its Appendix A.1) provided preliminary

ower station;

the decommissioning activities for the nuclear power station;

2.3.17 A further limited stage of consultation was subsequently carried out in respect of EDF Energy’s proposal to include a potential new alternative site for the proposed park and ride facility at Junction 24 and further highway improvements in the Bridgwater area. These changes were ma

consultation. This provided an opportunity for EDF Energy to respond to feedback received on these issues at earlier stages of consultation.

As EDF Energy considered these changes represented a material change to the proposals p

As at Stage 2 Update, EDF Energy consulted with aother relevant stakeholders, the significantly affected persons in respect of the land subject to the proposed changes, as well as with all other parties who had previously responded to consultationAlthough comments were accepted on the wider Project, consultees encouraged to provide comment on the specific areas covered in this consultati

c) Consultation Tools

The consultation material provided to stakeholders took into account the criteria outlined in relevant guidance.

Stage 1

The Stage 1 ‘Initial Proposals and Options’ docum2009), referred to as the Stage 1 Consultation Document, aimed to provide an outlineof the initial proposals in sufficient

The Stage 1 Consultation Document presented the ‘Initial Prop

environmental information. The Stage 1 Consultation Document outlined the following:

the pre-application consultation process;

the need for new nuclear power;

the suitability of the HPC site for a power station and its physical characteristics;

land use and activities during the construction of the nuclear p

the regulatory regime for the nuclear power station;

the waste management and spent fuel arrangements for the nuclear power station;




the need for, and outline description of, development required off-site to support the development of the nuclear power station;

information on EDF Energy’s approach to sustainability, community benefits and

nt t.

2.3.23

ument, consisting of approximately 8,000 pages

2.3.24 Documentation presented the

2.3.25 d

als and Options’ and the subsequent changes made to

2.3.26 on all of the areas covered above. In

rmal and informal consultation process to date and an outline of the

masterplans explaining the design process and justifying the principles and concepts that have been applied to the HPC Project, building on the principles

mental impacts including

s;

ansport demand of the HPC

risk for the HPC Project;

compulsory purchase; and

a report on the current status of EDF Energy’s environmental impact assessmefor the nuclear power station and associated developmen

Stage 2

The Stage 2 ‘Preferred Proposals’ documentation (EDF Energy, July 2010), referredto as the Stage 2 Consultation Documentation, was significantly more detailed than the Stage 1 Consultation Doccompared to 400 at the previous stage.

Following the initial stage, the Stage 2 Consultation‘Preferred Proposals’ for both the HPC Development Site and the associated development sites. An Environmental Appraisal was also provided setting out the understanding at that stage of the likely environmental impacts.

Additionally, an interim consultation report on the Stage 1 consultation was providewhich summarised EDF Energy’s response (at that stage) to comments received regarding the ‘Initial Proposthe proposals as a result.

The Stage 2 Consultation Documentation built on the earlier Stage 1 Consultation Document, providing more detailed information particular new information was provided on the following:

the fofeedback received, along with EDF Energy’s response, as a result of Stage 1;

the context and rationale for the proposed HPC Project;

outlined in the Stage 1 Consultation Document, in particular in the Environmental Status Report;

a comprehensive document setting out potential environEDF Energy’s understanding at that stage of the impact on relevant designated habitats, and any mitigation measures envisaged;

a transport appraisal setting out the issues arising from construction and operation of the HPC Project, and specifically addressing sustainable accessibility, management of residual trips, and mitigation measure

an overarching management plan dealing with the trProject;

reports on potential sources of flood




an evaluation of the HPC Project’s sustainability, involving the balancing of social,

d proposed mitigation measures;

ns to mitigate adverse impacts and maximise benefits from the HPC Project.

2.3.27

ocument, due to its focused nature, was a succinct document supported by six draft strategy documents on the

ight truction; Overview of Associated

2.3.29

workforce, employment and skills;

cal and regional economy would be helped;

e impacts and benefits to the community;

rticularly in regard to early restoration of the southern area and a fish recovery and return system.

n

starting date for operation of the park and ride and freight distribution, and increased capacity; and

economic and environmental objectives;

an appraisal of the potential health effects, both positive and negative, of the HPC Project on the population, the extent of these, anand

early proposals for planning requirements and development consent obligatio

Stage 2 Update

The Stage 2 ‘Update on and Proposed Changes to Preferred Proposals’ document (EDF Energy, February 2011), referred to as the Stage 2 Update Consultation Document, supplemented the earlier Stage 2 consultation.

2.3.28 The Stage 2 Update Consultation D

Accommodation; Construction Phase Waste Management Strategy; FreManagement Strategy; Overview of HPC ConsDevelopment Construction; and Workforce Profile Plan.

This consultation specifically focused on the following:

how the lo

proposals connected to th

updated proposals on construction working hours;

further clarification on transport proposals; and

amendments to the HPC Development Site proposals, pa

Junction 24 and Highways Improvements Consultatio

2.3.30 The Junction 24 and Highways Improvements Consultation Document (EDF Energy, July 2011) was targeted at relevant communities, statutory consultees and other relevant stakeholders, focusing on the proposed potential new site for a park and ride facility at Junction 24 and further highway improvements in the Bridgwater area.

2.3.31 The document covered the following:

information about the alternative park and ride site at Junction 24 and further highway improvements in the Bridgwater area;

preliminary environmental information on the proposed new development;




temporary siting of an induction centre for workers and premises for courier facilities.

2.3.32 Consultation with statutory consultees and other relevant stakeholders took place via

d) Consultation Methods

directly mailed hard copy and CD/DVD versions of the main consultation documentation, with availability of all documents plus draft strategy documents on the consultation website www.edfenergyconsultation.info.

At each stage, following requests and feedback from consultees, this direct mailing was updated to provide optimum accessibility for consultees.

2.3.33

2.3.34 Where ‘return to sender’ copies were received, an attempt to find an alternative

endix G).

d until after the start dates. These consultees consisted of landowners and significantly affected persons who were provided with the material

2.3.36 The Stage 1 consultation was the initial consultation with statutory consultees and other relevant stakeholders. Feedback was encouraged on the material presented in the Stage 1 Consultation Document.

2.

lly to inform them of the consultation process. A number of landowners and significantly affected persons were also consulted

.

a number of copies on CD were made available on request.

2.3.39

2.3.40 n appropriate covering letter setting out the avenues for providing feedback and obtaining further information if

address was made and a copy of the consultation material, whether in hard copy or DVD form, provided where possible. In some cases it was not possible to identify an alternative contact (see App

2.3.35 EDF Energy made every effort to identify all consultees in advance of each stage in order to send them the consultation materials, but nevertheless a handful of consultees were not identifie

some weeks later. In these instances EDF Energy ensured that the consultees had adequate time to respond, and feedback received was fully considered.

Stage 1

3.37 Statutory consultees included landowners and significantly affected persons as stated above. Prior to the commencement of the Stage 1 consultation, all landowners and significantly affected persons highlighted within the search areas were identified and contacted individua

informally to explore possible option sites in order to begin to investigate the issues and options surrounding them

2.3.38 Hard copies of the Stage 1 Consultation Document were sent to over 450 statutory consultees and other relevant stakeholders, and

On request, Somerset County, Sedgemoor District and West Somerset Councils all received multiple additional hard copies of the consultation documents for distribution through their organisations.

The Consultation Document was accompanied by a

required. Electronic access to all Stage 1 consultation material, as well as further




information on the Stage 1 consultation, was also provided for all consultees through the consultation website: www.edfconsultation.info.

Stage 2

2.3.41 The Stage 2 Consultation Documentation consisted of a suite of documents in order

2.3.42

2.3.43 All statutory consultees and relevant stakeholders were provided with a DVD

2.3.44 Due to its size, and in the interests of sustainability, only a limited number of nty nt

eir

2.3.45 e e

addition to the summaries, identified

2.3.46 ons, but who due to the changing proposals no longer fell

into this category of consultee, were also sent an appropriate covering letter in

the Stage 2 consultation material in the manner described above. The number of statutory

Recommendations from other consultees on other bodies, particularly other local

butors, docks etc. deemed necessary by EDF Energy for its own consultation purposes.

to explain fully the more detailed proposals and, as a result, was significantly longer and more detailed than the previous stage. A navigation document was provided in order to explain the purpose and content of each document and guide the consultees to the different parts of the proposals.

As at Stage 1, all consultees received the consultation material under cover of an appropriate covering letter.

containing all of the Stage 2 consultation material.

consultees received full hard copy sets of the documentation – Somerset CouCouncil, West Somerset Council, Sedgemoor District Council, the EnvironmeAgency and Natural England. On request, these consultees also received multiple additional hard copies of many of the key documents for distribution through thorganisations as well as additional copies of the DVD.

The remaining statutory consultees and other relevant stakeholders (excluding landowners and significantly affected persons) were sent hard copies of thsummaries of the proposals, the Stage 1 Interim Consultation Report, and thExplanation and Assessment document. Inlandowners and significantly affected persons were also sent, where relevant, anapplicable red line plan and appropriate covering letter depending on whether theyhad been contacted in the previous stage of consultation.

Those organisations and individuals previously identified as landowners andsignificantly affected pers

explanation together with the Stage 2 Consultation Documentation. Approximately 800 statutory consultees and other relevant stakeholders were sent

consultees and other relevant stakeholders was increased at this stage for thefollowing reasons:

groups, which would be useful to consult.

Following the IPC’s own consultation in relation to EDF Energy’s request for a scoping opinion from the IPC, made in January 2010, discussions with the IPC resulted in the inclusion of additional consultees, particularly statutory undertakers such as public gas transports, other electricity distri




Although EDF Energy was satisfied that in the previous stage that it had consulted all statutory local authority consultees, an expanded parish council list was included to cover all those in Sedgemoor and West Somerset council areas, on advice received from the district councils.

The number of landowner and significantly affected consultees was increased as a result of consulting those parties that would or might, if the DCO were to be made and fully implemented, be entitled to make a claim under section 10 of the Compulsory Purchase Act 1965 or Part 1 of the Land Compensation Act 1973 and to include parties who contacted EDF Energy to discuss the proposals during the Stage 1 consultation.

Where new areas of land were included in the proposals, the new landowners and significantly affected persons were included in the list of consultees.

2.3.47 Electronic access was given to the full suite of documents and further information on the Stage 2 consultation through the consultation website www.edfconsultation.info.

Stage 2 Update

2.3.48 As an update to the Stage 2 consultation, the Stage 2 Update Consultation Document was significantly smaller at 53 pages and reflected the focused nature of this consultation. This document was mailed directly to the approximately 810 statutory consultees and other relevant stakeholders for their comment along with a CD containing an electronic version of the document.

2.3.49 opies of the consultation document were provided to

earlier consultation stages. Those

On request, multiple hard cSomerset County Council, Sedgemoor District Council, West Somerset Council, the Environment Agency and Natural England.

2.3.50 The identified landowners and significantly affected persons were also sent the relevant red line plans to accompany the main consultation document along with an appropriate covering letter depending on their interest in the land and whether or not they had previously been involved in organisations and individuals previously identified as landowners and significantly affected persons but who, due to the changing proposals, no longer fell into this category of consultee were also sent an appropriate covering letter in explanation together with the consultation document. The six draft strategy documents were made available on the consultation website www.edfenergyconsultation.info, along with the main consultation document.

As at earlier stages of consultation, all consultees received the consultation material 2.3.51

n 24 and Highways Improvements Consultation

2.3.52 f 12 pages, was mailed out directly to

under cover of an appropriate covering letter.

Junctio

The consultation document, which consisted oapproximately 570 statutory consultees and other relevant stakeholders. This figure was smaller than at previous stages of consultation for the following reasons:




This consultation covered a smaller number of proposals and changes than previous consultations.

As a result, fewer landowners and significantly affected persons were affected by the proposals outlined in this consultation.

2.3.53 Somerset County Council, Sedgemoor District Council, West Somerset Council, the

2.3.54 were also sent the relevant land plans

together with the consultation document.

2.3.56 period of consultation of 28 days. However, EDF r those stages of consultation

2.3.57 The Stage 1 consultation period ran from 16 November 2009 to 18 January 2010 to

2.3.58 The Stage 2 consultation was held over an increased period of three months due to it r 2010.

2.3.59 The Stage 2 Update consultation, due to its limited size, was consulted on for 32

2.3.60 consultation, as the smallest scale consultation, took place for statutory consultees and other relevant stakeholders for

d until 12 August for the local community and

2.3.61 er relevant stakeholders, which were

On request, multiple hard copies of the consultation document were provided to

Environment Agency and Natural England.

Landowners and significantly affected persons to accompany the main consultation document, along with an appropriate covering letter depending on their interest in the land and whether or not they had previously been involved in earlier consultation stages. Those organisations and individuals previously identified as landowners and significantly affected persons, but who due to the changing proposals no longer fell into this category of consultee were also sent an appropriate covering letter in explanation

2.3.55 Again, all consultees received the consultation material under cover of an appropriate covering letter.

e) Consultation Time Period – Each Stage

The Act requires a minimumEnergy felt it was important to provide additional time fothat covered the full Project proposals due to the length of the consultation material provided at those stages.

provide sufficient time for all consultees to consider the outlined proposals andopenly engage with EDF Energy. This also included an additional seven days toallow for the inclement weather during this period.

taking place, in part, over the summer holiday period, from 9 July to 4 Octobe

days, from 25 February to 28 March 2011.

The Junction 24 and Highways Improvements

29 days from 1 to 29 July 2011 (anmembers of the public, which included a period from 1 to 14 July of informal local community consultation).

Despite the deadlines to the consultation periods, EDF Energy accepted late responses from statutory consultees and othtreated in the same way as responses received within the deadlines.




f) Methods of Responding to Consultations and Taking Account of Responses

i. Feedback Mechanisms

2.3.62 A number of feedback mechanisms were put in place for all stages to provide a transparent and coherent approach to pre-application consultation. Responses and queries could be made through the following means:

a dedicated email address, [email protected] – updated at Stage 2 to include the additional address: [email protected];

2.3.63

via the Freepost address (FREEPOST CONSULTATION RESPONSE); and

by hand to the EDF Energy Project Office in Bridgwater (14 King Square, Bridgwater, Somerset TA6 3DG).

Further information could also be obtained via the dedicated website, www.edfconsultation.info (updated to www.edfenergyconsultation.info at Stage 2

2.3.64

ed and taken into stages of consultation and the final DCO proposals.

2.3.67 consultation and EDF Energy responses are provided in Chapter 3. More detailed responses in direct correlation

2.3.68 lined above, informal engagement has taken place with statutory consultees and other relevant stakeholders from an

nd EDF Energy have shared information and views, with EDF Energy taking on board the feedback as it has continued to

2.3.69 provide some feedback to consultees, the Stage 1 Consultation Report was distributed to statutory consultees and other relevant stakeholders as part of the

Update) and freephone number 0800 169 6507.

ii. Taking Account of Responses

The Act imposes a duty on a promoter of a nationally significant infrastructure project, when formulating its application to the IPC, to ‘have regard to any relevant responses’ (section 49(2)) received to consultation or publicity under sections 42, 47 or 48 of the Act within the specified deadlines.

2.3.65 Responses received from each stage have been carefully consideraccount in producing further

2.3.66 The main route to demonstrate how EDF Energy has taken account of the feedback received from consultees, as well as to feed back in turn EDF Energy’s responses to the issues raised in this report, as required by the Act and consequent IPC guidance.

High-level summaries of the issues raised from

to the comments received at all stages are presented in Appendix H. Chapter 5 explains in more detail how EDF Energy has responded to the consultation comments and how consultees can view the EDF Energy responses to these comments.

In addition to the formal statutory consultation out

early stage up to the submission of the application to the IPC. This has consisted of a two-way process whereby consultees a

develop the proposals. For further information about this see Chapter 4.

In order to

Stage 2 Consultation Documentation (see Appendix B). As explained above, this




report summarised EDF Energy’s response at that stage to comments received regarding the ‘Initial Proposals and Options’ consultation and the subsequent changes made to the proposals as a result. The report specifically covered those issues raised by statutory consultees and other relevant stakeholders, as well as

2.4

2.4.1 ct provides for the IPC and the Secretary of State to issue guidance on pre-application consultation, which must be taken into account by the

comply with the requirements of section 37(3) of the Act (including the preparation of a consultation report).

2.4.2

rovides that the IPC may accept the DCO application only if it gives reasons for those respects in which any applicable guidance given

2.4.3 n report.

2.4.4 'IP mber 2009. It was revised in March 2010 and again on 5 September 2011 (‘IPC Guidance N

2.4.5 'IP s under s37 of the Planning Act 2008' was published on 7 December 2009 and contained guidance on th rawn, ho ote 1 in

2.4.6 The revised IPC Guidance Note 1 guidance removes some of the advice in the March

2.4.7 CLG published ‘Planning Act: Guidance on pre-application consultation' in September

2.4.8 .

Information on how EDF Energy has complied with the requirements for consultation

those from the local community.

Exceptions/Departures

Section 50 of the A

promoter of a DCO application. Section 37(4) of the Act enables the IPC to give guidance about how to

Section 55(4)(c) of the Act provides that in deciding whether a proposed application has complied with statutory pre-application procedure, the IPC must have regard to the extent to which the applicant has had regard to any guidance issued under section 50. Section 55(3)(d) p

under section 37(4) have not been complied with.

The IPC has published guidance on the pre-application stages of the Act, including the preparation of the consultatio

C Guidance Note 1 on Pre-application Stages' was first published in Dece

ote 1’).

C Guidance Note 2 on preparation of application document

e form and content of DCO application material. This guidance was withdwever, on the same date as the publication of Revision 2 of IPC Guidance N

September 2011.

2010 revision which was already addressed in non-statutory IPC Advice Notes, although it maintains much of the earlier guidance relating to the pre-application consultation process. It now contains the relevant guidance on the preparation of a consultation report.

2009 (CLG Guidance).

EDF Energy has had regard to this guidance in carrying out its pre-application consultation on its proposals for HPC and in preparing its application to the IPC

contained in Revision 2 of IPC Guidance Note 1 and the CLG Guidance is contained in Chapter 1 of this report.




2.4.9 ultation is not appropriate and that

promoters are best placed to understand the detail of their project. In particular, it

2.4.11

of this report.

2.4.13

referred to an Environmental Status Report as part of its Stage 1 consultation which provided a

2.4.14 Paragraph 22 of the guidance advises that it may be advisable in some cases for applicants to also make available to the public a separate document which sets out in

Although applicants must have regard to the above guidance, the DCLG Guidance recognises that a one size fits all approach to cons

states at paragraphs 13 and 14:

“We also recognise that, whilst consultation should be thorough and effective, there will be a variety of possible approaches to discharging the requirements, and that consultation will need to be proportionate. We understand that promoters will have their own approaches to consultation, and already have a wealth of good practice on which to draw.

This guidance therefore outlines what the Government’s expectations are, and suggests a range of approaches as a ‘toolkit’ for promoters to use where relevant and helpful, but does not specify a particular approach to pre-application consultation.”

2.4.10 Throughout the process of engaging with a wide range of consultees over several years, EDF Energy has sought to meet both the overarching principles of the above guidance and to provide a more bespoke approach for the specific requirements of the HPC proposals. This has led to some exceptions and departures to the above guidance.

This section of the consultation report explains how and why EDF Energy has departed from the current guidance on pre-application consultation. It considers that these exceptions and departures have resulted in more effective, targeted consultation with statutory consultees, the local community and the general public.

2.4.12 EDF Energy has also had regard to advice provided by the relevant local authorities on how to conduct consultation with the local community. Whilst EDF Energy has sought to agree an approach to community consultation with the relevant local authorities, it has not always been able to follow the advice provided by the local authorities in all regards. The CLG Guidance states that where an applicant has not followed the advice of the local authority, an explanation must be provided. This information is provided in Chapter 1

a) Departures from IPC Guidance Note 1

SoCC1 (relating to the Stage 1 consultation) was prepared in November 2009, before the first version of IPC Guidance Note 1, and did not explicitly address these matters in the same way as the later SoCCs. However, the SoCC referred to the preparation of a consultation report to be submitted with the DCO application, which made clear the importance of the consultation process as part of the consideration of the application. The SoCC referred to a DCO application being made to the IPC, which again made it clear that the IPC was to determine the application. It also

preliminary view of the key issues. This SoCC was, in any event, superseded by SoCC2 as part of the Stage 2 consultation, where all these aspects of the guidance were met.




more depth the factors that had led to the view taken on consultation catchment, timing and methods to be employed and refer to this in the published SoCC. No such document was prepared before the Stage 1 consultation or referred to in SoCC1, as the IPC Guidance had not been issued at that stage and it was considered that sufficient information had been made available regarding the general approach to be taken to consultation. However, from Stage 2 onwards, EDF Energy prepared a consultation strategy document which set out the wider context to the consultation process. SoCCs 2-4 referred to this supporting document.

Paragraph 23 of the guidance advises that it would be helpful if the published deadlines for receipt of views on the application under section 48 are as close as possible t

2.4.15

o deadlines given in the section 42 consultation. As EDF Energy decided to adopt a multi-stage consultation exercise, it did not publish its section 48 notice

2.4.16

2.4.17

the IPC.

2.4.18 ion of IPC Guidance Note 1 states that a clear

start of Stage 1. Following publication of IPC Guidance Note 1, EDF Energy ensured that for all further stages of consultation, all of the bodies consulted

2.4.19

SoCC and launched its Stage 1 consultation. Again, this was because IPC Guidance Note 1 was not published until after EDF Energy

until Stage 2 of its consultation, in accordance with the illustrative flow chart in Annex B of the CLG Guidance.

The deadline for receipt of views from members of the public, as set in the section 48 notice at Stage 2, mirrored the deadline given to the consultees who were consulted under section 42 of the Act. The same applied to the Stage 2 Update consultation. EDF Energy decided, however, to take a different approach with the Junction 24 and Highways Improvements consultation in summer 2011. For this consultation, the deadline for the receipt of views from the section 42 consultees (28 July 2011) was different for the deadline for the receipt of views following the section 48 notice (12 August 2011). The reason for this was that the section 48 deadline was set to coincide instead with the end of the consultation with the local community.

It should be noted that Table 1.6 in Chapter 1 addresses the current version of IPC Guidance 1 and that in the following limited respects EDF Energy did not comply with the previous March 2010 revision when in force. The guidance referred to below does not form part of the current statutory guidance of

Paragraph 21 of the March 2010 revisexplanation must be provided if applicants identify and consult fewer consultation bodies as part of their obligations under section 42 of the Act than the IPC consults in relation to a scoping opinion request. At Stage 1 of its consultation, EDF Energy did not consult some of the consultation bodies that the IPC consulted in connection with EDF Energy’s request for a scoping opinion. This is because IPC Guidance Note 1 was published after EDF Energy launched its Stage 1 consultation and EDF Energy did not become aware of which consultation bodies had been consulted by the IPC until after the

by the IPC were included within the list of section 42 consultees consulted by EDF Energy.

In a similar vein, paragraph 31 of the March 2010 revision of IPC Guidance Note 1 stated that if “the NPS relevant to the proposal is not yet in place and consultation on a draft NPS is planned or underway the SOCC publication and subsequent consultation should ideally follow the NPS consultation”. The Nuclear NPS was published in draft for consultation in November 2009, which is the same month that EDF Energy published its




launched Stage 1. In practice, there was very little overlap in the consultation events held by the Government in respect of the draft Nuclear NPS and those held by EDF Energy in respect of its proposals for the HPC Project. All of EDF Energy’s Stage 1 consultation events took place after the Government’s own local consultation events

2.4.20 tes that promoters may find it helpful to make

informal contact with the relevant local authorities in advance of formal consultation.

ity consultation had already been established at these stages of consultation, EDF Energy did not consider it was necessary to

the Stage 2 Update and e formal statutory 28-day

tion 47

2.4.22 imately coincide

with the start of the consultation with communities under section 47.

2.4.23

2. formal consultation on the proposed application with communities and technical consultees should be the same to help ensure that the process is as efficient and transparent as possible, though it is understood that this may not always be the best approach”.

near Hinkley Point, except for one supplementary consultation event that was arranged by the Government in Stogursey in late January 2010 due to adverse weather conditions at earlier events. A subsequent draft of the Nuclear NPS was later published for further consultation at the end of October 2010. The consultation on this NPS did not coincide with any of the stages of EDF Energy’s consultation and no further consultation on this NPS was carried out.

b) Departures from CLG Guidance

In respect of consultation with local authorities under section 47(2) of the Act, paragraph 42 of the CLG Guidance sta

Similarly, paragraph 46 states that where promoters will need to consult with multiple authorities, promoters are encouraged to consult informally as early as possible on their proposed approach to allow time for the resolution of differences between authorities.

2.4.21 Prior to launching Stages 1 and 2 of its consultation, EDF Energy undertook informal discussions with the relevant local authorities to discuss EDF Energy’s proposed approach to consulting the local community on its proposals for the HPC Project. As the overall approach to commun

undertake further such informal discussions again prior toJ24 and Highways Improvements consultations and that thperiod for consultation with the local authorities on the SoCC pursuant to secof the Act was sufficient.

Paragraph 65 of the CLG Guidance states that the first of the two requiredadvertisements published under section 48 of the Act should approx

As mentioned above, due to the multi-stage and long-term nature of EDF Energy’s consultation exercise, EDF Energy did not publish its section 48 notice until Stage 2 of its consultation, in accordance with the illustrative flow chart in Annex B of the CLG Guidance. The CLG Guidance recognises that “aligning publicity with section 47 consultation may not always be possible, especially where a multi-stage consultation is intended”. For the Stage 2 and Stage 2 Update consultations, the first of the two section 48 advertisements approximately coincided with the start of the formal community consultation. For the J24 and Highways Improvements consultation, the first of the two section 48 notices was timed to coincide with the start of the informal consultation with the local communities, which started on 1 July 2011, with formal consultation starting on 15 July 2011.

4.24 Paragraph 70 states that “timescales for




2.4.25 At Stages 1, 2 and 2 Update, the timescales for consultation with consultees under sections 42 and 47 were the same. As explained above, a different approach was taken for the J24 and Highways Improvements consultation. At this stage, the following time periods were used:

2.4.26

al authorities in respect of the SoCC. This meant that the earliest that the formal

nsultation could begin was 15 July 2011. However, EDF Energy at this coincided with the summer holidays and therefore decided to

2.4.27 hort document should be ummarising the proposals,

2.4.28

on including plans) and were written in e providing information suitable for both technical

this reason, EDF Energy decided that it would not be appropriate to produce a summary document. For the slightly longer

f the

an executive summary was not considered necessary.

2.5

2.5.1 This section outlines how, should EDF Energy’s DCO application be accepted by the IPC, EDF Energy intends to inform statutory consultees, the local community, the

formal section 42 consultation from 1 to 28 July 2011;

publication of first section 48 notice on 30 June 2011 with a deadline for response of 12 August 2011; and

informal consultation with the local community from 1 July to 14 July 2011, then formal section 47 consultation from 15 July to 12 August 2011.

EDF Energy decided to hold the section 42 consultation between 1 and 28 July 2011 because many statutory bodies, such as town/parish councils, do not hold meetings during the summer holiday period. It was not possible to begin the formal section 47 consultation at the same time because EDF Energy was required under section 47 of the Act to consult with, and have regard to responses from, the relevant loc

section 47 corecognised thhold a period of informal consultation with the local community between 1 July and 14 July 2011 so that members of the community could provide their input before the school holidays began, if they so wished. The section 48 notice was published to coincide with the start of the formal section 42 consultation and informal local community consultation, with a deadline of 12 August 2011 that mirrored that given to the section 47 local community consultees.

Paragraph 82 of the CLG Guidance states that “…a sprepared by promoters specifically for local communities, soutlining the matters on which the view of the local community is sought”.

At Stages 1 and 2 of its consultation, a large amount of material was published by EDF Energy for consultation and it was therefore considered appropriate to also publish a summary document as suggested in the guidance. However, the Stage 2 Update and J24 and Highways Improvements consultations were limited, focused stages of consultation that did not seek to re-consult on the proposals as a whole. For these stages of consultation, the consultation documents were relatively short (54 pages for Stage 2 Update of which 14 were appended maps and 10 pages for J24 and Highways Improvements consultaticlear non-technical languagconsultees and the local community. For

Stage 2 Update document, a full executive summary was provided at the start oconsultation document. For the J24 and Highways Improvements consultation, this document was so short that

Next Steps




general public and other relevant stakeholders about the acceptance and explafinal proposals for the HPC Project. EDF Energy will continue to engacommunities, local authorities and other consultees throughout the post-applicatand examination stages of the process.

in its ge with

ion

2.5.2 ry s,

eadline to submit relevant representations to rgy’s

will also direct people to the ptance

an be viewed locally.

2.5.3

stakeholders and those who responded to EDF Energy’s pre-application consultation pursuant to section 56(2)

t to section 56(7) of the Act and seeking media editorial news coverage;

(2) of the APR Regs)

ely within

ation information via the HPC Project

a) Notification of Acceptance of the DCO Application

On acceptance of the DCO application by the IPC, EDF Energy will notify all statutoconsultees and the general public of this acceptance. Through these notificationEDF Energy will advise people of the dthe IPC outlining the key issues that they wish to raise in respect of EDF Eneapplication and to register as an interested party. This deadline will be not less than 28 days after publication of the notices. EDF EnergyIPC’s website where more information can be found on the process after acceof the application. In addition, EDF Energy will explain where copies of the application document c

Notification will be given by:

writing to all statutory consultees, other relevant

of the Act;

advertising the acceptance in local and national newspapers and the London Gazette pursuan

sending a copy of the section 56(2) notice to any consultees notified to EDF Energy by the IPC under Regulation 9(1)(c) of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (EIA Regs) pursuant toReg 13 of the EIA Regs;

putting up a site notice (as required by Regulation 9advertising the acceptance of the application;

publicising acceptance of the application in a newsletter circulated widthe affected local communities; and

providing a link to the final DCO applicwebsite, www.edfenergyconsultation.info.

b) Providing Information about EDF Energy’s Consultation and the DCO Application

EDF Energy is committed to keeping statutory2.5.4 consultees, other relevant

2.5.5 response to the consultation process and explain how this has informed the DCO application, EDF Energy will undertake a public

stakeholders, the local community and the general public informed about its response to the pre-application consultation process, how this has informed the DCO application and the content of the application itself.

In order to communicate its




ument and a consultation report summary bmitted to the IPC) to be made available

A further issue of EDF Energy Hinkley Point News, the community newsletter,

information exercise following acceptance of the DCO application by the IPC and provide/undertake:

A DCO application project summary doc(summarising the Consultation Report suto all key stakeholders and those who responded to the consultation process;

A series of public exhibitions in the main locations affected by the development incorporating exhibition boards and DCO material;

summarising the DCO application and providing IPC contact details;

All DCO application material to be provided via the HPC Project website, www.edfenergyconsultation.info; and

All exhibition material and DCO application documentation to be available at the EDF Energy Bridgwater office during normal office hours.

2.5.6 EDF Energy will publicise this information exercise and the availability of final documentation through the local and regional media.

2.5.7 This material will help to facilitate examination of the DCO application when statutory consultees, the local community and the general public (if registered with the IPC as interested parties) will have a further opportunity to comment directly to the IPC on the final proposals for HPC.

2.5.8 EDF Energy will seek to co-ordinate this public information exercise with any outreach events that the IPC may hold in relation to the HPC Project and explain the role of the IPC.

c) Continuing Community Engagement

2.5.9 EDF Energy is committed to continuing to engage informally on its plans for HPC with local authorities, affected local communities, statutory consultees and other relevant stakeholders during the post-application and examination stages of the IPC process and beyond.

2.5.10 This engagement will include regular meetings of the Community Forum, the Transport Forum and the MSNF, updates through newsletters, direct mail and the website www.edfenergyconsultation.info, as well as other meetings with community representatives. This process of continuous community engagement will be managed primarily through the EDF Energy office in Bridgwater, which also remains available to handle stakeholder queries by telephone, email, post or in person.



CHAPTER 3: RESULTS OF CONSULTATION


Consultation Report – Results of Consultation | October 2011 1


CONTENTS

3. RESULTS OF CONSULTATION .....................................................................................6

3.1 Introduction......................................................................................................................6

3.2 Quantitative Results ........................................................................................................7

3.3 Summary of Qualitative Results by Theme....................................................................98

a) Accommodation ........................................................................................................................99

b) Transport ................................................................................................................................101

c) Socio-Economics and Procurement ........................................................................................104

d) Sustainability Strategy.............................................................................................................113

e) Waste Management Strategy..................................................................................................115

f) Environmental Mitigation Strategy...........................................................................................117

g) Health Impact Assessment .....................................................................................................119

h) Environmental Impact Assessment .........................................................................................121

i) Habitats Regulations Assessment...........................................................................................125

j) Hinkley Point C Development Site ..........................................................................................127

k) Hinkley Point C Development Site Environmental ...................................................................129

l) On-site Accommodation Campus............................................................................................133

n) Cannington Bypass.................................................................................................................138

o) Combwich...............................................................................................................................141

p) Williton ....................................................................................................................................143

q) Bridgwater A ...........................................................................................................................145

r) Bridgwater C ...........................................................................................................................147

s) M5, Junction 23 ......................................................................................................................149

t) M5, Junction 24 ......................................................................................................................151

u) Planning Strategy....................................................................................................................153

v) Consultation............................................................................................................................159

w) Issues Beyond the Scope of the Consultation.........................................................................161

3.4 Qualitative Summary of Workshops and Focus Groups ..............................................162

TABLES

Table 3.1: Stage 1 and 2 Quantitative Questions ........................................................................7

Table 3.2: Postcode Area Groupings.........................................................................................11

Table 3.3: Area of Respondents to Stage 1 Questionnaire........................................................12

Table 3.4: Area of Respondents to Stage 2 Questionnaire........................................................13

Table 3.5: Area of Respondents to Stage 2 Update Questionnaire ...........................................14

Table 3.6: Area of Respondents to J24 and Highways Improvements Questionnaire ...............15

Table 3.7: Responses to Stage 1, Question 1 (a) ......................................................................16


2 Consultation Report – Results of Consultation | October 2011


Table 3.8: Area of Respondents to Stage 1, Question 1(a) .......................................................17

Table 3.9: Responses to Stage 1, Question 1(b) .......................................................................19

Table 3.10: Area of Respondents to Stage 1, Question 1(b) .....................................................19

Table 3.11: Responses to Stage 1, Question 2(i) ......................................................................21

Table 3.12: Area of Respondents to Stage 1, Question 2(i).......................................................21

Table 3.13: Responses to Stage 1, Question 2(ii) .....................................................................23

Table 3.14: Area of Respondents to Stage 1, Question 2(ii)......................................................23

Table 3.15: Responses to Stage 1, Question 2(iii).....................................................................25

Table 3.16: Area of Respondents to Stage 1, Question 2(iii) .....................................................25

Table 3.17: Responses to Stage 1, Question 2(iv) ....................................................................27

Table 3.18: Area of Respondents to Stage 1, Question 2(iv).....................................................27

Table 3.19: Responses to Stage 1, Question 11(a) ...................................................................29

Table 3.20: Area of Respondents to Stage 1, Question 11(a) ...................................................29

Table 3.21: Responses to Question Stage 1, Question 11(b)....................................................31

Table 3.22: Area of Respondents to Stage 1, Question 11(b) ...................................................31

Table 3.23: Responses to Stage 1, Question 11(c) ...................................................................33

Table 3.24: Area of Respondents to Stage 1, Question 11(c)....................................................33

Table 3.25: Responses to Stage 2, Question 1 .........................................................................35

Table 3.26: Area of Respondents to Stage 2, Question 1..........................................................35





Table 3.31: Responses to Stage 1, Question 4(b) .....................................................................41

Table 3.32: Areas of Respondents to Stage 1, Question 4(b)....................................................42





Table 3.37: Responses to Stage 1, Question 6(iii) .....................................................................48


Table 3.39: Responses to Stage 1, Question 6(iv) ....................................................................50

Table 3.40: Area of Respondents to Stage 1, Question 6(iv).....................................................50

Table 3.41: Responses to Stage 1, Question 6(v) .....................................................................52

Table 3.42: Area of Respondents to Stage 1, Question 6(v)......................................................52

Table 3.43: Responses to Stage 1, Question 6(vi) ....................................................................54




Table 3.44: Areas of Respondents to Stage 1, Question 6(vi) ...................................................54







Table 3.51: Responses to Stage 2, Question 9(iii).....................................................................63


Table 3.53: Responses to Stage 1, Question 4(a) .....................................................................65

Table 3.54: Area of Respondents to Stage 1, Question 4(a) .....................................................66







Table 3.61: Responses to Stage 1, Question 7(c) .....................................................................74

Table 3.62: Area of Responses to Stage 1, Question 7(c).........................................................74

Table 3.63: Responses to Stage 1, Question 7(d) .....................................................................76

Table 3.64: Area of Respondents to Stage 1, Question 7(d) .....................................................76





Table 3.69: Responses to Stage 1, Question 8(c) .....................................................................82

Table 3.70: Area of Respondents to Stage 1, Question 8(c)......................................................82









Table 3.79: Responses to Stage 2, Question 10 .......................................................................92




Table 3.80: Area of Respondents to Stage 2, Question 10........................................................92





FIGURES

Figure 3.1: Map Illustrating Responses to Stage 1, Question 1(a) ............................................18

Figure 3.2: Map Illustrating Responses to Stage 1, Question 1(b) ............................................20

Figure 3.3: Map Illustrating Responses to Stage 1, Question 2(i) .............................................22

Figure 3.4: Map Illustrating Responses to Stage 1, Question 2(ii).............................................24

Figure 3.5: Map Illustrating Responses to Stage 1, Question 2(iii) ............................................26

Figure 3.6: Map Illustrating Responses to Stage 1, Question 2(iv)............................................28

Figure 3.7: Map Illustrating Responses to Stage 1, Question 11(a) ..........................................30

Figure 3.8: Map Illustrating Responses to Stage 1, Question 11(b) ..........................................32

Figure 3.9: Map Illustrating Responses to Stage 1, Question 11(c) ..........................................34

Figure 3.10: Map Illustrating Responses to Stage 2, Question 1...............................................36




Figure 3.14: Map Illustrating Responses to Stage 1, Question 6(i) ...........................................45

Figure 3.15: Map Illustrating Responses to Stage 1, Question 6(ii)...........................................47

Figure 3.16: Map Illustrating Responses to Stage 1, Question 6(iii) ..........................................49

Figure 3.17: Map Illustrating Responses to Stage 1, Question 6(iv)..........................................51

Figure 3.18: Map Illustrating Responses to Stage 1, Question 6(v) ..........................................53

Figure 3.19: Map Illustrating Responses to Stage 1, Question 6(vi)..........................................55


Figure 3.21: Map Illustrating Responses to Stage 2, Question 9(i) ...........................................60

Figure 3.22: Map Illustrating Responses to Stage 2, Question 9(ii)...........................................62

Figure 3.23: Map Illustrating Responses to Stage 2, Question 9(iii) ..........................................64









Figure 3.29: Map Illustrating Responses to Stage 1, Question 7(d) ..........................................77








Figure 3.37: Map Illustrating Responses to Stage 2, Question 10.............................................93






3. RESULTS OF CONSULTATION

3.1 Introduction

3.1.1 This chapter sets out EDF Energy’s analysis of the results of formal consultation with statutory consultees and other relevant stakeholders, the local community and the general public during the pre-application consultation process. It covers written responses, completed questionnaires and the outcomes of workshops and focus groups. Summaries of the proposals being consulted on and, for the Stage 2, Stage 2 Update and Junction 24 and Highways Improvements consultations, how these changed following the previous stage of consultation, can be viewed in Appendix C.

3.1.2 The chapter is divided into two main sections: one providing a quantitative analysis

of the results of public questionnaires and some high-level statistics about issues raised in the qualitative responses; and the other providing a qualitative analysis of comments drawn from the public questionnaires and written responses from all categories of consultee. Reports of workshops, focus groups and a survey of tourists have also been included in the qualitative analysis.

3.1.3 Within the quantitative results section are the responses to the multiple-choice questions used at both the Stage 1 and the Stage 2 consultations. These questions, set out in Table 3.1, asked respondents to grade their considerations (from very important to not at all important) or views (from very satisfied to not satisfied at all). There were no quantitative questions in either of the questionnaires used for the Stage 2 Update or Junction 24 and Highway Improvements consultations. Copies of all the questionnaires used during the consultation process are shown in Appendix

C.

3.1.4 The quantitative analysis of the results of the public questionnaires has been divided into three key themes - the main Hinkley Point C (HPC) Development Site, accommodation and transport. Within these themes the results of both the Stage 1 and Stage 2 quantitative questionnaire responses have been analysed. This means that analysis of the results of the questionnaires is not always presented in the sequence of the questions as they originally appeared on the questionnaires.

3.1.5 The results of the qualitative analysis of the responses are organised by theme. EDF Energy’s high-level response to each theme is included under the relevant headings in this chapter.

3.1.6 Each overarching high-level response contains summaries of the main issues raised at each stage of the formal consultation. Where appropriate, a distinction has been drawn between the issues raised by statutory consultees and those raised by other relevant stakeholders, the local community and the general public.

3.1.7 EDF Energy has had regard to all qualitative and quantitative responses received throughout its consultation on proposals for Hinkley Point C and associated development. Feedback from the local community, statutory consultees, stakeholders and the general public has helped to shape the proposals. Quantitative results have been helpful in enabling EDF Energy to understand the views of the local




communities on certain key issues. However, the qualitative responses from the public, key stakeholders and statutory consultees have covered all aspects of the Project.

3.2 Quantitative Results

3.2.1 A questionnaire with a selection of quantitative and qualitative questions was produced at Stage 1 and Stage 2 consultations to gather feedback on EDF Energy’s proposals for Hinkley Point C and the associated development.

3.2.2 At the Stage 2 Update consultation and Junction 24 and Highway Improvements consultation, the questionnaires only contained free text comment boxes. As such, there were no quantitative responses to include in this section.

3.2.3 This section has been divided into area-specific responses within the following themes, as shown in Table 3.1:

• HPC Development Site

• Accommodation Strategy

• Transport Strategy

Table 3.1: Stage 1 and 2 Quantitative Questions

HPC Development Site

Stage 1 – Question 1a Do you agree that EDF Energy’s proposal to provide a landscape buffer on the southern boundary of the site is the best way of minimising the potential impact of the construction site for nearby local residents?

Stage 1 – Question 1b If yes, should this be retained as a permanent feature once the construction is completed?

Stage 1 – Question 2 There are a number of options for the restoration of the site at the end of the construction phase. How would you rate the following options:

i. Return land to its previous use

ii. Creation of wildlife habitats

iii. Grassland

iv. Woodland

Stage 1 – Question 11 What are your views on our proposals for undertaking, at our own risk, preliminary works to get the site ready for construction?

a. Construction of temporary sea jetty

b. Construction of sea wall

c. Site preparation and earthworks

Stage 2 – Question 1 What are your views on the proposed arrangement and landscaping of the Hinkley Point site?

Stage 2 – Question 2 We have reduced the amount of land to be used during construction in the southern part of the site in response to concerns from local residents. What are your views on this proposal?





Stage 2 – Question 3 In order to speed up the process of building the new power station, and enable us to finish work earlier, we intend to apply this summer to undertake preliminary works to prepare the main site and build a temporary jetty for the delivery of bulk materials. If permission for the power station is not obtained, we will be required to reinstate the land. What are your views on our plans for preliminary works?

Accommodation Strategy

Stage 1 – Question 4b What is your view on EDF Energy’s initial proposals for managing accommodation during the construction phase?

Stage 1 – Question 6 We are proposing a mix of solutions for accommodating construction workers. Please indicate your preference:

i. Temporary campus on-site for up to 700 workers

ii. Campus accommodation on a site to the south of Cannington for up to 200 workers with potential long-term legacy uses including student accommodation, hotel or other

iii. Additional campus accommodation at Cannington College for up to 120 workers, for long-term benefits to the college

iv. Campus accommodation at Williton for up to 200 workers with the potential for long-term legacy benefits including a care home, hotel or other

v. Accommodation for up to 500 workers at one of several campuses in Bridgwater, with potential long-term legacy uses, including student accommodation, hotel or other

vi. Use of existing owner-occupied and privately rented accommodation, including guesthouses and caravan parks

Stage 2 – Question 4 We intend to maximise the use of local workers to build the power station but we will expect between 3,000 to 3,500 workers at peak to require short-term accommodation because they do not currently live locally. These workers will be accommodated in a mixture of rented and owner-occupied accommodation, bed and breakfast and caravan parks. We are proposing purpose-built accommodation campuses; two in Bridgwater and one on the Hinkley Point C site. What are your views on our overall accommodation strategy?

Stage 2 – Question 9 We plan to accommodate between 1,080 and 1,925 non-local workers in accommodation campuses, depending upon the success of local recruitment and other factors. What are your views on our plans for accommodation campuses for the following locations?

i. Views on accommodation campuses at the Bridgwater Innovia site, Bath Road (site BRI-A) for up to 1,075 places

ii. Views on accommodation campus at the Bridgwater and Albion Rugby Football Club site, college way (site BRI-C) for up to 150 places

iii. Views on accommodation campuses at the Hinkley Point C site for up to 700 places

Transport Strategy

Stage 1 – Question 4a What is your view on EDF Energy’s initial proposals for managing transport during the construction phase?

Stage 1 – Question 5 We are planning a bypass for Cannington. Do you think the road is needed? If so, should it go to the east or west of the village?

Stage 1 – Question 7 What are your views on the four locations EDF Energy is proposing





for the new park and ride sites? Please indicate your preferences before and with reference to the maps

a. Views on a park and ride site at Cannington

b. Views on a park and ride site near Junction 24 of the M5 on the southern outskirts of Bridgwater

c. Views on a park and ride site near Junction 23 of the M5 on the northern outskirts of Bridgwater

d. Views on a park and ride site at Williton

Stage 1 – Question 8 What are your views on proposed freight handling facilities adjacent to some of the proposed park and ride sites and at Combwich?

a. Views on freight handling facilities on the outskirts of Bridgwater

b. Views on freight handling facilities near Cannington

c. Views on freight handling facilities at Combwich

Stage 2 – Question 5 The construction of the power station will increase traffic movements over a prolonged, but temporary, period of time. Our approach to managing this is to provide park and ride and freight logistics facilities so that traffic can be accommodated within the capacity of the existing highway network. What are your views on the overall transport strategy?

Stage 2 – Question 6 Although the levels of traffic anticipated could be accommodated within existing road capacity, we believe that particular considerations apply to Cannington which will see the greatest change to traffic flows and that a bypass would be beneficial. We consider that a western bypass for Cannington is the best option because it is the shortest route, can be built quickly (with less environmental impact than the eastern option) and will affect fewer properties. Do you agree with EDF Energy’s view that a Cannington western bypass should be provided?

Stage 2 – Question 7 We propose a park and ride facility on the A39, south of Cannington, for visitors to the main site and workers from Bridgwater and other nearby settlements so that they can leave their cars and transfer to buses to Hinkley Point. The park and ride facility would be removed when no longer required. What are your views on our plans for a temporary park and ride facility at Cannington?

Stage 2 – Question 8 We propose a park and ride facility on the A39, west of Williton, for workers from Minehead and other nearby settlements to leave their cars and transfer to buses to Hinkley Point. The park and ride facility would be removed when no longer required. What are your views on our plans for a temporary park and ride facility at Williton?

Transport Strategy

Stage 2 – Question 10 At Junction 23 of the M5 we are planning a park and ride facility for workers where they will be transferred to buses. A freight logistics facility is also proposed where freight could be consolidated and sent to Hinkley Point outside peak periods. After construction of the power station is complete, this site could be used to serve Bridgwater as a park and ride facility, employment-generating use or other appropriate land use. What are your views on our plans for the site near Junction 23 of the M5?

Stage 2 – Question 11 At Junction 24 of the M5 we are planning a park and ride facility for workers where they will be transferred to buses. A freight logistics facility is also proposed where freight could be consolidated and sent





to Hinkley Point outside peak periods. After construction of the power station is complete, this site could be used to serve Bridgwater as a park and ride facility, employment-generating use or other appropriate land use. What are your views on our plans for the site near Junction 24 of the M5?

Stage 2 – Question 12 We plan to bring in as much of the construction material as possible by sea, including large components. What are your views on our proposals for furbishing Combwich Wharf and providing an associated freight logistics/storage area to assist this process?

3.2.4 The results to each question are illustrated in three ways:

• A table showing the responses to the question – from all who responded; from those who provided a valid postcode in the area; from those outside the area or who did not provide a valid postcode; and a percentage of all respondents to the specific questions.

• A table showing the number of respondents that provided a valid postcode broken down into geographical area.

• A map showing the breakdown of responses in each geographical area.1

3.2.5 To assist with analysis of the results, where respondents provided a valid postcode, responses have been grouped together into geographical areas. Maps have been generated to help illustrate the responses from these different areas to the quantitative questions:

• At Stage 1, 88% of respondents supplied a valid postcode in the area.

• At Stage 2, 92% of respondents supplied a valid postcode in the area.

3.2.6 At Stage 1, the consultation included a number of search areas for the proposals, which were based on proximity to the proposed associated development sites. These are shown on the key of the Stage 1 maps in this chapter:

1) Bridgwater search areas

2) Cannington search areas

3) Cannington bypass options

4) Combwich search areas

1 It should be noted that, prior to the creation of the full Consultation Report, the postcode groupings of

respondents had not been finalised. For the Consultation Report, geographical boundaries were refined to ensure

accurate analysis, resulting in some changes to postcode groupings.




5) Junction 23 (J23) search areas

6) Junction 24 (J24) search areas

7) Williton search areas

3.2.7 At Stage 2, this changes to eight specific sites being consulted upon:

1) Bridgwater A site

2) Bridgwater C site

3) Cannington bypass

4) Cannington site

5) Combwich Wharf site

6) M5 Junction 23 site

7) M5 Junction 24 site

8) Williton site

3.2.8 The quantitative results set out in the tables and figures in this section are presented with some limited statistical analysis and interpretation. The key results from each table and figure are highlighted in the narrative text that follows them. It should be noted that the number of respondents to these questionnaires represent a relatively small proportion of the overall population within the area being consulted and, as such, it is only possible to draw broad conclusions based on these results.

a) Questionnaire Respondents

3.2.9 Table 3.2 describes how the o postcode areas of respondents were grouped in order to provide a detailed analysis f the quantitative responses.

Table 3.2: Postcode Area Groupings

Grouped Areas Places Included in Groupings

Shurton, Burton and Stogursey Shurton, Burton, Knighton, Wick, Stogursey, Stolford

Nether Stowey Nether Stowey, Over Stowey, Fiddington, Stringston, Spaxton, Kilve, Holford, East & West Quantoxhead

Cannington Cannington

Otterhampton/Combwich Otterhampton, Combwich, Stockland Bristol

Bridgwater Central Bridgwater, Wembdon

Bridgwater North North of Express Park, Bridgwater, including area around Junction 23 of the M5 (Puriton, Pawlett, Bawdrip)

Bridgwater South South of Wills Road, Bridgwater (including area around Junction 24 of the M5) North Petherton, Stockmoor Village, Huntworth




Grouped Areas Places Included in Groupings

Burnham-on-Sea and Highbridge Burnham-on-Sea, Highbridge, Brean

Watchet, Williton, Donisford and Sampford Brett

Watchet, Williton, Donisford and Sampford Brett

Taunton area Taunton and surrounding area

Minehead Minehead, Dunster

Bristol area Bristol and surrounding area

Between Bristol and Burnham-on-Sea (including Weston-super-Mare, North Somerset, rural parts of north Sedgemoor and parts of Mendip)


Outside these areas or no postcode supplied

Outside these areas or no postcode supplied

i. Stage 1

3.2.10 At the end of the Stage 1 consultation period, 472 completed questionnaires had been returned, either online or in hard copy format (at the exhibition or using the freepost address) – see Table 3.3.

Table 3.3: Area of Respondents to Stage 1 Questionnaire

(Valid Postcode in Area Only)

Areas Questionnaires

with a Valid

Postcode in the

Area

Percentage of

Responses

Watchet, Williton, Donisford and Sampford Brett 108 23%

Cannington 100 21%

Otterhampton/Combwich 45 10%

Shurton, Burton and Stogursey 42 9%

Bridgwater Central 25 5%

Nether Stowey 21 4%

Bristol area 15 3%

Burnham-on-Sea and Highbridge 14 3%


13 3%

Bridgwater South 9 2%

Taunton area 8 2%

Minehead 7 2%

Bridgwater North 5 1%

Outside these areas or no postcode supplied 60 12%

Total 472 100%




3.2.11 As Table 3.3 shows, 472 completed questionnaires were submitted at Stage 1.

Of those, 412 respondents supplied a valid postcode (88%), while 60 (12%) either did not or were outside these geographic areas. An analysis of these postcodes illustrates that, at Stage 1, those expressing most interest in the proposals lived closest to the search areas for associated developments: Williton/Sampford Brett (23%), Cannington (21%), Otterhampton/Combwich (10%) and Bridgwater (8%).

3.2.12 It should be noted that, at this stage, a relatively small percentage of respondents (9%) lived in the villages closest to the HPC Development Site (Shurton, Burton and Stogursey).

ii. Stage 2

3.2.13 At the end of the Stage 2 consultation period, 541 completed questionnaires were returned, either online or in hard copy format; 69 more questionnaires than received at Stage 1 (see Table 3.4).

Table 3.4: Area of Respondents to Stage 2 Questionnaire



with a Valid

Postcode in the

Area

Percentage of

Responses


Cannington 79 15%




Nether Stowey 51 9%




Taunton area 13 2%

Minehead 12 2%


3 1%

Bristol area 2 1%


Total 541 100%

3.2.14 Of the 541 completed questionnaires, 497 respondents supplied a valid postcode (92%) and 44 (8%) did not or were outside these geographic areas.

3.2.15 Those expressing most interest in the proposals lived closest to the HPC Development Site and associated development sites; Otterhampton/Combwich




(17%), Cannington (15%), Shurton, Burton and Stogursey (14%), Bridgwater Central (11%) and Bridgwater South (11%).

3.2.16 At Stage 2, the level of response increased in a number of areas, particularly in Otterhampton/Combwich (from 45 respondents to 93), Nether Stowey (from 21 respondents to 51), Bridgwater Central (from 25 respondents to 60), Bridgwater South (from 9 respondents to 55) and Shurton, Burton and Stogursey (from 42 respondents to 74).

3.2.17 By contrast, respondents from Watchet, Williton, Doniford and Sampford Brett, decreased by more than three quarters (from 108 respondents to 24) and from Cannington by nearly a quarter (from 100 respondents to 79). Responses from those in Bristol decreased from 15 to 2 and those outside the areas/no postcode supplied from 60 respondents to 44, despite wider advertising through the Daily Telegraph

and London Gazette.

3.2.18 This largely reflects the changes made to the HPC proposals at Stage 2, with interest levels rising in areas proposed for associated development and the HPC Development Site.

iii. Stage 2 Update

3.2.19 At the end of the consultation on proposed changes to the ‘Preferred Proposals’ period, 159 completed questionnaires were returned, either online or in hard copy format (see Table 3.5).

Table 3.5: Area of Respondents to Stage 2 Update Questionnaire



with a Valid

Postcode in the

Area

Percentage of

Responses



Cannington 23 14%


Nether Stowey 12 8%






2 1%

Taunton area 1 1%

Minehead 1 1%

Bristol area 0 0


Total 159 100%




3.2.20 The highest level of response was from Shurton, Burton and Stogursey (18%), Otterhampton/Combwich (15%), Cannington (14%) and Bridgwater Central (10%). Although the percentage of responses received from these areas was similar to Stage 2, the actual numbers were much fewer at this stage of consultation.

3.2.21 A lower response is consistent with the limited number of material changes being consulted on at this stage of the consultation, and the higher level of responses are predominantly in those areas in which changes were proposed.

iv. Junction 24 and Highways Improvements

3.2.22 At the end of the Junction 24 and Highways Improvements consultation period, 90 questionnaires were completed and returned, either online or in hard copy format (see Table 3.6).

Table 3.6: Area of Respondents to J24 and Highways Improvements Questionnaire



with a Valid

Postcode in the

Area

Percentage of

Responses




Cannington 7 8%

Nether Stowey 3 3%



Taunton area 1 1%


1 1%



Minehead 0 0%

Bristol area 0 0%


Total 90 100%

3.2.23 The highest level of response was from Bridgwater Central (35%) and Bridgwater South (19%). This is representative of the areas of proposed material changes on which EDF Energy was consulting at this stage.

b) Questionnaire Responses – HPC Development Site

3.2.24 Questions at Stages 1 and 2 invited people to comment on the proposed arrangement, landscaping and land use of the HPC Development Site, particularly




with regard to providing a landscape buffer and the restoration of the site at the end

of the construction phase. At Stage 1, questions were also asked about EDF Energy’s proposals for undertaking preliminary works to prepare the development site for construction.

3.2.25 Although being applied for in separate application processes (see Appendix B), the

Preliminary Works, both the Site Preparation and Temporary Jetty, are also included in the DCO application and are therefore also covered in this chapter.

i. Stage 1

Stage 1 - Question 1a: Do you agree that EDF Energy’s proposal to provide a landscape buffer on the southern boundary of the site is the best way of minimising the potential impact of the construction site for nearby local residents?

3.2.26 As Table 3.7 shows, of the 370 respondents who answered this question, more than two thirds (67%) agreed that EDF Energy’s proposal to provide a landscape buffer on the southern boundary of the site would be the best way of minimising the potential impact of the construction site for nearby residents. Less than a quarter (11%) of respondents did not agree that this was the best option.

Table 3.7: Responses to Stage 1, Question 1 (a)

Responses All Respondents Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

Yes 242 217 25 67%

No 49 39 10 11%

Don’t know 79 68 11 22%

Question Unanswered

102 59 43 N/A

Total 472 383 89 100%

3.2.27 Of the 242 respondents who were in agreement with the proposal for a landscape buffer, 124 (just over 50%) lived in the areas closest to the site: 56 (23%) in Cannington, 28 (11%) in Otterhampton/Combwich, 27 (11%) lived in Shurton, Burton and Stogursey and 13 (5%) in Nether Stowey.

3.2.28 Of the 49 respondents who answered that they were not in agreement with the proposal for a landscape buffer, 24 (under 50%) lived in the areas closest to the site: 11 (22%) in Cannington, 7 (14%) in Shurton, Burton and Stogursey, 3 (6%) in Nether Stowey and 1 (2%) in Otterhampton/Combwich.




Table 3.8: Area of Respondents to Stage 1, Question 1(a)



with a Valid

Postcode in Area

Percentage of

Responses


Cannington 92 24%




Nether Stowey 20 6%


Bristol area 14 4%


10 2%


Minehead 7 2%

Taunton area 6 1%


Total 383 100%




Figure 3.1: Map Illustrating Responses to Stage 1, Question 1(a)


3.2.29 As Figure 3.1 shows, the majority of respondents in each area who answered the

question were in favour of EDF Energy’s proposals to provide a landscape buffer on the southern boundary of the Development Site to minimise the potential impact of the construction site for nearby local residents. Of the 41 people living closest to the Hinkley Point C Development Site (Shurton, Burton and Stogursey), 27 (66%) were in favour of the landscape buffer and 7 (17%) did not agree it would be the best way to minimise potential impacts.

Stage 1 - Question 1b: If yes, should this be retained as a permanent feature once construction is completed?

3.2.30 As Table 3.9 shows, of the 321 people who answered this question, two thirds (212

respondents, 67%) thought the buffer should be a permanent feature, while 32 (11%) thought it should be a temporary feature.




Table 3.9: Responses to Stage 1, Question 1(b)

Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

Yes 212 190 22 67%

No 32 26 6 11%

Don’t know 77 61 16 22%

Question Unanswered

151 73 78 N/A

Total 472 350 122 100%

3.2.31 Of the 212 respondents who were in favour of the proposed landscape buffer being a permanent feature, 102 (nearly 50%) lived in the areas closest to the site: 44 (21%) in Cannington, 25 (12%) in Otterhampton/Combwich, 23 (11%) in Shurton, Burton and Stogursey and 10 (5%) in Nether Stowey.

3.2.32 Of the 32 respondents who thought the proposed landscape buffer should be a temporary feature, 17 (just over 50%) lived in the areas closest to the site: 7 (22%) in Cannington, 4 (12%) in Otterhampton/Combwich, 3 (9%) in Shurton, Burton and Stogursey and 3 (9%) in Nether Stowey.

Table 3.10: Area of Respondents to Stage 1, Question 1(b)



with a Valid

Postcode in the

Area

Percentage of

Responses


Cannington 80 23%




Nether Stowey 18 5%


Bristol area 13 4%


10 3%

Minehead 7 2%


Taunton area 6 2%


Total 350 100%




Figure 3.2: Map Illustrating Responses to Stage 1, Question 1(b)


3.2.33 As Figure 3.2 shows, the majority of respondents in the mapped areas who were in

favour of EDF Energy’s proposals to provide a landscape buffer on the southern boundary thought that it should be a permanent feature.

3.2.34 Of the 35 people living closest to the site (Shurton, Burton and Stogursey), 23 (66%) were in favour of the buffer being a permanent feature and 3 (9%) would prefer it to be temporary.

Stage 1 - Question 2: There are a number of options for the restoration of the site at the end of the construction phase.

3.2.35 There were a number of options in this question for respondents to rate (from very important to not at all important) and, therefore, this section is divided into the following four options:

• Return land to its previous use;

• Creation of wildlife habitats;

• Grassland; and

• Woodland.

3.2.36 Those living closest to the site (Shurton, Burton and Stogursey) favoured slightly different priorities, favouring woodland and grassland above the other options:




woodland (37%), followed by grassland (34%), wildlife habitat (31%) and returning the land to previous use (25%).

Stage 1 – Question 2(i): Return land to its previous use

3.2.37 As Table 3.11 shows, of the 316 respondents who completed this question, 233 (74%) respondents felt it was either very important or important that the land be returned to its previous use. 51 (16%) respondents thought this was not important or not at all important.

Table 3.11: Responses to Stage 1, Question 2(i)

Responses All

Respondents

Valid Postcode

in Area

Outside

Mapped Area or

No Valid

Postcode

Percentage of

Responses

Very important 165 147 18 52%

Important 68 55 13 22%

Not important 41 36 5 13%

Not at all important 10 6 4 3%

Don’t know 32 27 5 10%

Question Unanswered

156 97 59 N/A

Total 472 368 104 100%

3.2.38 Of the 233 respondents who felt it was important or very important that the land be returned to its previous use, 111 (nearly 50%) lived in the area closest to the site: 51 (22%) in Cannington, 25 (11%) lived in Shurton, Burton and Stogursey, 24 (10%) in Otterhampton/Combwich and 11 (3%) in Nether Stowey.

Table 3.12: Area of Respondents to Stage 1, Question 2(i)



with a Valid

Postcode in the

Area

Percentage of

Responses


Cannington 88 24%




Nether Stowey 23 6%

Bristol area 14 4%



8 2%





with a Valid

Postcode in the

Area

Percentage of

Responses


Taunton area 6 2%

Minehead 5 1%


Total 368 100%

Figure 3.3: Map Illustrating Responses to Stage 1, Question 2(i)


3.2.39 As Figure 3.3 shows, of those who expressed an opinion on this question, the majority of those people living in the mapped areas thought it was either very important or important to return the land to its previous use.

3.2.40 Of the 32 residents in Shurton, Burton and Stogursey who expressed an opinion on this option, 25 respondents (78%) thought returning the land to its previous use was important or very important, and only seven respondents (2%) thought that it was unimportant or very unimportant.

Stage 1 - Question 2(ii): Creation of wildlife habitats

3.2.41 As Table 3.13 shows, 320 respondents completed this question. Of those, 276

respondents (86%) felt it was either very important or important to create wildlife




habitats when the land is restored following construction. Only 23 (7%) thought creating wildlife habits on the site was not important or not at all important.

Table 3.13: Responses to Stage 1, Question 2(ii)

Responses All

Respondents

Valid Postcode

in Area

Outside Mapped Area

or No Valid Postcode

Percentage of

Responses





Don’t know 21 17 4 7%

Question Unanswered

152 97 55 N/A

Total 472 372 100 100%

3.2.42 Of the 276 respondents who felt it was very important or important that wildlife habitats be created, 134 (nearly 50%) lived in the areas closest to the site: 53 (19%) in Cannington, 37 (13%) in Otterhampton/Combwich, 31 (11%) in Shurton, Burton and Stogursey and 13 (5%) in Nether Stowey (see Table 3.14).

Table 3.14: Area of Respondents to Stage 1, Question 2(ii) (Valid Postcode in Area Only)

Areas Questionnaires with

a Valid Postcode in

the Area

Percentage of

Responses


Cannington 86 23%



Nether Stowey 22 6%



Bristol area 14 0%

Bridgwater South 8 2.5%


9 1%

Bridgwater North 6 2.5%

Taunton area 6 2.5%

Minehead 6 2.5%

Total 372 100%




Figure 3.4: Map Illustrating Responses to Stage 1, Question 2(ii)


3.2.43 As Figure 3.4 above shows, of those who expressed an opinion on this question, a

large majority of those in the mapped areas thought it was either very important or important to create wildlife habitats.

3.2.44 Of the 38 residents in Shurton, Burton and Stogursey who expressed an opinion on this option, 31 (82%) thought creation of wildlife habitats was important or very important, and only five (13%) that it was unimportant or very unimportant.

Stage 1 - Question 2(iii): Grassland

3.2.45 As Table 3.15 shows, 291 of those who completed the questionnaire answered this question. Of those, 222 respondents (76%) felt it was very important or important to restore the land to grassland after use, whereas 37 respondents (13%) thought grassland was unimportant or very unimportant.




Table 3.15: Responses to Stage 1, Question 2(iii)


Responses All

Respondents

Valid Postcode

in Area

Outside Mapped Area


Percentage of

Responses


Important 102 89 13 35%



Don’t know 32 25 7 11%

Question Unanswered

181 97 84 N/A

Total 472 345 127 100%

3.2.46 Of the 222 respondents who felt it was very important or important that grassland be created, 114 (just over 50%) lived in the area closest to the site: 46 (21%) in Cannington, 34 (15%) lived in Shurton, Burton and Stogursey, 29 (13%) in Otterhampton/Combwich and five (2%) in Nether Stowey (see Table 3.16).

Table 3.16: Area of Respondents to Stage 1, Question 2(iii)



with a Valid

Postcode in the

Area

Percentage of

Responses


Cannington 81 24%




Nether Stowey 18 5%


Bristol area 14 4%



8 2%

Taunton area 6 2%

Minehead 5 1%


Total 345 100%




Figure 3.5: Map Illustrating Responses to Stage 1, Question 2(iii)


3.2.47 As illustrated in Table 3.16, of the 39 residents in Shurton, Burton and Stogursey who responded to this question, 34 (87%) thought grassland was important or very important and only two (5%) that it was unimportant or very unimportant.

Stage 1 - Question 2(iv): Woodland

3.2.48 As Table 3.17 shows, 308 of those who completed the questionnaire responded to this question. Of those, 260 respondents (84%) felt it was very important or important to restore the land to woodland after use. Only 22 (8%) of respondents felt the creation of woodland was not important.




Table 3.17: Responses to Stage 1, Question 2(iv)


Responses All

Respondents

Valid Postcode

in Area

Outside

Mapped Area

or No Valid

Postcode

Percentage of

Responses





Don’t know 26 20 6 8%

Question Unanswered 164 97 67 N/A

Total 472 361 111 100

3.2.49 Of the 260 respondents who felt it was important or very important to create woodlands, 136 (just over 50%) lived in the areas closest to the site: 53 (20%) in Cannington, 37 (14%) in Shurton, Burton and Stogursey, 35 (13%) in Otterhampton/Combwich and 11 (4%) in Nether Stowey (see Table 3.18).

Table 3.18: Area of Respondents to Stage 1, Question 2(iv)



with a Valid

Postcode in the

Area

Percentage of

Responses


Cannington 87 24%



Nether Stowey 21 6%

Bridgwater Central 20 5.5%


Bristol area 14 4%



8 2%

Minehead 6 1.5%


Taunton area 6 1.5%

Total 361 100%




Figure 3.6: Map Illustrating Responses to Stage 1, Question 2(iv)


3.2.50 Of the 39 residents in Shurton, Burton and Stogursey who responded to this question, 37 (95%) thought woodland was important or very important and no one thought that it was unimportant or very unimportant (see Figure 3.6).

Stage 1 – Question 11: What are your views on our proposals for undertaking, at our own risk, preliminary works to get the site ready for construction? a): Construction of temporary sea jetty

3.2.51 As can be seen from Table 3.19, respondents to the questionnaire were generally

supportive of EDF Energy’s proposals for the construction of the temporary jetty, with only 17% of respondents not very or not at all satisfied by the proposals.

3.2.52 Of those 59 respondents (17%) that were not satisfied with the proposals, two thirds (61%) came from the inner consultation zone nearest to the Hinkley Point C Development Site: 13 respondents (22%) from Cannington, 11 respondents (19%) from Shurton, Burton and Stogursey, seven respondents (12%) from Otterhampton/Combwich and five respondents (8%) from Nether Stowey.




Table 3.19: Responses to Stage 1, Question 11(a)

Responses All

Respondents

Valid Postcode

in Area

Outside

Mapped Area

or No Valid

Postcode

Percentage of

Responses

Very satisfied 80 66 14 23%

Satisfied 98 87 11 28%

Neither satisfied nor dissatisfied

67 63 4 18%

Not very satisfied 13 9 4 4%

Not satisfied at all 46 42 4 13%

Don’t know 51 41 10 14%


Total 472 378 94 100%

3.2.53 As Table 3.20 shows, 378 respondents in the mapped area who completed the questionnaire responded to this question. Of those responding to the temporary jetty question, just over half (51%) came from the inner consultation zone nearest to the preliminary works: 94 respondents (25%) from Cannington, 43 respondent (11%) from Otterhampton/Combwich, 38 respondents (10%) from Shurton, Burton and Stogursey and 20 respondents (5%) from Nether Stowey.




with a Valid

Postcode in the

Area

Percentage of

Responses


Cannington 94 25%




Nether Stowey 20 5%


Bristol area 13 4%


9 2%



Taunton area 6 2%

Minehead 5 1%

Total 378 100%






3.2.54 As can be seen from Figure 3.7, in nearly all areas mapped, the majority of those

who responded to the question were either very satisfied, satisfied or neither satisfied nor dissatisfied. The exception to this is the Taunton area where 50% of respondents were not at all satisfied with the temporary jetty proposal; however, this only represents the views of three people.

3.2.55 Only a relatively small percentage of respondents in each area were not very satisfied or not at all satisfied with the temporary jetty proposals. Those living in the closest proximity to the site (in Shurton, Burton and Stogursey) had the highest percentage of respondents not satisfied.

Stage 1 – Question 11: What are your views on our proposals for undertaking, at our own risk, preliminary works to get the site ready for construction? b) Construction of Sea Wall

3.2.56 As shown in Table 3.21, the majority of those who gave a response to the question were supportive of EDF Energy’s proposals to construct a sea wall to protect the Hinkley Point C Development Site. Of the 350 people who responded to the question about the sea wall, 183 (53%) respondents were very satisfied or satisfied with the proposal, 60 (17%) were neither satisfied nor dissatisfied and only 55 (15%) were not very satisfied or not at all satisfied.




Table 3.21: Responses to Question Stage 1, Question 11(b)

Responses All

Respondents

Valid Postcode

in Area

Outside

Mapped Area

or No Valid

Postcode

Percentage of

Responses


Satisfied 107 95 12 31%


60 55 5 17%



Don’t know 52 44 8 15%


Total

3.2.57 As Table 3.22 shows, just over half (52%) of the respondents were from the areas closest to the site: 95 (25%) respondents from Cannington, 43 (11%) respondents from Otterhampton, 40 (11%) respondents from Shurton, Burton and Stogursey and 20 (5%) from Nether Stowey.



Areas Questionnaires with a

Valid Postcode in the

Area

Percentage of

Responses


Cannington 95 25%




Nether Stowey 20 5%


Bristol area 13 3%



9 2%

Taunton area 6 2%

Minehead 5 1%


Total 381 100%






3.2.58 As can be seen from Figure 3.8, the majority of respondents in each of the mapped

areas were either very satisfied or satisfied with EDF Energy’s proposals to construct a sea wall as part of the preliminary site works.

3.2.59 The highest number of respondents in an area dissatisfied with the proposals lived in the Shurton, Burton and Stogursey area, the areas closest to the Hinkley Point C Development Site. Of the 49 respondents not satisfied or not at all satisfied with the proposals, nearly a quarter (12 respondents) lived in the Shurton, Burton and Stogursey area.

Stage 1 – Question 11: What are your views on our proposals for undertaking, at our own risk, preliminary works to get the site ready for construction? c) Site preparation and earthworks

3.2.60 As shown in Table 3.23, the largest percentage of those who gave a response to this

question were supportive of EDF Energy’s proposals to undertake site preparation and earthworks to get the site ready for construction. Of the 349 people who responded to the query about site preparation and earthworks, 158 (45%) respondents were very satisfied or satisfied with the proposal, 66 (19%) were neither satisfied nor dissatisfied and 70 (21%) were not very satisfied or not at all satisfied.




Table 3.23: Responses to Stage 1, Question 11(c)

Responses All

Respondents

Valid Postcode

in Area

Outside

Mapped Area

or No Valid

Postcode

Percentage of

Responses




66 61 5 19%



Don’t know 55 45 10 15%


Total 472 379 93 100%

3.2.61 As Table 3.24 shows, just over half (52%) of the respondents were from the areas closest to the site: 93 (25%) respondents from Cannington, 43 (12%) respondents from Otterhampton, 39 (10%) respondents from Shurton, Burton and Stogursey and 20 (5%) from Nether Stowey.

Table 3.24: Area of Respondents to Stage 1, Question 11(c)


Areas Questionnaires with a

Valid Postcode in the

Area

Percentage of

Responses


Cannington 93 25%




Nether Stowey 20 5%

Bristol area 13 4%




9 2%

Taunton area 6 2%

Minehead 5 1%


Total 379 100%




Figure 3.9: Map Illustrating Responses to Stage 1, Question 11(c)


3.2.62 As can be seen from Figure 3.9, the majority of respondents in almost all of the

mapped areas, with the exception of Shurton, Burton and Stogursey, were more satisfied than dissatisfied with EDF Energy’s proposals for site preparation and earthworks.

3.2.63 Those living closest to the Hinkley Point C Development Site were relatively evenly split between those satisfied and dissatisfied with the proposals. Of the 39 respondents in the Shurton, Burton and Stogursey area, 16 were dissatisfied or very dissatisfied and 14 were satisfied or very satisfied.

ii. Stage 2

3.2.64 In developing the ‘Preferred Proposals’ consulted on at Stage 2 consultation, EDF Energy had regard to the feedback received in response to Stage 1 consultation. In particular, EDF Energy consulted on the proposal of moving the southern boundary of the site further north, away from the village of Shurton. Furthermore, in designing the Stage 2 proposals for landscaping, EDF Energy took into consideration the spread of opinion for restoration of the site at Stage 1 and incorporated new woodland, the reinstatement of grass meadows and streams, the creation of new grass meadows and wetland areas, in addition to creating wildlife habitats.

3.2.65 People were given the opportunity to comment on these ‘Preferred Proposals’ in the Stage 2 questionnaire. As at Stage 1, a question was also asked on Preliminary Works.




Stage 2 - Question 1: What are your views on the proposed arrangement and landscaping of the Hinkley Point site?

3.2.66 As shown in Table 3.25, of the 347 who answered this question (satisfactory or unsatisfactory), more than half, 197 (57%), were satisfied with the proposals. Of the 541 people that filled in a questionnaire, 194 respondents either did not know or did not express an opinion on the landscaping options.

Table 3.25: Responses to Stage 2, Question 1

Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

Satisfactory 197 176 21 36%

Unsatisfactory 150 142 8 28%

Don’t know 27 27 0 5%

No opinion/Question Unanswered

167 153 14 31%

Total 541 498 43 100%

3.2.67 Those living nearest the site (Shurton, Burton and Stogursey), however, did not reflect the majority view from the overall responses. Of the 74 people in that area who responded to the questionnaire, only 12 respondents (16%) were satisfied with the proposed arrangement and landscaping, 44 respondents (59%) thought the proposals were unsatisfactory, while 17 respondents (15%) did not know or had no opinion (see Table 3.26).

Table 3.26: Area of Respondents to Stage 2, Question 1 (Valid Postcode in Area Only)


a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%



Nether Stowey 51 10%




Taunton area 13 3%


Minehead 12 2%


3 0.5%

Bristol area 2 0.5%

Total 497 100%




Figure 3.10: Map Illustrating Responses to Stage 2, Question 1

(Valid Postcode In Area Only)

3.2.68 As illustrated in Figure 3.10, the majority of those who thought the proposals were unsatisfactory lived in the areas closest to the site. In the Shurton, Burton and Stogursey area, more respondents were dissatisfied than satisfied with the proposals. In Otterhampton and Nether Stowey, respondents were divided in their views.

3.2.69 The majority of those living in the wider area, as represented by the map, were more satisfied than dissatisfied with the proposed arrangement and landscaping.

Stage 2 - Question 2: We have reduced the amount of land to be used during construction in the southern part of the site in response to concerns from local residents. What are your views on this proposal?

3.2.70 Of the 347 who answered this question (satisfactory or unsatisfactory), 210 (60%) were satisfied with the proposals. Of the 541 people that filled in a questionnaire, 194 respondents either did not know or did not express an opinion on the reduction of the land to be used during construction in the southern part of the site (see Table

3.27).





Responses All

Respondents

Valid

Postcode in

Area

Outside

Mapped Area

or No Valid

Postcode

Percentage of

Responses



Don’t know 19 18 1 4%

No opinion/Question Unanswered

175 160 15 32%

Total 541 497 44 100%

3.2.71 Respondents living nearest the site (Shurton, Burton and Stogursey) were marginally more satisfied than dissatisfied with the proposals. Of the 74 people in that area that responded to the questionnaire, 30 respondents (41%) thought the proposals were satisfactory, whilst 28 respondents (38%) thought they were unsatisfactory. The remaining 16 respondents (21%) from the area either did not know or did not express an opinion (see Table 3.28).

Table 3.28: Area of Respondents to Stage 2, Question 2



with a Valid

Postcode in the

Area

Percentage of

Responses


Cannington 79 16%







Taunton area 13 3%


Minehead 12 2%


3 0.5%

Bristol area 2 0.5%

Total 497 100%






3.2.72 As illustrated in Figure 3.11, the respondents in the Shurton, Burton and Stogursey

area were divided equally in their views on the reduction of the amount of land to be used during construction in the southern part of the site. Respondents in Nether Stowey were similarly split in their views on the proposals.

3.2.73 Elsewhere, the majority of respondents were more satisfied than dissatisfied with EDF Energy’s proposal to reduce the amount of land to be used during construction in the southern part of the site.

3.2.74 The only notable exception was Otterhampton, where respondents were more dissatisfied than satisfied. Of the 93 respondents in Otterhampton, 38 (41%) thought the proposals were unsatisfactory, whereas 22 (24%) thought they were satisfactory. Of those 93, 33 (35%) did not know or had no opinion.

Stage 2 - Question 3: In order to speed up the process of building the new power station, and enable us to finish work earlier, we intend to apply this summer to undertake preliminary works to prepare the main site and build a temporary jetty for the delivery of bulk materials. If permission for the power station is not obtained, we will be required to reinstate the land. What are your views on our plans for preliminary works?

3.2.75 As Table 3.29 shows, of the 541 people who completed the questionnaire, 219 respondents (41%) were satisfied and 192 respondents (35%) were dissatisfied with EDF Energy’s plans for preliminary works at Stage 2.





Responses All

respondents

Valid postcode

in area

Outside

mapped area

or no valid

postcode

Percentage of

Responses

Satisfied 219 201 18 41%

Not satisfied 192 182 10 35%

Don’t know 11 11 0 2%

No opinion 119 103 16 22%

Total 541 497 44 100%



with a Valid

Postcode in the

Area

Percentage of

Responses


Cannington 79 15%

Shurton, Burton And Stogursey 74 14%




Watchet, Williton, Donisford And Sampford Brett 24 4%

Burnham-On-Sea And Highbridge 18 3%


Taunton Area 13 3%

Minehead 12 2%

Between Bristol And Burnham-On-Sea (Including Weston-Super-Mare, North Somerset, Rural Parts Of North Sedgemoor And Parts Of Mendip)

3 1%

Bristol Area 2 1%

Total 497 100%






3.2.76 As illustrated in the map (Figure 3.12), respondents in the Stogursey and Otterhampton areas were more dissatisfied than satisfied with the proposals for preliminary works. In Cannington and Nether Stowey, respondents were almost equally split between those that were satisfied and dissatisfied with the proposals and, in the majority of the other areas mapped, more respondents were satisfied than dissatisfied.

3.2.77 Respondents living nearest the site (Shurton, Burton and Stogursey) were more dissatisfied than satisfied with the proposals. Of the 74 people in that area that responded to the questionnaire 41 respondents (55%) thought the proposals were unsatisfactory, whilst 22 respondents (30%) thought they were satisfactory. The remaining 11 respondents (15%) from the area either did not know or did not express an opinion (see Table 3.30).

c) Questionnaire Responses – Accommodation

3.2.78 Questions at Stage 1 and 2 invited people to comment on EDF Energy’s proposed accommodation strategy and on the search areas and site-specific proposals on-site at Cannington, at Williton and at Bridgwater.

i. Stage 1

3.2.79 The Stage 1 questionnaire included question 4, which covered both transport and accommodation. The second part of this question is therefore covered in this




section. The questionnaire goes on to ask specifically about the accommodation-related search areas.

3.2.80 Of the six proposals for workers’ accommodation during construction, the most popular options were (the percentage represents those that were in favour):

• On-site campus 71%;

• Bridgwater campuses 65%;

• Use of existing accommodation 58%; and

• Cannington College 45%.

3.2.81 Although these four were the most popular generally, the on-site campus received support from just 3% of those from the area closest to the site (Shurton, Burton and Stogursey).

3.2.82 The Bridgwater campuses and use of existing accommodation received wide support, including from those living in Bridgwater.

3.2.83 The least popular options for accommodation were (the percentage represents those that were in favour):

• Williton 21%; and

• South Cannington 30%.

3.2.84 The option for a campus at Williton was the least popular, with 60% of people opposed to it; almost half of these were from the area closest to the site (Watchet/Williton area).

Stage 1 – Question 4(b): What is your view on EDF Energy’s initial proposals for managing accommodation during the construction phase?

3.2.85 As Table 3.31 shows, 373 of those that responded to the questionnaire completed this question. Of those, 75 respondents (20%) were satisfied or very satisfied with EDF Energy’s overall accommodation strategy for the construction of the proposed new nuclear power station at Hinkley Point C, but the majority of respondents, 265 (71%), were not very satisfied or not satisfied at all. The remaining 33 were neither satisfied nor dissatisfied or did not know. 99 respondents did not answer the questionnaire.


Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses




5 4 1 1%




Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses



Don’t know 28 21 7 8%


Total 472 383 89 100%

3.2.86 The majority of respondents to this question came from the search areas that EDF Energy was considering. Just over half (51%) were from the Watchet/Williton area and Cannington. Although search areas were also identified in Bridgwater, only 9% of respondents were from the Bridgwater area (6% from Bridgwater Central, 2% from Bridgwater South and 1% from Bridgwater North) – see Table 3.32.

3.2.87 There was also a relatively high level of interest in the accommodation strategy from people living in Otterhampton (11%) and those living in Shurton, Burton and Stogursey (10%).

Table 3.32: Areas of Respondents to Stage 1, Question 4(b) (Valid Postcode in Area Only)


a Valid Postcode in

the Area

Percentage of

Responses


Cannington 95 25%




Nether Stowey 20 5%


Bristol area 13 3%


10 3%


Minehead 6 2%

Taunton area 6 2%


Total 383 100%






3.2.88 From Figure 3.13, it is evident that the majority of respondents in the mapped areas

were more dissatisfied than satisfied with EDF Energy’s accommodation proposals. The main areas in which respondents were most evenly split in their views were in Nether Stowey, Bridgwater Central, Bridgwater South and the areas between Bristol and Burnham-on-Sea.

Stage 1 - Question 6: We are proposing a mix of solutions for accommodating construction workers. Please indicate your preferences.

(i): Temporary campus on-site for up to 700 workers

3.2.89 As Table 3.33 shows, 369 of those who completed the questionnaire answered this question. Almost three quarters, 261 respondents (71%), were in favour of an on-site campus. Only 82 respondents (22%) were not in favour of an on-site campus, whilst 26 respondents (7%) were undecided.





Responses All

Respondents

Valid Postcode

in Area

Outside

Mapped Area

or No Valid

Postcode

Percentage of

Responses

In favour 261 237 24 71%

Not in favour 82 70 12 22%

Don’t know 26 19 7 7%


Total 472 388 84 100%

3.2.90 As can be seen from Table 3.34, of the 388 respondents whose comments have been mapped, the majority were from Watchet/Williton (26%), Cannington (25%), Otterhampton (46%) and those living in Shurton, Burton and Stogursey (10%).




with a Valid

Postcode in the

Area

Percentage of

Responses


Cannington 95 25%




Nether Stowey 22 6%


Bristol area 13 3%


9 2%


Taunton area 7 2%


Minehead 5 1%

Total 388 100%






3.2.91 As can clearly be seen from Figure 3.14, the majority of respondents from almost

every area mapped were in favour of EDF Energy’s proposals for an on-site workers campus.

3.2.92 The clear exception was from those living closest to the proposed Hinkley Point C development site, where the majority of respondents were opposed to proposals for an on-site campus. Of the 39 respondents from the Shurton, Burton and Stogursey area, 32 (82%) were not in favour of the proposals.

3.2.93 Of those respondents not in favour of the on-site campus, 39% were from the Shurton, Burton and Stogursey area. The majority of the other respondents not in favour of an on-site campus came from the Cannington area (13 respondents, 16%) and Bridgwater Central (5 respondents, 6%). Of the 82 respondents to this question who were not in favour, 12 (15%) were either outside the mapped area or did not supply a valid postcode.

Stage 1 – Question 6(ii): Campus accommodation on a site to the south of Cannington for up to 200 workers with potential long-term legacy uses including student accommodation, hotel or other:

3.2.94 As Table 3.35 shows, of the 364 respondents who answered the question, the majority (195 or 54%) were not in favour of a campus to the south of Cannington, with 111 (30%) in favour.





Responses All

Respondents

Valid Postcode

in Area

Outside

Mapped Area

or No Valid

Postcode

Percentage of

Responses

In favour 111 96 15 30%

Not in favour 195 175 20 54%

Don’t know 58 47 11 16%


Total 472 380 92 100%

3.2.95 A quarter of respondents (25%) were from the area closest to the proposed campus site (Cannington), whilst the remaining respondents (75%) were from areas further removed from the proposals (see Table 3.36).

Table 3.36: Area of Respondents to Stage 1, Question 6(ii)



with a Valid

Postcode in the

Area

Percentage of

Responses


Cannington 95 25%




Nether Stowey 21 6%


Bristol area 13 3%


9 2%


Taunton area 7 2%

Minehead 6 1%


Total 380 100%






3.2.96 As can be seen from Figure 3.15, of the 54% of respondents not in favour of a

workers’ campus south of Cannington, the majority (58%) came from the Cannington and Otterhampton areas. Of the 380 respondents mapped, 175 were not in favour of the proposals, with the majority of those from Cannington and Otterhampton.

3.2.97 Respondents from Bridgwater Central, Nether Stowey and the Stogursey area split almost 50:50 in favour: not in favour of the proposals, whilst the majority in Williton were in favour of a workers campus south of Cannington (37 in favour: 23 not in favour).

Stage 1 – Question 6(iii): Additional campus accommodation at Cannington College for up to 120 workers, for long-term benefits to the College

3.2.98 As Table 3.37 shows, 366 of those who completed the questionnaire answered this

question. Of those that responded, 45% were in favour of EDF Energy’s proposals for additional campus accommodation at Cannington College, 39% were not in favour and 16% were undecided.

3.2.99 Of the two Cannington accommodation proposal options consulted on at Stage 1, Cannington College received a greater level of favour than the site south of Cannington.





Responses All

Resp

onde

nts

Valid Postcode

in Area

Outside Mapped Area


Percentage of

Responses

In favour 164 139 25 45%

Not in favour 144 131 13 39%

Don’t know 58 50 8 16%

Question Unanswered

106 62 44 N/A

Total 472 382 90 100%

3.2.100 As with the previous question relating to the campus accommodation in the Cannington area, 25% of respondents were from Cannington (see Table 3.38).




with a Valid

Postcode in the

Area

Percentage of

Responses


Cannington 94 25%




Nether Stowey 21 5%


Bristol area 13 3%


9 2%


Minehead 6 2%

Taunton area 6 2%


Total 382 100%





(Valid Postcode In Area Only)

3.2.101 As can be seen from Figure 3.16 above, those in the mapped area were marginally

more in favour (139 respondents) of the proposals than those not in favour (131 respondents).

3.2.102 Of the 139 respondents in favour of the Cannington College accommodation proposals, the majority came from Watchet/Williton (43 respondents, 31%), the Shurton, Burton and Stogursey area (22 respondents, 16%), Nether Stowey (11 respondents, 8%) and Bridgwater Central (11 respondents, 8%).

3.2.103 In Otterhampton, an equal number of respondents were and were not in favour of the proposals (19 respondents for each).

3.2.104 The majority of the 131 mapped respondents who were not in favour of these proposals came from the Cannington area (63 respondents, 48%).




Stage 1 – Question 6(iv): Campus accommodation at Williton for up to 200 workers, with the potential for long-term legacy benefits including a care home, hotel or other

3.2.105 As Table 3.39 shows, 378 of those who completed the questionnaire answered this question. Just over a fifth of respondents (21%) were in favour of the proposals for campus accommodation at Williton, whilst nearly three quarters (74%) were not in favour.

Table 3.39: Responses to Stage 1, Question 6(iv)

Responses All

Respondents

Valid Postcode

in Area

Outside

Mapped Area

or No Valid

Postcode

Percentage of

Responses

In favour 79 67 12 21%

Not in favour 226 210 16 59%

Don’t know 73 60 13 20%


Total 472 399 73 100%

3.2.106 Respondents in the Watchet/Williton area provided the most responses to this question, with nearly 30% living in the area closest to the proposed Williton campus site (see Table 3.40).

Table 3.40: Area of Respondents to Stage 1, Question 6(iv)



a Valid Postcode in

the Area

Percentage of

Responses


Cannington 93 23%




Nether Stowey 23 6%


Bristol area 13 3%


9 2%


Taunton area 7 2%

Minehead 6 1%


Total 399 100%




Figure 3.17: Map Illustrating Responses to Stage 1, Question 6(iv)


3.2.107 As can be seen from Figure 3.17, the majority of respondents from the mapped areas were not in favour of the proposed campus in Williton. Just over three quarters of respondents not in favour of the proposals came from the Watchet/Williton area (93 respondents, 44%), Cannington (47 respondents, 22%) and the Shurton, Burton and Storgursey area (22 respondents, 10%).

3.2.108 Of the 116 people in the Watchet/Williton area who returned the questionnaire, 93 respondents were not in favour, 18 respondents did not know or did not answer the question and only 5 respondents were in favour of the proposed campus in Williton.

Stage 1 – Question 6(v): Accommodation for up to 500 workers at one of several campuses in Bridgwater, with potential long-term legacy uses, including student accommodation, hotel or other

3.2.109 As Table 3.41 shows, 364 of those who completed the questionnaire answered this question. Of those who expressed a view (in favour or not in favour) on EDF Energy’s proposals for worker accommodation in one or several locations in Bridgwater, more than three quarters (235 respondents, 77%) were in favour, whilst just under a quarter (71 respondents, 23%) were not in favour.




Table 3.41: Responses to Stage 1, Question 6(v)

Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

In favour 235 209 26 65%


Don’t know 58 48 10 15%

Question unanswered

108 62 46 N/A

Total 472 381 91 100%

3.2.110 As can be seen from Table 3.42, only 36 respondents (9%) to the Stage 1 question on worker accommodation in Bridgwater were from the Bridgwater area (central, south or north).

Table 3.42: Area of Respondents to Stage 1, Question 6(v)



a Valid Postcode in

the Area

Percentage of

Responses


Cannington 95 25%




Nether Stowey 20 5%


Bristol area 13 4%


9 2%


Taunton area 7 2%

Minehead 6 2%


Total 381 100%




Figure 3.18: Map Illustrating Responses to Stage 1, Question 6(v)


3.2.111 As can be seen from Figure 3.18, the majority of respondents in all areas (with the

exception of those in the area between Bristol and Burnham-on-Sea) were in favour of EDF Energy’s proposals for 500 workers to be accommodated in the Bridgwater area, with the highest percentage of support coming from those living in the Bridgwater North and Shurton, Burton and Stogursey area.

3.2.112 In the Bridgwater areas, twice as many respondents (18) were in favour as those respondents (9) not in favour of these accommodation proposals.

Stage 1 – Question 6(vi): Use of existing owner-occupied and privately rented accommodation, including guesthouses and caravan parks

3.2.113 As Table 3.43 shows, 369 of those who completed the questionnaire answered this question. Of those that expressed an opinion (in favour or not in favour), 215 respondents (70%) were in favour of EDF Energy using existing owner-occupied and privately rented accommodation during the construction period.




Table 3.43: Responses to Stage 1, Question 6(vi)

Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

In favour 215 208 7 58%


Don’t know 60 49 11 17%

Question Unanswered

103 62 41 N/A

Total 472 407 65 100%

Table 3.44: Areas of Respondents to Stage 1, Question 6(vi)



a Valid Postcode in

the Area

Percentage of

Responses


Cannington 94 23%




Nether Stowey 20 5%


Bristol area 13 3%


10 3%


Taunton area 7 2%

Minehead 6 0.5%


Total 407 100%

3.2.114 As can be seen from Table 3.44 and Figure 3.19, the majority of respondents in the mapped areas were in favour of EDF Energy’s proposal to use existing owner-occupied and privately rented accommodation, with the main areas of support for this proposal coming from the Stogursey and Cannington areas.




Figure 3.19: Map Illustrating Responses to Stage 1, Question 6(vi)


ii. Stage 2

3.2.115 Feedback from Stage 1 further shaped the accommodation strategy, and consequently the ‘Preferred Proposals’ for providing accommodation for workers during construction. Views and comments were sought on EDF Energy’s preferred accommodation strategy and sites through the Stage 2 consultation questionnaire. In Question 4, respondents were asked to comment on the overall Accommodation Strategy. Question 9 then asked people to comment on the individual sites.

3.2.116 With both the overall Accommodation Strategy and individual sites, the highest level of response came from the combined Bridgwater area, Otterhampton, Cannington and Shurton, Burton and Stogursey areas.

3.2.117 As will be seen from the responses to the three site-specific accommodation proposals, there were mixed views about the proposals, largely reflecting the proximity of respondents to the sites on which EDF Energy was consulting. Nonetheless, a higher percentage of respondents were satisfied than dissatisfied with all three proposals.

Stage 2 – Question 4: We intend to maximise the use of local workers to build the power station but we still expect between 3,000 and 3,500 workers at peak to require short-term accommodation because they currently do not live locally. These workers will be accommodated in a mixture of rented and owner-occupied accommodation, bed and breakfast and caravan parks. We are also proposing purpose-built accommodation campuses;




two in Bridgwater and one on the Hinkley Point C site. What are your views on our overall accommodation strategy?

3.2.118 As Table 3.45 shows, 430 people who responded to the questionnaire answered this

question. 161 respondents (30%) were satisfied with the overall accommodation strategy at Stage 2. This shows a slight increase in the number of respondents that were very satisfied or satisfied with EDF Energy’s accommodation proposals at Stage 1 (75 respondents, 20%).

3.2.119 In comparison, 262 respondents were dissatisfied with EDF Energy’s accommodation strategy at Stage 2. This is a marginally lower number than the 265 respondents that were not very satisfied or not at all satisfied with EDF Energy’s proposals at Stage 1. However, as a higher number of questionnaires were completed for the Stage 2 consultation, the percentage of those dissatisfied with the accommodation proposals at Stage 2 was 48%, whereas 71% were dissatisfied at Stage 1.


Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses



Don’t know 7 5 2 1%

No opinion/ Question Unanswered

111 96 15 21%

Total 541 497 44 100%

3.2.120 As reflected in Table 3.46, the majority of respondents to the Stage 2 consultation were located in the areas in which EDF Energy’s accommodation proposals were concentrated: Bridgwater (Central, South and North), Otterhampton, Cannington and Shurton, Burton and Stogursey. The number of respondents to the Stage 2 proposals from the Watchet/Williton area decreased significantly from those that participated at Stage 1, when Williton was being considered for an accommodation campus.




a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%








a Valid Postcode in

the Area

Percentage of

Responses




Taunton area 13 2.5%


Minehead 12 2%


3 0.5%

Bristol area 2 0.5%

Total 497 100%


3.2.121 As can be seen in Figure 3.20, the majority of those dissatisfied with the

accommodation strategy at Stage 2 were from the Stogursey area, Otterhampton, Nether Stowey and the Bridgwater areas.

3.2.122 In the Bridgwater area, of those who responded (satisfactory or unsatisfactory) to this question, 63 of the 103 respondents (61%) were dissatisfied with the Stage 2 accommodation strategy. Alternatively, if the Bridgwater area is broken down into Central, South and North, it is almost divided equally between those who are




satisfied and dissatisfied with the accommodation strategy in Bridgwater Central. In Bridgwater North, twice as many respondents were dissatisfied (8 respondents) as satisfied (4 respondents), and in Bridgwater South 30 out of the 42 respondents were dissatisfied (71%).

3.2.123 In the Shurton, Burton and Stogursey area, of those who responded, 59 of the 65 respondents (91%) were dissatisfied. Of those that responded, 34 out of 45 respondents (76%) from Nether Stowey and 43 out of 65 respondents (66%) in Otterhampton were dissatisfied with the proposals.

3.2.124 However, in Cannington and the Taunton area the majority were satisfied with EDF Energy’s accommodation strategy. In Cannington, 38 out of 62 respondents (61%) were satisfied, and in Taunton seven out of nine respondents (78%) were satisfied.

3.2.125 In the Watchet/Williton area, 14 people responded to the question and they were split equally, with seven respondents (50%) satisfied and seven respondents (50%) dissatisfied. This is a significant difference from at Stage 1, when five respondents were satisfied and 83 were dissatisfied.

Stage 2 – Question 9: We plan to accommodate between 1,080 and 1,925 non-local workers in accommodation campuses, depending upon the success of local recruitment and other factors. What are your views on our plans for accommodation campuses at the following locations?

Stage 2 – Question 9(i): Views on accommodation campus at the Bridgwater Innovia site, Bath Road (site BRI-A) for up to 1,075 places

3.2.126 As Table 3.47 shows, of those who responded ‘satisfactory’ or ‘unsatisfactory’ to this

question, 235 respondents (65%) were satisfied, whilst 129 respondents (35%) were dissatisfied.


Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses



Don’t know 21 19 2 3%


155 138 17 29%

Total 540 497 43 100%







a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%









Minehead 12 2%


3 0.5%

Bristol area 2 0.5%

Total 497 100%






3.2.127 As can be seen from Table 3.48 and Figure 3.21, the majority of the respondents

who expressed an opinion (satisfied or dissatisfied) in most of the mapped areas, with the exception of Bridgwater North and Bridgwater South, were satisfied with the proposals for the Innovia site in Bridgwater.

3.2.128 In Bridgwater South, 18 of the 32 respondents (56%) and in Bridgwater North, six of the 11 respondents were dissatisfied (55%) with the proposals for the Innovia site.

Stage 2 – Question 9(ii): Views on accommodation campus at the Bridgwater and Albion Rugby Football Club site, College Way (site Bri-C) for up to 150 places

3.2.129 As Table 3.49 shows, 358 people who responded via this questionnaire answered this question. Of those who responded ‘satisfactory’ or ‘unsatisfactory’ to the question, 202 respondents (60%) thought the proposals were satisfactory, whilst 136 (40%) thought they were unsatisfactory.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses



Don’t know 20 18 2 4%


183 162 21 34%

Total 541 497 44 100%

Table 3.50: Area of Respondents to Stage 2, Question 9(ii)



a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%









Minehead 12 2%


3 0.5%

Bristol area 2 0.5%

Total 497 100%






3.2.130 As can be seen from Figure 3.22, the majority of people in many of the areas mapped thought the proposals for the accommodation campus on the Bridgwater and Albion Rugby Football Club site were satisfactory. Those in Otterhampton were split exactly 50:50, with 27 respondents thinking the proposals were satisfactory and 27 respondents thinking they were unsatisfactory.

3.2.131 In Bridgwater Central and Bridgwater South, the majority of respondents were dissatisfied. In Bridgwater Central 25 of the 45 respondents were dissatisfied (56%) and in Bridgwater South 19 out of 31 respondents (61%) were dissatisfied.

3.2.132 Only 10 people in Bridgwater North responded to this question and, of those, six out of 10 (60%) were satisfied with the proposals.

Stage 2 – Question 9 (iii): Views on accommodation campus at the Hinkley Point C site for up to 700 places

3.2.133 As Table 3.51 shows, overall there were 397 responses to this question. Of these,

204 respondents (54%) thought that EDF Energy’s proposals for a 700-space on-site accommodation campus were satisfactory, whilst 172 respondents (46%) thought they were unsatisfactory.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses



Don’t know 21 19 2 4%


144 129 15 26%

Total 541 497 44 100%




a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%









Minehead 12 2%


3 0.5%

Bristol area 2 0.5%

Total 497 100%






3.2.134 As can be seen from Table 3.52 and Figure 3.23, the majority of those dissatisfied

with EDF Energy’s proposals for a campus at the Hinkley Point C Development Site lived in the Shurton, Burton and Stogursey area, Nether Stowey and Otterhampton. Of the 162 mapped respondents dissatisfied with the proposals, 61 respondents (38%) came from the Shurton, Burton and Stogursey area, 30 respondents (19%) were from Nether Stowey and 25 respondents (15%) were from Otterhampton.

3.2.135 Of those respondents that expressed a view in the Shurton, Burton and Stogursey area, approximately three quarters were dissatisfied with EDF Energy’s proposals for an on-site campus at the Hinkley Point C Development Site.

d) Questionnaire Responses – Transport

3.2.136 The questionnaires at Stages 1 and 2 invited people to comment on EDF Energy’s overall transport strategy before focusing on the options being considered. This section looks at the responses to the quantitative questions. An overview of the qualitative responses can be seen in the relevant section of this chapter.

i. Stage 1

3.2.137 The Stage 1 questionnaire included Question 4, which covered both transport and accommodation. The first part of this question dealt with transport. Additionally, at Stage 1 a number of questions were asked on specific transport-related sites.




3.2.138 Of the areas EDF Energy consulted on for a freight handling facility, respondents’ preferences were as follows:

• at Combwich Wharf (66% favoured); and

• on the outskirts of Bridgwater, north - near Junction 23 of the M5 (56% favoured) and south – near Junction 24 of the M5 (21% favoured).

3.2.139 The Cannington freight handling facility was clearly unpopular, with 67% opposed to either site. Those who did express an opinion were fairly evenly split with 18% supporting the north-west site and 15% supporting the south site.

Stage 1 – Question 4a: What is your view on EDF Energy’s initial proposals for managing transport during the construction phase?

3.2.140 As Table 3.53 shows, 380 of those that submitted a questionnaire completed this question, of which 81 respondents (22%) were satisfied or very satisfied with EDF Energy’s Initial Proposals and Options for its overall transport strategy for the construction and operation of a new nuclear power station at Hinkley Point C. In contrast, 271 respondents (71%) were not satisfied or not at all satisfied with EDF Energy’s Initial Proposals and Options for its transport strategy.


Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses




4 4 0 1%

Not satisfied 66 53 13 17%


Don’t know 24 19 5 6%

Question Unanswered

92 52 40 N/A

Total 472 384 88 100%







a Valid Postcode in

the Area

Percentage of

Responses


Cannington 95 25%




Nether Stowey 20 5%


Bristol area 13 3%


10 3%


Taunton area 6 2%


Minehead 5 1%

Total 384 100%






3.2.141 As can be seen in Table 3.54 and Figure 3.24, the majority of people in the areas

mapped thought that EDF Energy’s overall transport strategy at Stage 1 was not satisfactory or not at all satisfactory. The highest level of respondents dissatisfied with the proposals was from the Watchet/Williton area, with 83 out of 101 respondents (82%) dissatisfied and Cannington, with 70 out of 95 respondents (74%) dissatisfied.

Stage 1 – Question 5: We are planning a bypass for Cannington. Do you think the road is needed? If so, should it go to the east or the west of the village?

3.2.142 As can be seen from Table 3.55, 335 of those who submitted a questionnaire

completed this question. Of those, only 53 respondents (16%) did not believe a bypass at Cannington was required.

3.2.143 Of those who responded to this question, 121 (36%) expressed a preference for a bypass to the east of the village, whereas 69 respondents (21%) preferred the western bypass option.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

East of the village 121 110 11 36%

West of the village 69 55 14 21%

Not required 53 43 10 16%

Don’t know 92 83 9 27%

Question Unanswered

137 79 58 N/A

Total 472 370 102 100%

3.2.144 As can be seen in Table 3.56, of those respondents with a valid postcode in the mapped area, nearly a quarter of respondents to this question (24%) came from the area nearest the proposed bypass (Cannington).




a Valid Postcode in

the Area

Percentage of

Responses


Cannington 89 24%


Shurton, Burton and Stogursey 39 10.5%


Nether Stowey 21 5.5%


Bristol area 13 4%


10 3%


Minehead 6 1.5%

Taunton area 6 1.5%


Total 370 100%






3.2.145 As illustrated in Figure 3.25, of the 89 respondents from Cannington, 18 (20%) felt

that a bypass was not required, 15 respondents (17%) thought the bypass should go to the west of the village and 30 respondents (34%) thought the bypass should go to the east of the village. 16 respondents (18%), did not answer the question, and 10 respondents (11%) did not know.

Stage 1 – Question 7: What are your views on the four locations EDF Energy is proposing for the new park and ride sites? Please indicate your preferences below and with reference to the maps

Stage 1 – Question 7(a): Views on a park and ride site at Cannington

3.2.146 As can be seen from Table 3.57, 323 of those who completed the questionnaire

answered this question. Of those, 67 respondents (21%) would have preferred to have seen a park and ride to the south of Cannington, 61 respondents (19%) would have preferred to have seen a park and ride to the north-west of the village and 195 (60%) did not prefer either option.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

To the south of the village and adjacent to the proposed workers campus

67 60 7 21%

To the north-west of the village

61 41 20 19%

Neither 195 180 15 60%

Question Unanswered

149 95 54 N/A

Total 472 376 96 100%

3.2.147 As can be seen from Table 3.58, the largest percentage of respondents to this question (28%) came from the Cannington area.




a Valid Postcode in

the Area

Percentage of

Responses

Cannington 104 28%





Nether Stowey 20 5%


Bristol area 14 4%


9 2%


Minehead 6 2%

Taunton area 6 2%


Total 376 100%






3.2.148 As can be seen in Figure 3.26, the majority of respondents in the mapped areas

favoured neither of the two options for the park and ride at Cannington. Of those that did express a preference, the majority favoured the southern option, with the exception of residents of Nether Stowey and Otterhampton, who marginally favoured the north-west option.

3.2.149 Of the respondents from the Cannington area, 13 respondents (13%) favoured the site to the south, 11 respondents (11%) favoured the site to the north-west and 68 respondents (65%) favoured neither.

Stage 1 – Question 7(b): Views on a park and ride site near Junction 24 of the M5 on the southern outskirts of Bridgwater

3.2.150 As can be seen from Table 3.59, of the 286 respondents who answered this

question, 94 (33%) did not favour any of the sites.

3.2.151 Of those who expressed a preference, the most popular site was Location C (27%), closely followed by Location B (23%). Location A was the least popular of the three options (17%).

3.2.152 A third of people who submitted a questionnaire did not want a park and ride at any of the three proposed sites at Junction 24 of the M5.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

Location A – south west of Junction 24

49 42 7 17%

Location B – south east of Junction 24

66 56 10 23%

Location C – north east of Junction 24

77 66 11 27%

None of these 94 84 10 33%

Question Unanswered

186 95 91 N/A

Total 472 343 129 100%




a Valid Postcode in

the Area

Percentage of

Responses

Cannington 91 27%





Nether Stowey 17 5%


Bristol area 14 4%


8 2.5%


Minehead 6 2%

Taunton area 6 2%


Total 343 100%






3.2.153 As illustrated by Table 3.60 and Figure 3.27, site popularity varied between the

geographical areas. In Watchet/Williton and Bridgwater Central, Location B was the most favoured option. However, in Shurton, Burton and Stogursey, Nether Stowey, Otterhampton and Cannington, Location C was the preferred option.

3.2.154 For those living nearest the site (Bridgwater South), Location A and C were equally popular, whilst no respondents opted for Location B.

Stage 1 – Question7(c): Views on a park and ride site near Junction 23 of the M5 on the northern outskirts of Bridgwater

3.2.155 As can be seen from Table 3.61, 288 of those who completed a questionnaire answered this question. Of those, nearly a quarter (24%) did not favour either option.

3.2.156 Of those who expressed a preference for the location of a park and ride facility at Junction 23 of the M5, 154 respondents (54%) favoured Option 1, the site north of the Dunball roundabout and 64 respondents (22%) favoured Option 2, the side south of Dunball roundabout.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

Option 1 – north of Dunball roundabout

154 136 18 54%

Option 2 – south of Dunball roundabout

64 52 12 22%

Neither 70 61 9 24%

Question Unanswered

184 95 89 N/A

Total 472 344 128 100%

Table 3.62: Area of Responses to Stage 1, Question 7(c)



a Valid Postcode in

the Area

Percentage of

Responses

Cannington 89 26%



Shurton, Burton and Stogursey 29 8.5%


Nether Stowey 17 5%


Bristol area 14 4%


9 3%


Taunton area 6 2%

Minehead 5 1%


Total 344 100%






3.2.157 As can be seen from Table 3.62 and Figure 3.28, the majority of respondents in the

areas mapped favoured Option 1. Only five completed questionnaires were received from the Bridgwater North area (closest to Junction 23 of the M5). Of those, four respondents (80%) favoured Option 1.

Stage 1 – Question 7(d): Views on a park and ride site at Williton


answered this question. Of those, 233 respondents (72%) did not favour a park and ride to the west or east of Williton.

3.2.159 Of the 93 respondents who favoured the site to the west or east of Williton, 44 respondents (13%) favoured the west and 49 respondents (15%) favoured the east.




Table 3.63: Responses to Stage 1, Question 7(d)

Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

To the west of Williton

44 35 9 13%

To the east of Williton

49 34 15 15%

Neither 233 219 14 72%

Question Unanswered

146 95 51 N/A

Total 472 383 89 100%

Table 3.64: Area of Respondents to Stage 1, Question 7(d)



a Valid Postcode in

the Area

Percentage of

Responses


Cannington 83 22%




Nether Stowey 19 5%


Bristol area 14 4%


8 2%


Minehead 8 2%

Taunton area 5 1.5%


Total 383 100%




Figure 3.29: Map Illustrating Responses to Stage 1, Question 7(d)


3.2.160 As can be seen from Table 3.64 and Figure 3.29, the majority of those who

responded to this question did not favour either of the proposed sites for a park and ride at Williton.

3.2.161 Of the 128 people in the Williton/Watchet area who completed the questionnaire, 80 respondents did not support a park and ride at Williton, 14 respondents favoured the site to the west of Williton, 5 respondents favoured the site to the east of Williton and 29 did not answer the question.

3.2.162 Of those who did express a preference for the west or east option, there were differences depending on the geographical location of respondents. In Watchet/Williton, Nether Stowey and Bridgwater (Central and South) the site to the west of Williton was favoured. However, in the Shurton, Burton and Stogursey area, Otterhampton, Cannington and Bridgwater North, the east option was preferred.




Stage 1 – Question 8: What are your views on proposed freight handling facilities adjacent to some of the proposed park and ride sites and at Combwich? Please indicate your preferences below and with reference to the maps

Stage 1 – Question 8(a): Views on freight handling facilities on the outskirts of Bridgwater

3.2.163 The questionnaire invited respondents to indicate a preference between two possible sites for a freight handling facility on the outskirts of Bridgwater at Junction 23 of the M5 and at Junction 24 of the M5.


answered this question. Of those, 66 respondents (23%) did not support either of the options.

3.2.165 Of the 283 people who answered this question, 158 (56%) preferred the site to the north at Junction 23 of the M5, 59 (21%) preferred the site to the south at Junction 24 of the M5 and 66 (23%) did not support either site.


Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

North – near Junction 23 of the M5

158 141 17 56%

South – near Junction 24 of the M5

59 45 14 21%

Neither 66 57 9 23%

Question Unanswered

189 105 84 N/A

Total 472 348 124 100%




a Valid Postcode in

the Area

Percentage of

Responses

Cannington 88 25%





Nether Stowey 17 5%


Bristol area 14 4%





a Valid Postcode in

the Area

Percentage of

Responses


9 3%


Minehead 6 2%

Taunton area 6 2%


Total 348 100%



3.2.166 As can be seen from Table 3.66 and Figure 3.30, when asked to choose between a

freight handling facility at Junction 23 or Junction 24 of the M5, the largest percentage of respondents in the combined Bridgwater area expressed a preference for Junction 23.

3.2.167 In general, Junction 23 had the highest preference level, with the exception of the Bristol area and the area between Bristol and Burnham-on-Sea.




Stage 1 – Question 8(b): View on freight handling facilities near Cannington

3.2.168 As can be seen from Table 3.67, 314 of those who responded to the questionnaire answered this question. In respect of EDF Energy’s proposals for a freight handling facility at Cannington, just over two thirds (67%) of respondents favoured neither site.

3.2.169 Of those who expressed a preference, 58 respondents (18%) preferred the site to the north-west of the village adjacent to the C182 and 45 respondents (15%) preferred the site to the south of the village adjacent to the A39.


Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

North-west of the village adjacent to the C182

58 45 13 18%

South of the village adjacent to the A39

45 34 11 15%

Neither 211 194 17 67%

Question Unanswered

158 105 53 N/A

Total 472 378 94 100




a Valid Postcode in

the Area

Percentage of

Responses

Cannington 103 27%

Watchet, Williton, Donisford and Sampford Brett 85 22.5%




Nether Stowey 20 5%

Bristol area 14 4%

Burnham-on-Sea and Highbridge 13 3.5%


9 2.5%


Minehead 6 2%

Taunton area 6 2%


Total 378 100%






3.2.170 Table 3.68 and Figure 3.31 illustrate that the majority of respondents in the mapped

areas favoured neither of the Cannington freight handling facility options.

3.2.171 Of those who expressed a preferred site, there was a fairly even split between the two sites, with some variance of opinion within the different geographical areas. For example, in Bridgwater Central the site to the south of the village was the preference. However, in Bridgwater North and Bridgwater South the site to the north-west of the village found more favour.

Stage 1 – Question 8 (c): Views on freight handling facilities at Combwich Wharf

3.2.172 As can be seen from Table 3.69, 317 of those who completed the questionnaire answered this question. Two thirds of respondents (66%) were in favour of a freight handling facility at Combwich Wharf, whilst the other third (34%) were not.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

In favour 210 184 26 66%


Question Unanswered

155 105 50 N/A

Total 472 380 92 100%

Table 3.70: Area of Respondents to Stage 1, Question 8(c)



a Valid Postcode in

the Area

Percentage of

Responses

Cannington 98 26%





Nether Stowey 22 6%

Bristol area 14 4%



9 2%


Minehead 6 1.5%

Taunton area 6 1.5%


Total 380 100%






3.2.173 As can be seen from Table 3.70 and Figure 3.32, the majority of respondents in the

mapped areas were in favour of a freight handling facility at Combwich. Of the 45 respondents living closest to the site (in Otterhampton), 23 (51%) were in favour of the proposals, 15 respondents (33%) were not in favour of the proposals and seven respondents (16%) did not answer the question.

ii. Stage 2

3.2.174 By Stage 2, EDF Energy had analysed feedback from Stage 1 and undertaken further traffic assessments and site-specific research in order to consult on its ‘Preferred Proposals’. As at Stage 1, the Stage 2 questionnaire invited comments on EDF Energy's overall transport strategy before looking at site-specific proposals.

Stage 2 – Question 5: The construction of the power station will increase traffic movements over a prolonged, but temporary, period of time. Our approach to managing this is to provide park and ride and freight logistics facilities so that traffic can be accommodated within the capacity of the existing highway network. What are your views on the overall transport strategy?

3.2.175 As can be seen from Table 3.71, of the 478 people who answered this question, 22%

of respondents were satisfied with the transport proposals, while 65% of respondents were dissatisfied with the proposals.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses



Don’t know 8 6 2 1%


63 51 12 12%

Total 541 497 44 100%

3.2.176 As with the Development Site and accommodation strategies, the change in the number of respondents in each area from Stage 1 to Stage 2 largely reflects the changes in EDF Energy’s proposals.

3.2.177 For example, at Stage 1, 42 (11%) respondents from the Otterhampton/Combwich area answered the transport strategy question. At Stage 2, this increased to 93 respondents (19%) answering the transport strategy question (see Table 3.72).

3.2.178 Similarly, at Stage 1, there were 38 respondents (10%) from Bridgwater Central, Bridgwater North and Bridgwater South. At Stage 2 this increased, with 128 respondents (25.5%) answering the transport strategy question.

3.2.179 By contrast, the number of respondents from Cannington went down from 95 respondents (25%) at Stage 1 to 79 respondents (16%) at Stage 2.

3.2.180 The most marked reduction in response in relation to EDF Energy’s overall transport strategy was from the Watchet/Williton area. At Stage 1 more than a quarter of respondents (101 respondents, 26%) came from the Watchet/Williton area. However, at Stage 2 this had gone down to just 24 respondents (5%).




a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%












a Valid Postcode in

the Area

Percentage of

Responses


Minehead 12 2%


3 0.5%

Bristol area 2 0.5%

Total 497 100%



3.2.181 As can be seen by Figure 3.33, the majority of people in the mapped areas closest the Hinkley Point C Development Site and associated development sites were dissatisfied with EDF Energy’s transport strategy.




Stage 2 – Question 6: Although the levels of traffic anticipated could be accommodated within existing road capacity, we believe that particular considerations apply to Cannington which will see the greatest change in traffic flows and that a bypass would be beneficial. We consider that a western bypass for Cannington is the best option because it is the shortest route, can be built quickly (with less environmental impact than the eastern option) and will affect fewer properties. Do you agree with EDF Energy’s view that a Cannington western bypass should be provided?

3.2.182 As can be seen from Table 3.73, of the 431 respondents who answered this question, 215 respondents (40%) agreed with EDF Energy’s proposals for a western bypass to Cannington and 200 respondents (37% disagreed).


Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses

Agree 215 198 17 40%

Disagree 200 188 12 37%

Don’t know 16 14 2 3%


110 97 13 20%

Total 541 497 44 100%




a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%








Taunton area 13 3%

Minehead 12 2%


3 0.5%

Bristol area 2 0.5%

Total 497 100%






3.2.183 As can be seen in Table 3.74 and Figure 3.34, in most of the areas mapped more people agreed than disagreed with the proposals. The only exceptions to this were in Cannington, Otterhampton and the Bristol area.

3.2.184 In Cannington, of the 79 people who responded to the question, 42 respondents (53%) disagreed, 28 respondents (35%) agreed and nine respondents (12%) did not express an opinion on a western bypass for Cannington.

3.2.185 Similarly in Otterhampton, of the 93 people that responded to the question, 55 respondents (59%) disagreed, 24 respondents (26%) agreed and 14 respondents (15%) did not express an opinion.

Stage 2 – Question 7: We propose a park and ride facility on the A39, south of Cannington, for visitors to the main site and workers from Bridgwater and other nearby settlements, so they can leave their cars and transfer to buses to Hinkley Point. The park and ride facility would be removed when no longer required. What are your views on our plans for a temporary park and ride facility at Cannington?

3.2.186 As can be seen from Table 3.75, of the respondents who expressed a view (satisfied or unsatisfied) on EDF Energy’s proposals for a temporary park and ride facility at Cannington, 187 respondents (35%) were satisfied with the proposal and 222 respondents (41%) were dissatisfied.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses



Don’t know 14 14 0 2%


118 102 16 22%

Total 541 497 44 100%




a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%









Minehead 12 2%


3 0.5%

Bristol area 2 0.5%

Total 497 100%






3.2.187 As can be seen from Table 3.76 and Figure 3.35, in the Shurton, Burton and Stogursey area, Bridgwater Central, Burnham on Sea, the Bristol to Burnham-on-Sea area, Watchet/Williton and Bridgwater North more people that responded to the proposals were satisfied than dissatisfied.

3.2.188 However, in Nether Stowey, Cannington, Otterhampton, Bridgwater South and Bristol more people were dissatisfied than satisfied.

Stage 2 – Question 8: We propose a park and ride facility on the A39, west of Williton, for workers from Minehead and other nearby settlements to leave their cars and transfer to buses to Hinkley Point. The park and ride facility would be removed when no longer required. What are your views on our plans for a temporary park and ride facility at Williton?

3.2.189 As can be seen from Table 3.77, the 363 respondents who answered this question

found the proposals satisfactory or unsatisfactory. Of these, 153 (28%) thought the proposed park and ride facility on the A30 west of Williton was satisfactory and 175 respondents (32%) thought it was unsatisfactory.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses



Don’t know 35 33 2 7%


178 163 15 33%

Total 541 497 44 100%




a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%









Minehead 12 2%


3 1%

Bristol area 2 0.5%

Total 497 100%






3.2.190 As can be seen from Table 3.78 and Figure 3.36, in Watchet/Williton, the area

closest to the proposed park and ride facility, 24 people responded to the questionnaire. Of those, 14 respondents (58%) thought the proposals were unsatisfactory, six respondents (25%) thought the proposals were satisfactory and four respondents (17%) did not express an opinion.

3.2.191 More respondents were dissatisfied than satisfied with the proposals in Stogursey, Nether Stowey, Otterhampton, Minehead and Bristol. In contrast, more respondents in Cannington, Bridgwater (Central, North and South), Burnham-on-Sea and Taunton were satisfied than dissatisfied with the proposals.

Stage 2 – Question 10: At Junction 23 of the M5 we are planning a park and ride facility for workers where they will be transferred to buses. A freight logistics facility is also proposed where freight could be consolidated and sent to Hinkley Point outside peak periods. After construction of the power station is complete, this site could be used to serve Bridgwater as a park and ride facility, employment-generating use or other appropriate land use. What are your views on our plans for the site near Junction 23 of the M5?

3.2.192 As can be seen from Table 3.79, of the 397 respondents who expressed a view (satisfied or unsatisfied), the majority of people (255 respondents, 64%) were satisfied with the proposal for a park and ride and freight logistics facility at Junction 23 of the M5. Just over a third (142 respondents, 36%) were dissatisfied with this proposal.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses



Don’t know 18 18 0 4%


126 112 14 23%

Total 541 497 44 100%




a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%









Minehead 12 2%


3 0.5%

Bristol area 2 0.5%

Total 497 100%






3.2.193 As can be seen from Table 3.80 and Figure 3.37, in most of the areas mapped,

more respondents thought that EDF Energy’s proposals for a park and ride facility and freight logistics facility at Junction 23 were satisfactory than those who thought that the proposals were unsatisfactory.

3.2.194 In Bridgwater Central, more people were satisfied with the proposals than were dissatisfied. Meanwhile, in Otterhampton, Bridgwater North and Bridgwater South, a similar number of people thought the proposals were satisfactory as unsatisfactory.

Stage 2 – Question 11: At Junction 24 of the M5 we are planning a park and ride facility for workers where they will be transferred to buses. A freight logistics facility is also proposed where freight could be consolidated and sent to Hinkley Point outside peak periods. After construction of the power station is complete, this site could be used to serve Bridgwater as a park and ride facility, employment-generating use or other appropriate land use. What are your views on our plans for the site near Junction 24 of the M5?

3.2.195 As can be seen from Table 3.81, of the 400 people who expressed a view (satisfactory or unsatisfactory) on EDF Energy’s proposals for a new park and ride facility and freight logistics facility at Junction 24 of the M5, 209 respondents (39%) thought the proposals were satisfactory and 191 respondents (35%) thought the proposals were unsatisfactory.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses



Don’t know 20 20 0 4%


121 105 16 22%

Total 541 497 44 100%




a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%









Minehead 12 2%


3 1%

Bristol area 2 0.5%

Total 497 100%






3.2.196 As can be seen from Table 3.82 and Figure 3.38, at every mapped location, with the

exception of Bridgwater South, Otterhampton and Bristol, more people thought that EDF Energy’s proposals for Junction 24 were satisfactory than unsatisfactory.

3.2.197 In Bridgwater South, of the 55 respondents who returned the questionnaire, 52 expressed a view (satisfactory or unsatisfactory). Of those, 47 respondents (85%) thought the Junction 24 proposals were unsatisfactory and five respondents (9%) that they were satisfactory.

3.2.198 In Otterhampton, 66 of the 93 respondents who returned the questionnaire expressed a view (satisfactory or unsatisfactory) on the Junction 24 proposals. Of those, 39 respondents (42%) were dissatisfied and 27 respondents (29%) were satisfied.

Stage 2 – Question 12: We plan to bring in as much of the construction material as possible by sea, including large components. What are your views on our proposals for furbishing Combwich Wharf and providing an associated freight logistics/storage area to assist this process?

3.2.199 As can be seen from Table 3.83, 414 respondents expressed a view (satisfactory or

unsatisfactory) for EDF Energy’s proposals to refurbish Combwich Wharf and provide an associated freight logistics/storage area. Of those, 248 (46%) thought that EDF Energy’s proposals were satisfactory and 166 (31%) that they were unsatisfactory.





Responses All

Respondents

Valid Postcode

in Area

Outside Mapped

Area or No Valid

Postcode

Percentage of

Responses



Don’t know 21 20 1 4%


106 93 13 19%

Total 541 497 44 100%




a Valid Postcode in

the Area

Percentage of

Responses


Cannington 79 16%









Minehead 12 2%


3 1%

Bristol area 2 0.5%

Total 497 100%






3.2.200 As can be seen from Table 3.84 and Figure 3.39, in almost every location mapped,

with the exception of Otterhampton, more respondents thought that EDF Energy’s proposals at Combwich were satisfactory than unsatisfactory.

3.2.201 Of the 93 respondents at Otterhampton, 64 respondents (69%) thought that EDF Energy’s proposals were unsatisfactory, 17 respondents (18%) thought the proposals were satisfactory and 12 respondents (13%) did not know or did not express an opinion.




3.3 Summary of Qualitative Results by Theme

3.3.1 EDF Energy has captured all of the feedback from its formal stages of consultation. This was drawn primarily from questionnaires returned during or after public exhibitions and from formal written responses from statutory and non-statutory bodies, the local community and the general public.

3.3.2 Due to the high volume of consultee responses and the diverse issues raised within them, EDF Energy has taken a three-tier approach to organising and indexing the responses received and assigning the EDF Energy responses provided.

3.3.3 This structured approach is intended to:

• assist with identifying particular concerns and therefore focussing development work on key areas;

• ensure targeted, relevant responses; and

• help the reader or consultee to match comments with responses in a comprehensible and navigable way.

3.3.4 Comments have been assessed and captured in a descending hierarchy of Themes, Categories and Topics.

3.3.5 In total, EDF Energy received more than 2,000 responses, out of which nearly 33,000 comments have been processed. These comments have been assigned to more than 1,200 Topics, within 225 Categories, which in turn sit within 23 Themes. A more detailed explanation of the process for analysing and categorising the comments during the formal stages of consultation is included in Chapter 5 of this report.

3.3.6 This chapter summarises the main issues raised under each of the Themes during the formal stages of consultation and how EDF Energy has addressed them, distinguishing, where appropriate, between issues raised by statutory consultees, other relevant stakeholders, the local community or the general public. Feedback received during workshops and focus groups during the formal consultation periods also summarised in this chapter.

3.3.7 More detailed responses to the issues raised, organised by Topic, are produced in Appendix H, set against the identified verbatim comments.

3.3.8 A summary of responses covering each of the 23 chosen Themes is outlined below.




a) Accommodation

3.3.9 Consultees raised a wide range of issues, including the justification for the demand and supply of accommodation, the appropriateness of relying on existing accommodation provision (both housing and tourist accommodation), the scale, distribution and disposition of campus accommodation, whether the proposed accommodation campuses could be used to provide legacy housing and various impacts on transport, local services and community cohesion.

3.3.10 A number of issues about campuses, including their size, location, on-site facilities, impacts and legacy were raised during consultation. Following responses to the Stage 1 and 2 consultations, EDF Energy has reduced the overall level of campus provision from just over 1,900 bedspaces to just over 1,500. It has also focused provision in three locations – at the HPC Development Site and at two sites in Bridgwater. Initial options to locate campus accommodation at Williton and Cannington were not continued, largely in response to comments from local residents at Stage 1 of the consultation.

3.3.11 Partly in response to comments about the impact on local services, more detail was provided about the facilities available in the campuses in the Stage 2 Update documentation. The campuses would provide most of the day-to-day facilities that workers would need on-site. Comprehensive medical and other facilities would also be provided to ensure that workers would not increase the burden on local providers and to minimise the number of trips that they would need to make off-site.

3.3.12 Consultees raised issues about the lack of local housing and possible over-use of tourist accommodation. Some respondents stated that workers might drive up the cost of housing and that this could lead to an increase in the cost of living. Others feared that the Project would drive down house prices. EDF Energy has updated its Accommodation Strategy in response to these comments. This includes an updated assessment of the existing local accommodation markets. EDF Energy’s Accommodation Strategy shows that the proposals should not have a detrimental impact on local tourism or the local housing market. It shows that increased demand from HPC is relatively small in the context of the amount of housing in the area and even in the summer months there is significant unused capacity in local tourist accommodation.

3.3.13 Since the Stage 2 Update consultation, EDF Energy has developed its Accommodation Strategy further in response to concerns about housing supply and worker behaviour. The Strategy explains how EDF Energy would work with stakeholders to direct workers away from geographical areas or accommodation sectors where issues have been identified. The Strategy includes a Worker Code of Conduct to set expectations about how workers would use accommodation and how they interact with the local community.

3.3.14 Some responses to consultation suggested that either permanent housing should be provided instead of campuses, or that the accommodation campuses should be built in such a way as to allow for subsequent conversion into housing once the construction phase of the Project was complete. EDF Energy clarified, as part of the Stage 2 Update consultation, that the accommodation campuses are not suitable for conversion into housing due to their functional design, with workers living in individual




rooms in each accommodation block and shared amenities provided in separate blocks.

3.3.15 In its Stage 2 Update consultation, EDF Energy explained that it would propose additional support for housing in the local area by establishing a Housing Fund. This is intended to respond to concerns, mainly from the local authorities, about the impact of workers on the cost and supply of housing locally. The Housing Fund would provide £5 million of financial support towards a range of initiatives to boost the supply of accommodation locally and help local people to access the housing market. This also has the potential to deliver legacy benefits when funds used to support investment such as loans are repaid and then ‘recycled’ to provide ongoing support to the local housing sector.




b) Transport

3.3.16 EDF Energy has held four rounds of public consultation relating to the proposed development at Hinkley Point and its associated development. Transport was a principal and contentious issue throughout. After analysing all the comments received, the main themes that were raised at each consultation, from both public and statutory stakeholders, related to:

• the impact that construction worker and HGV traffic would have on the capacity of the road network;

• the perceived need for a northern Bridgwater bypass;

• the rationale behind the proposed Cannington bypass;

• the transporting of freight to the site, by sea or road;

• the provision of parking on-site; and

• the need to promote and facilitate non-car modes of transport.

3.3.17 With regard to the impact that construction worker and HGV traffic would have on the local highway network, many demand-management measures are proposed in order to limit the impact of the development. These include:

• providing facilities to ensure as much freight as possible can travel by sea;

• the provision of freight management centres on major routes to control the movement of freight on the more local highway network;

• a postal courier consolidation centre to reduce such movements on the local highway network;

• contractual limits on how many HGVs can travel during peak periods;

• proposing HGV routes that keep to appropriate roads with penalties for not doing so and monitoring those routes using automatic number plate recognition scanners;

• the provision of a Cannington bypass;

• limiting the number of parking spaces during construction on the Hinkley Point C Development Site to 200;

• provision of four park and ride sites to be used by the majority of workers, greatly reducing the number of vehicles passing to/from the site;

• staggered worker shift start/end times away from peak periods; and

• improving the capacity and safety of key road junctions and promoting non-car modes of travel to all staff via the measures outlined in the Framework Travel Plan, part of the Transport Assessment, and explained further below.




3.3.18 In addition, the residual impacts of traffic on the local highway network have been extensively assessed by EDF Energy, working with transport and highways experts from the relevant local authorities. The detailed assessment and analysis is contained within the Transport Assessment submitted as part of the DCO application.

3.3.19 A high number of consultees, in particular members of parish councils and the general public, strongly advocated the construction of a northern Bridgwater bypass in order to accommodate the HPC construction traffic and to address existing congestion issues in the town. After an initial technical review at Stage 1, which was confirmed by further technical assessments at Stage 2, EDF Energy concluded in its Stage 2 Update consultation that the existing highway network would be able to cater for the development traffic. EDF Energy believes that a northern Bridgwater bypass is not required for the construction of HPC, especially in view of the highway improvement schemes that are proposed in Bridgwater itself and the surrounding area. Consistently, from the Stage 1 consultation through all other stages, a number of reasons were given for not including a Bridgwater bypass in the HPC proposals. The principal reasons relate to national, regional and local transport policy, the environmental impact of construction of the bypass, impact on the flood plain, lack of significant traffic relief and construction timescale issues.

3.3.20 The Bridgwater Bypass Study, submitted as part of the DCO application, provides

a detailed explanation of EDF Energy’s position and assessment of the suggestion for a northern Bridgwater bypass. Details of the proposed new highway improvement schemes in and around Bridgwater were variously consulted on in the Stage 2 Update and Junction 24 and Highway Improvements consultations. Nonetheless, strong local support for a new northern Bridgwater bypass remains.

3.3.21 In respect of a Cannington bypass, although in highway capacity terms the local road network would be able to cope with the additional traffic in the village, the level of increase from the current traffic flow through the village would be substantial and would have a significant impact on Cannington residents. Therefore, EDF Energy proposes that a western bypass be built in order to route traffic away from the village centre. The responses to the Stage 1 consultation expressed varying levels of support for two alternative route alignments around Cannington (east and west). Following the completion of the Stage 1 consultation and further technical studies, the preferred route for a bypass west of Cannington (Cannington western route) was identified. The Environmental Statement submitted as part of the DCO application details the rationale behind the chosen location of the western bypass. Detailed drawings of the route were prepared for the Stage 2 consultation and modifications were made in light of comments received. The final alignment and detailed drawings are submitted as part of the DCO application.

3.3.22 The Freight Management Strategy details how a significant proportion of construction materials for the HPC Development Site, including an expected 80% of aggregate material for concrete production, would be transported by sea and unloaded via the temporary jetty and refurbished facilities at Combwich Wharf.

3.3.23 The route along the C182 from Combwich to Hinkley Point has been identified as an area where the large vehicles from Combwich Wharf, combined with the additional traffic from the site, could lead to deterioration and damage to the highway. To




address these concerns, the highway and associated highway structures would be inspected and a programme of works agreed with the highway authority to ensure that the highway would be able to cope with the additional loads if the overall proposals receive approval.

3.3.24 In addition to the proposed improvement works, EDF Energy is also committed to regularly surveying the highway quality during and after the completion of the works to identify and rectify issues that may arise as a consequence of the HPC construction phase.

3.3.25 The proposals for Combwich Wharf and HPC include the provision of a lay-by on the private Combwich Wharf access road for Abnormal Indivisible Loads (AILs) and a holding area for HGVs within the Combwich site boundaries. This would allow vehicles to wait away from residential properties and off the highway when there are issues on the highway network, before being cleared for travel to HPC. An alternative access road to Combwich Wharf is also proposed which would keep HGV traffic as far from nearby housing as practicable.

3.3.26 All AILs leaving Combwich Wharf would be escorted by an escort vehicle to ensure that the route ahead is clear and to maintain a safe passage. The timings of these movements would be agreed in advance with the Highways Agency to minimise traffic impacts.

3.3.27 The proposed construction worker parking at HPC for the construction phase consists of 200 spaces provided for the major construction contractors. Overall, the proposed parking provision during construction is heavily constrained relative to the size of the construction workforce, meaning that the large majority of construction workers would need to arrive at site by other non-car modes, in most cases by park and ride, or direct by bus.

3.3.28 The Framework Travel Plan, submitted as part of the DCO application, contains the

various measures that would be implemented in order to maximise the use of non-car modes of transport for travel to/from the Hinkley Point C Development Site. In addition, there are significant proposals to improve walking and cycle infrastructure in the local area to further encourage the use of non-car modes of transport.

3.3.29 Overall, the effects of the development on the local highway network would be managed in order to reduce, as far as possible, any negative impact. The Transport

Assessment demonstrates that, with the mitigation measures proposed, the highway

network has sufficient capacity to cater for traffic associated with the HPC Project.




c) Socio-Economics and Procurement

3.3.30 Due to the wide range of Topics within this Theme, the responses have been sub-divided into the following areas, arranged in alphabetical order:

• Apprentices

• Community Cohesion – Equalities and Inclusion

• Community Fund, Strategy and Policy

• Construction Workforce Development Strategy (CWDS)

• Economic Regeneration, Economic Development, Low Carbon Cluster, Legacy, Public Funding

• Education

• Education Capacity

• Employment Brokerage and Employment Outreach

• Hinkley Charter

• Local Business Engagement and Procurement Strategy

• Operational Workforce Development Strategy

• Performance Monitoring

• Policing, Security and Fire including Code Of Conduct, Community Wellbeing and Community Safety

• Recreation and Amenity

• Skills

• Socio-Economic Team Plan

• Tourism

3.3.31 In the following areas of the Socio-Economic Theme, a number of discrete strategies are referred to. These can be found as supporting documents to the Economic

Strategy.

ii. Apprentices

3.3.32 In response to the local authorities’ request for apprenticeship numbers, EDF Energy stated that the proposals are designed to meet the national average of 1.4% and that




the figure could be as high as 2% of the total workforce. The local authorities also sought reassurance as to whether the ‘right interventions’ would be in place at the ‘right time’. They were aware of the forecasting model and were keen to see that this is used to drive the planning of the interventions. EDF Energy replied that the forecasting model would drive the interventions.

3.3.33 Public responses focussed on the issue of non-local people gaining apprenticeship places and concerns that EDF Energy would not see the proposals through to Project completion. EDF Energy gave a reassurance that the proposals focus specifically on the districts of Sedgemoor and West Somerset and that the projects cover the entire construction phase into operation and legacy.

iii. Community Cohesion – Equalities and Inclusion

3.3.34 Both the statutory consultees and members of the local community expressed concern regarding a possible divide between local communities and the construction workforce. Additionally, statutory consultees’ responses focused on language barriers and the issue of translation with regard to non-English speaking construction workers. In response to these concerns, EDF Energy has proposed a number if mitigation proposals, including community liaison support, an awareness campaign, a construction worker welcome pack and a 24-hour construction telephone hotline that members of the public would be able to call to raise concerns or issues. EDF Energy would also provide translation services, if required.

iv. Community Fund, Strategy and Policy

3.3.35 The local authorities expressed a strong desire for EDF Energy to commit to a community benefits package to provide long-term compensation, rewards and hosting payments to the local community. EDF Energy has proposed a £20 million Community Fund, plus a wide range of mitigation measures and commitments, which seek to respond to the range of specific concerns that have been raised. The substantial commitments to fund local authority, community and public services are set out in the Requirements and Obligations in the Planning Statement. The measures specifically target those communities that would be most affected by the proposals and a voluntary Main Site Neighbourhood Support Scheme, comprising property price and noise mitigation schemes, has been proposed for the properties in the five hamlets closest to the construction site (see Chapter 4 for more information). Voluntary noise mitigation schemes are also proposed in Cannington and Combwich.

v. Construction Workforce Development Strategy (CWDS)

3.3.36 The statutory consultees’ responses centred on concerns that the Construction

Workforce Development Strategy would not maximise economic benefit, that there was not enough detail within the consultation documentation and that insufficient attention was being given to legacy and outreach to local people. It was also suggested that the CWDS relies on goodwill for delivery. EDF Energy responded by noting that a detailed version of the CWDS had been produced following the feedback received from the Stage 2 Update consultation. This version of the CWDS is an ‘implementation strategy’, which clearly sets out the delivery requirements to ensure objectives are met. Each project within the Strategy has its own timeline and key deliverables, which are clearly set out within the CWDS, along with plans for future legacy operation.




3.3.37 The public concerns at Stage 1 and Stage 2 centred primarily on inward migration. An examination of the realistic employment opportunities for people from within the home-based area was undertaken and agreed with key stakeholders in February 2011. This was based on an economic analysis of the supply of existing construction labour within Somerset and the specific demands of Hinkley Point C.

vi. Economic Regeneration, Economic Development, Low Carbon Cluster,

Legacy, Public Funding

3.3.38 These issues have been combined into a single summary response as they are inter-related. They relate to the need to maximise the benefits of Hinkley Point C during the construction phase and to ensure that the benefits are long-lasting.

3.3.39 The views of the local community and general public were polarised. A large number of comments suggested that the development would create no economic benefit and would actually have a detrimental impact on the economy by increasing congestion, causing wage inflation and causing an influx of migrant workers. Similar numbers very much welcomed the proposals, arguing that the jobs it would create are needed in a declining area. There was a general view that efforts should be maximised to ensure that both local businesses and people should be able to access the opportunities available.

3.3.40 Statutory consultees highlighted the real opportunity that the development would create to support economic development. The focus of these comments was on ensuring that mechanisms were in place to support the local supply chain and that skills and training plans ensured that job creation in the local area was not limited to the low-skill jobs. There was also concern that any plans for training would be detrimentally impacted by cuts in public sector funding.

3.3.41 The statutory consultees were concerned that more robust strategies were needed, not only to ensure the short-term benefits to the local economy, but also to create a long-term legacy. The statutory consultees outlined their key expectations for the HPC development in terms of:

• moving Somerset to a high-value economy;

• developing a highly-skilled labour force;

• ensuring that local communities benefit; and

• supporting the image of Somerset.

3.3.42 In parallel to these expectations was the view that the low-carbon economy could be the focus for long-term economic development. The HPC Project would act as a catalyst to attract other related business that would have long-term potential in itself, and the added potential to be broadened to other low-carbon technologies. This focus could also support a change of image for Somerset linked to a societal change and transition to a low-carbon way of life.




3.3.43 EDF Energy committed itself, from the earliest stages, to maximise the local supply chain benefits and to ensure a long-term legacy, with the concept of a low-carbon cluster being introduced at a later stage. A series of economic development strategies have been devised and will help to leave a positive legacy. These documents include a Local Supply Chain Engagement Strategy, a Construction

Workforce Development Strategy (CWDS), an Education ‘Inspire’ Strategy and, more broadly, a strategic framework for a low-carbon economy.

3.3.44 The Local Supply Chain Engagement Strategy, CWDS and Education Strategy are designed to support access to jobs and business opportunities for local businesses and people. The Local Supply Chain Engagement Strategy is focussed on making firms aware of the contract opportunities and working with local partners to ensure businesses have the right skills to compete for tenders. It also has a role in strengthening the local supply chain by encouraging inward investment and joint ventures. This Strategy works in partnership with key local agencies to promote Somerset as a place to do business. Both the CWDS and Education Strategy have a particular focus on up-skilling local people; getting them ‘work and job-ready’. The CWDS focuses on the construction phase and can be seen in conjunction with EDF Energy’s investments in the training infrastructure in Somerset, whilst the Education Strategy has more long-term goals in terms of encouraging the take up of science, technology, engineering and maths (STEM) subjects to encourage entry into the nuclear sector at apprenticeship and graduate levels.

3.3.45 These strategies, which have been developed in partnership with key stakeholders, support the procurement and skill requirements of Hinkley Point C, but would also deliver wider benefits for the economy as a whole.

3.3.46 The partnership approach was replicated when forming the low-carbon delivery team to support the wider economic development goals in Somerset. A strategic framework has been agreed and would form the basis for a wider discussion with regional partners, such as the Local Enterprise Partnership, to place the nuclear sector at the heart of a low-carbon economy.

vii. Education

3.3.47 The main concern of the statutory consultees was a lack of clear detail with regard to the scope of the overall education programme and proposed initiatives. Another specific suggestion was that work placements could be arranged on the construction site. During the Stage 2 consultation EDF Energy developed the various strands of the Education Strategy under the auspices and direction of the Employment and Skills Operations Group (ESOG) (see Chapter 4 for more information). In response to feedback from ESOG and the Stage 2 consultation, EDF Energy developed the more detailed Education Strategy, which has been designed as an ‘implementation strategy’. It clearly sets out each of the education interventions required as specific projects. Each has its own timeline and key deliverables, along with plans for future legacy operation.

3.3.48 Public consultees saw engagement with schools as being important and that encouraging the study of STEM subjects in local schools and colleges should ensure sustainable futures for many young people in Somerset. EDF Energy’s aim has been to develop an education strategy and a series of interventions that raise aspirations




among young people in Somerset and enable them to enter sustainable careers. The interventions within the Education Strategy are targeted at specific groups of young people within the community. They form an integrated programme of educational outreach projects, and each of the proposed interventions are differentiated and prioritised across a range of audience groups, from primary school age through to Higher Education (16-24 year olds) and link to onward employment-related training and development opportunities.

viii. Education Capacity

3.3.49 Responses from the general public did not cover the issue of education capacity; focusing more on general investment in schools in Somerset, which is detailed in the Education summary above. The statutory consultees were concerned about the cuts to the Building Schools for the Future (BSF) programme and, generally, that HPC would create a strain on capacity within schools. EDF Energy’s response was that the BSF funding that is going ahead is creating additional capacity in terms of school places. Data shows that the birth rate is going down; therefore, the pressure on schools is likely to be less, in terms of demand, which will lead to extra capacity in existing schools. As part of the section 106 agreement, EDF Energy would make an educational contribution if development consent is granted.

ix. Employment Brokerage and Employment Outreach

3.3.50 The initial comments from the public focussed on a lack of awareness of the employment brokerage proposals. Once they were made aware of the planned and existing interventions, they wanted more information on how to get involved and guidance on how further information could be obtained. EDF Energy responded with details of the partnership that has been created with JobCentre Plus (JCP) and the arrangements that have been made with the organisation across Somerset, such as the appointment of JCP HPC champions across the region, who are responsible for providing information on the employment proposals. EDF Energy also pointed out that engagement had commenced with community groups and voluntary organisations as part of the preparations for the HPC Project.

3.3.51 Statutory consultees’ responses focussed on the requirement for an employment and skills charter. EDF Energy confirmed that detailed monitoring would take place on the Project and that the employment brokerage would be able to provide performance data (while complying with the Data Protection Act). EDF Energy also highlighted that it would work with JobCentre Plus to deliver the scheme.

x. Hinkley Charter

3.3.52 The primary concerns of the statutory consultees were that, whilst a charter was welcomed by most, its targets should be stretching and represent a genuine commitment on behalf of EDF Energy and its contract partners. A number of consultees also felt strongly that local labour agreements should be implemented with contract partners to ensure that commitments are met. The way in which a charter is promoted and communicated was felt to be important to its success, as it is not a legally binding document. It was also felt by some that focussed initiatives need to be implemented in order to reach the targets contained within the charter.




3.3.53 The evidence collected to support the Key Performance Indicators (KPIs), and methods of performance reporting against them, are a key element of the Construction Workforce Development Strategy (CWDS). The Employment and

Skills (Hinkley) Charter would reflect challenging aspirations that EDF Energy, in partnership with its contract and stakeholder partners, will work together to achieve should consent be granted for the HPC Project. Progress against the charter will be published regularly.

3.3.54 There were no public responses on the subject of the Hinkley Charter.

xi. Local Supply Chain Engagement Strategy

3.3.55 The most frequently occurring concern from both statutory consultees and the local community was that local companies would not be able to benefit from the construction of HPC or in terms of the legacy of the Project. The Local Supply

Chain Engagement Strategy addresses these concerns. Other interventions

implemented by EDF Energy are the noting of requirements within contract bid instructions and appropriate tender documentation. These include a strong requirement to use local labour, where feasible.

3.3.56 At Stage 2, the statutory consultees expressed concern that there was little evidence of supplier engagement. Since Stage 2, EDF Energy has engaged with local business engagement forums and has made more than 70 separate visits to local suppliers. The engagement has included the provision of information on the requirements needed to gain work on the Project, with several supplier support events also taking place.

3.3.57 Since Stage 2, the definition of ‘local’ has widened, in response to comments from consultees, from the administrative boundary of Somerset to incorporate North Somerset and include towns such as Weston-super-Mare, as it was agreed that this was a more appropriate geographical boundary for the Project.

xii. Operational Workforce Development Strategy

3.3.58 The statutory consultees requested that an operational workforce development strategy be produced. EDF Energy agreed that a strategy would be produced. There were no comments from the local community on this element.

xiii. Performance Monitoring

3.3.59 The statutory consultees raised concerns about the lack of detail with regard to specific delivery plans or targets; a lack of evidence against which Key Performance Indicators (KPIs) could be set; that aspirations for local employment are set too low; and a perception that there would be a lack of contractual mechanisms to ensure that contract partners comply with EDF Energy’s workforce development aspirations. EDF Energy has refined and produced specific skills forecasts for the early phases of construction and the main civil engineering works. A detailed paper, which accompanied the development of the detailed skills forecasts, set out clearly the realistic levels of opportunity to employ people from within the home-based area. This was based on an economic analysis of the supply of existing construction labour within Somerset, demographic data, consultation with Tier 1 contractors and




information from the nuclear project at Flamanville in France. The data was used to determine the specific demands of Hinkley Point C. The results of the analysis were accepted and signed off by key stakeholders in February 2011. This formed the basis for EDF Energy’s KPIs and published aspirations for levels of local employment in the workforce.

3.3.60 There were no public responses relating to performance monitoring.

xiv. Policing, Security and Fire including Code of Conduct, Community

Wellbeing and Community Safety

3.3.61 The statutory consultees and members of the local community both raised significant concerns about the potential behaviour of workers within the local community. Specific concern was raised with regard to worker behaviour in the evenings in towns such as Bridgwater. Drug and alcohol-related issues were also a concern, with an associated concern about increased crime within the community. These issues are addressed within the Worker Code of Conduct, which is submitted as part of the DCO application. Workers would also be vetted and subjected to a rigorous induction process, and community liaison support would be appointed to monitor behaviour and provide a point of contact.

3.3.62 Concern was also raised by statutory consultees over the impact of traffic accidents on response times to incidents on-site. The other main concern raised by statutory consultees was strain on the resources of the Coastguard, Ambulance, Police and Fire services. Resource strain has been assessed through Outline Contingency

Response Arrangements and a Community Safety Management Plan (see Annex 6 of the Environmental Statement). Traffic issues have been addressed within the traffic incident management plan, which outlines processes and diversion routes.

xv. Recreation and Amenity

3.3.63 Consultees raised a number of issues about recreation and amenity that related to the availability of leisure and recreation facilities for HPC workers, and the impact of proposed developments on Combwich Wharf and the Bridgwater Sports and Social Club. EDF Energy has committed to provide sports pitches and gyms within its accommodation campuses, with sports and leisure facilities available for public use. It has also worked with the local authorities to identify current levels of provision and has agreed to invest in additional facilities. This will ensure that there would be adequate facilities available for the local community and HPC workers. EDF Energy has also amended its proposals for Combwich Wharf to ensure that they do not obstruct the activities of the sailing club.

xvi. Skills

3.3.64 The statutory consultees and general public are generally in favour of the proposals in relation to skills. Both groups are in favour of the use of local provision, such as the partnerships created with Bridgwater College and West Somerset Community College. Building on this, members of the public commented that participation should be widened to other educational establishments.




3.3.65 The statutory consultees specifically mentioned the requirement for an employment and skills charter and a detailed plan of the proposed offer. Pre-employment training was noted as a requirement, together with the desire to engage the voluntary sector. They also highlighted the need for a Construction Workforce Development

Strategy (CWDS), and that EDF Energy should maximise local procurement. The

local community wanted assurance that schools would benefit and that an EDF Energy-branded scholarship programme would be put in place.

3.3.66 EDF Energy responded by confirming that there would be investment in local providers. A CWDS has been produced and meetings have now been convened regarding pre-employment training. A Local Supply Chain Engagement Strategy

and an employment and skills charter have also been produced. With regard to the widening of the participation of local colleges, EDF Energy notes that other Further Education providers have not been excluded.

xvii. Socio-Economic Team Plan

3.3.67 At Stage 1 and Stage 2 of the consultation, statutory consultees commented on the need to co-ordinate activity within the socio-economic workstream and agree a common framework to gain agreement on key themes. The Socio-Economic Task Group (SETG) was formed to undertake these tasks and the governance, scope and timeframes were set out in the Socio-Economic Team Plan. This was formally agreed by group members. The purposes were:

• to act as a programme management function of the work areas within the socio-economic workstream;

• to act as the forum for regular communication and discussion; and

• to act as the authority for agreement of a statement of common ground for the purposes of the DCO application.

3.3.68 SETG is accountable for the following areas when progressing discussion on agreeing Common Ground: socio-economic evidence and assessment; commercial property; community wellbeing (including health, community safety, tourism and leisure); employment, skills and education; and low-carbon cluster and economic development (see Chapter 4 for more information).

xviii. Tourism

3.3.69 Statutory consultees and some members of the general public raised a number of concerns about the potential impact of the HPC Project on the tourism industry. These were principally: that workers would use too much tourist accommodation and crowd out regular tourists, that the construction of HPC would affect tourists’ perceptions of the area and that traffic congestion would prevent tourists getting around the county easily. The view was that these concerns, if they were to be realised, could combine to reduce the number of tourist visitors and deter them from returning to Somerset. In response, EDF Energy has undertaken further analysis of the tourist accommodation market and concluded that even during the summer peak there is more surplus capacity around the HPC site than would be demanded by workers. There is therefore little risk of workers crowding out tourists and the Project




would provide a net benefit by using up capacity, especially in the off-peak season, which would otherwise remain vacant. Further details can be found in the Accommodation Strategy.

3.3.70 Consultees recognised the potential role of the Public Information Centre in providing a new visitor attraction and helping to attract tourists to the county. Please see the Public Information Centre Management Strategy, as part of the Economic

Strategy.




d) Sustainability Strategy

3.3.71 This section provides a response to the consultation comments received throughout all stages of consultation on matters relating to sustainability. Sustainability is a broad issue which has been addressed by EDF Energy in a number of ways across the Project as a whole.

3.3.72 Through the development of the Hinkley Point C Project, and the various stages of consultation, EDF Energy has made clear its intention to bring forward the project in a sustainable way. At Stage 2 consultation on the ‘Preferred Proposals’, EDF Energy published a sustainability evaluation document, which set out at a high level how EDF Energy was addressing sustainability. The document provided an initial appraisal of the scheme proposals and sustainability measures identified by EDF Energy to demonstrate how social, environmental and economic objectives could be achieved. This triple bottom line approach is an important outcome for EDF Energy.

3.3.73 During the various consultation exercises, EDF Energy has collected and built on the consultation responses received. The responses received during this process typically relate to two main categories: firstly, the Sustainability Statement which

relates to comments received on the sustainability measures proposed for the project; and secondly, the Sustainability Evaluation which relates to the appraisal of these measures and was submitted at the Stage 2 ‘Preferred Proposals’ consultation

3.3.74 These consultation exercises have shaped the Sustainability Statement, which is made up of four parts:

• Part 1: Project Overview – provides a general overview of the Project and the purpose and objectives of the Sustainability Statement.

• Part 2: Sustainability Strategy – describes the approach taken to consider and integrate sustainability into the Project.

• Part 3: Sustainability Statement – provides a description of how the sustainability opportunities which have been evaluated, developed and embedded into the Project would successfully contribute to the sustainable development of HPC.

• Part 4: Sustainability Appraisal – a detailed appraisal of the Project proposals against a sustainability framework.

3.3.75 It is intended that the document is read as a whole. Consultees commented during consultation that the Sustainability Evaluation did not provide sufficient evidence that sustainability had been incorporated into the Project. The Sustainability Evaluation submitted at Stage 2 was based on ‘Preferred Proposals’, so it was not possible to provide detailed design measures. The Sustainability Statement provided in the DCO application includes information on sustainable design measures, how these have been considered and integrated into the design of the development, and the way in which principles of sustainable development would be implemented in the construction, operation and decommissioning of HPC. In addition, site-specific design measures are detailed in the Design and Access Statements.




3.3.76 The purpose of the Sustainability Statement is to identify the environmental, social and economic benefits of the Project by demonstrating compliance with a series of sustainability objectives. The Sustainability Appraisal is informed by findings of the Environmental Impact Appraisal (EIA) and other technical studies. It is therefore necessary to summarise elements of this information in the Sustainability Statement. It was noted that certain issues were ‘under-represented’ in the narrative of the Sustainability Evaluation. However, this information is now provided in the Environmental Statement.

3.3.77 Since Stage 2, EDF Energy has considered a number of additional sustainability opportunities for the Project. The Sustainability Statement explains these and provides a description of the process EDF Energy has undertaken to consider and integrate these opportunities into the Project. This includes publication of the method EDF Energy has used to consider specific sustainability opportunities through the development of a sustainability opportunities register.

3.3.78 Since Stage 2, EDF Energy has undertaken extensive work in updating the Sustainability Appraisal, building on findings of the Sustainability Evaluation that was first published at Stage 2. It has been updated with additional information from the EIA, socio-economic workstreams, community-based strategies and additional design detail.




e) Waste Management Strategy

3.3.79 Statutory consultees, other relevant stakeholders and members of the general public raised a number of concerns during the consultation periods in relation to conventional (i.e. non-radioactive) waste management, both during the construction and operation of HPC. These concerns included queries about on-site waste storage, traffic impacts arising from off-site waste disposal, perceived health risks, and queries on the removal of construction waste such as spoil.

3.3.80 Since the consultee comments were received, a Waste Management

Implementation Strategy (WMIS) document has been produced (Annex 5 to the Environmental Statement). This comprehensive Strategy covers:

• the site preparation, construction and operational phases of the HPC Development Site and its off-site associated development;

• decommissioning of HPC; and

• reinstatement of the associated development sites.

3.3.81 The level of detail and explanation included in this strategy addresses the conventional waste management queries raised at Stage 1 and 2. It has been submitted to the Environment Agency and Somerset County Council for consultation.

3.3.82 The WMIS sets out practical steps that can be implemented to achieve the above aim. The main objectives of the WMIS are to:

• ensure waste minimisation and, where waste is produced through the HPC Project, ensure that it is re-used or disposed of in the most sustainable manner; and

• provide measures to improve sustainability and minimise vehicle movements, where possible.

3.3.83 The ways to achieve these objectives are to:

• prevent and reduce the volumes of waste produced through the application of the waste hierarchy – namely, to reduce, re-use, recycle and, only as a last resort, dispose of waste;

• reduce vehicle movements on the road through two-way trips;

• re-use materials on the associated developments during reinstatement;

• sustainably use the existing waste management infrastructure;

• encourage re-use of material through a waste inventory; and

• offer incentives to the contractor to achieve key goals.




3.3.84 Although it is the intention for waste to be managed in order of the waste hierarchy, inevitably there will be some waste that will require disposal at landfill. Any waste to be disposed of would be sent to an authorised waste management facility.

3.3.85 The WMIS includes predicted waste volumes for the site preparation, construction and operational phases of the HPC Development and its off-site associated developments, decommissioning of HPC and reinstatement of the associated developments. The anticipated waste volumes for HPC were derived with reference to the construction of the Flamanville 3 nuclear power station in France and the decommissioning of Hinkley Point A nuclear power station. The majority of construction phase waste would be produced in the first few years of construction. However, the greatest waste production peak would be during the reinstatement of off-site associated developments. Following the operational phases and prior to the removal/reinstatement of the associated developments, there would be a review stage, whereby the proposed waste management methods would be reassessed. The WMIS also includes a breakdown of waste production through time; all of the waste volumes have been linked into the Freight Management Strategy to enable an estimate of vehicle trips.




f) Environmental Mitigation Strategy

3.3.86 Consultation responses, chiefly from the local authorities as statutory consultees, recognised the significance of the Environmental Management and Monitoring Plan (EMMP) framework in mitigating the risk of environmental harm from the construction of Hinkley Point C. Issues included pollution, especially of the water environment, and impacts elsewhere on the environment, such as ecology, soils and the local community.

3.3.87 Respondents sought clarity on the breadth of the EMMP, the rigour of governance and comprehensive coverage across all the HPC development sites, which together would give confidence that environmental impacts resulting from work activities would be eliminated where possible or minimised to an acceptable level. Particular emphasis was placed on the clarity of interconnection between the EMMPs, the topic-specific strategies and the legally-required permits, licences and consents, and the way in which these requirements would be transmitted to the contractors for management under their own construction environmental management plans (CEMPs) and related arrangements.

3.3.88 EMMPs and their supporting subject-specific management plans would be key to the mitigation of potential environmental impacts arising from construction activities on both the HPC Development Site and the associated development sites. In each case, the plans would establish the management control framework from design (permanent and temporary works), through construction, leading eventually to the implementation of EDF Energy’s environmental management system for the operating phase. The EMMPs would also address environmental mitigation of the operation of the jetty and the associated development sites, and of their deconstruction at the end of their operational lives. See Annexes to the Environmental Statement.

3.3.89 The EMMPs would be supported by a suite of subject-specific management plans. These plans would provide greater detail and clarity on the mitigation measures associated with specific aspects of environmental protection, providing contractors with a clearer understanding of the constraints applying to work on the development sites.

3.3.90 The EMMP and supporting plans would identify the applicable legal, planning and best practice requirements and commitments, and set out EDF Energy’s expectations of its contractors. Under their contracts, the contractors would then be required to develop their own construction environmental management plans (CEMPs) to address their specific scope of work, in compliance with the EMMP framework. The CEMP will detail the practical day-to-day controls, including roles and responsibilities, risk assessment and method statement processes. Prior to any works commencing, the contractor would be required to gain approval of the CEMP by EDF Energy’s own environmental management team. This approach would ensure a systematic and consistent management control of construction work activities, including monitoring and control of environmental impacts in accordance with EDF Energy’s objectives.

3.3.91 The EMMPs and supporting plans would be structured to comply with environmental standards, though formal accreditation of management standards may be sought at a later stage. The EMMPs would reference relevant external standards including the




Environment Agency’s pollution prevention guidelines and CIRIA Environmental Good Practice guides. They would also embody the sustainability objectives of the HPC Project through the implementation of BREEAM (BRE Environmental Assessment Method) and CEEQUAL (Civil Engineering Environmental Quality Assessment and Award Scheme) ratings systems for certain elements of permanent and temporary works.

3.3.92 The qualification, experience and competency of staff and contractors with environmental responsibilities would be defined in the EMMPs and supporting plans, and managed through the recruitment and procurement processes, with contractors identifying and meeting the training needs of their personnel.

3.3.93 To give assurance of compliance to regulators, stakeholders and the local communities, the EMMPs and supporting plans would set out monitoring, inspection and auditing requirements that would be reported as part of EDF Energy’s oversight of the Project. They would also be reviewed and updated as and when required, for example, to reflect any new legislation.




g) Health Impact Assessment

3.3.94 The consultation feedback relating to health, received through both the Stage 1 and Stage 2 consultation processes, has been allocated against a number of categories, each carefully scrutinised and assessed into key topic areas. All the comments have been individually reviewed and audited to demonstrate whether or not the comment has led to a change in the assessment.

3.3.95 The consultation feedback on health centred heavily on three topic areas: the change in health requirements due to an influx of a large construction workforce; the mitigation measures which had been outlined; and the impact of noise and disturbance from construction activities on the local community. Comments have been received and reviewed from statutory and non-statutory consultees and the local community.

3.3.96 Specifically, the South West Strategic Health Authority, a statutory consultee, commented that a period of each week should be free of construction to safeguard the health and wellbeing of local residents, a comment that was echoed by both the public and non-statutory consultees, including NHS Somerset.

3.3.97 Furthermore, the Strategic Health Authority queried additional demand for healthcare services generated by the construction workforce and recommended additional financial support to local healthcare services. Concerns regarding the capacity of GP surgeries, dentists and hospitals have also been raised by the public and a number of non-statutory consultees including the Federation of Bridgwater Practices and Somerset Primary Care Trust.

3.3.98 Although not a regulatory requirement to the UK planning process, the Health

Impact Assessment (HIA) is regarded as best practice, is recommended through the Draft National Policy Statement for Nuclear Power Generation (EN-6), and has proven successful in facilitating more effective community and health stakeholder engagement on a wide range of major infrastructure projects. HIA also further investigates and addresses perceived risks, and facilitates a more joined-up approach to planning, environment and community/public health.

3.3.99 EDF Energy has, therefore, prepared and voluntarily commissioned a HIA, both to inform the IPC process and to investigate and address more effectively local community concerns, priorities and needs. The HIA has identified and assessed a number of health pathways which influence known determinants of health. For example, construction activities are known to influence environmental determinants of health, such as air, noise and traffic. A health pathway is identified when such influences have the opportunity to impact on communities with the potential to cause a health outcome.

3.3.100 The HIA quantifies and appraises the magnitude, distribution and likelihood of potential health outcomes (both adverse and beneficial) directly attributable to the proposed development. This includes an assessment of conventional health impacts, such as communicable disease, accidents and risk, along with the wider determinants vital to good health and wellbeing. The HIA also provides an assessment of the potential impact of increased demand for local health services.




3.3.101 A Health Action Plan has been developed with key health stakeholders to put forward recommended monitoring regimes to further reduce and remove potential adverse health outcomes, if the overall proposals are approved.

3.3.102 The HIA also considers the more subjective aspects of health such as wellbeing, which includes anxiety, stress and fear of anti-social behaviour from the construction workforce. Somerset County Council stated that ‘given the potential impacts of your proposals, anxiety is likely to be a key issue for the population surrounding the site and on routes into the site’.

3.3.103 Following the Stage 2 ‘Preferred Proposals’ consultation, a number of changes which address the above have taken place and are reflected in the updated HIA. Key changes include the proposed appointment of an occupational healthcare provider to help reduce the demand on local NHS services through the provision of prevention and health promotion campaigns coupled with on-site treatment facilities. Healthcare planning contributions have also been developed with key health stakeholders to address any residual impact.

3.3.104 Following the Stage 2 Update consultation, a noise and vibration assessment (see Environmental Statement) was been updated to reflect changes in planned shift patterns and to model the potential noise impact for local residents. The findings of this assessment are reflected in the final Health Impact Assessment included as part of this DCO application.

3.3.105 Following the Stage 2 consultation process, the health pathways investigated through the HIA were updated to include mental health and wellbeing. Subsequently, the Health Action Plan has been updated to outline mitigation measures that would reduce the potential impact on the more intangible aspects important to mental health and wellbeing, including perceived risk, stress, coping skills and counselling. These mitigation measures are complemented by the. provision of a £20 million Community Fund and launch of a voluntary scheme, which provides financial support if eligible residents want to move house and offers secondary or double glazing to insulate properties closest to the HPC Development Site from noise impacts. NHS Somerset was kept informed about the schemes.




h) Environmental Impact Assessment

3.3.106 The proposals for Hinkley Point C (HPC) and supporting environmental information, including studies undertaken to inform the Environmental Impact Assessment

(EIA), have been shared and consulted upon throughout the pre-application consultation, including details on the following, where applicable:

• baseline surveys;

• the scope of the assessments and methodology;

• the assessment outcomes; and

• potential options for mitigation.

3.3.107 The EIA considers how a proposed development would affect the existing environmental conditions and what the consequences would be of such changes. Impacts which are identified as having the potential to be significant have been considered to determine whether they can be mitigated by measures to prevent, reduce or off-set the impact, beyond that already taken into account as normal good practice. In such cases, the EIA has considered site-specific measures to mitigate the magnitude of the impact. This includes changes to the design proposals. As such, the EIA is an inherent part of the iterative design process.

3.3.108 Consultees’ comments at Stage 1 and Stage 2 made reference to compliance with the EIA regulations. The EIA was undertaken for the proposed HPC Project as required by the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (EIA Regulations). A scoping process commenced in 2008 with key stakeholders to scope the surveys and studies required to adequately describe baseline conditions and to inform the assessment of impacts. Consultation with key stakeholders has been ongoing throughout the EIA process, and included the submission of a Scoping Report to the IPC in January 2010 for which a Scoping Opinion was received in May 2010.

3.3.109 Comments received at Stage 1 and Stage 2 recognised that baseline surveys were still ongoing and that, in some cases, this was due to time constraints. For example, many ecology surveys are season-specific. It was noted that the overall approach to determining the baseline, based on primary and secondary research, was fundamentally sound. Where there have been changes to the proposed development sites throughout the pre-application consultation period, either in terms of location or extent of the red line development boundary, these have been addressed in the Environmental Statement (ES) and an extension to the study area, or further surveys have been undertaken as required. Material changes to proposals have been formally consulted upon.

3.3.110 General comments received on the EIA methodology and significance criteria received during the formal pre-application consultation identified the requirement to provide details on the baseline environment, the assessment of adverse impacts on sensitive receptors and proposed mitigation. More specific comments were received at Stage 2, mainly from Sedgemoor District Council and West Somerset Council on the methodology and application of significance criteria. It was suggested that the approach to criteria used to determine the significance of an impact had the potential




to lead to an overall suppression of the determined significance of an impact; therefore giving rise to an under prediction across the impact assessment. Following Stage 2, EDF Energy engaged in dialogue on this matter specifically with the local authorities (West Somerset Council and Sedgemoor District Council) and their technical and legal advisors through the EIA workstream (see Chapter 4 of this

report). In consultation and following further technical appraisal and receipt of expert legal opinion, EDF Energy considers that the employed assessment criteria will ensure a robust impact assessment.

3.3.111 Furthermore, comments noted that further explanation was required when describing the duration of effects, particularly with regard to the use of the term ‘temporary’ when referring to the construction works programmed to last at least nine years. Concern was raised that the consideration of the term ‘temporary’ without a full explanation may result in an underestimated impact, and EDF Energy has given this careful consideration. For the purpose of the EIA, EDF Energy has defined permanent impacts as those which result in an irreversible change to baseline conditions or will last for the foreseeable future. In the context of the development proposals, temporary impacts are those which occur over shorter time periods and which are associated mainly with the construction, dismantling and removal phases of the HPC Project. EDF Energy has also defined durations of temporary impacts to assist in determining the significance of an impact. However, the EIA also recognises that, for some impacts, these generic temporary timeframes may not be applicable. For example, some ecological receptors may have a lifecycle shorter than the proposed timeframe. Where this is the case, appropriate timeframes have been applied and the justification for it is explained in the relevant topic chapters of the ES.

3.3.112 Consultation comments received at Stage 1 and 2 also recognised the need to consider specific design alternatives in accordance with the EIA Regulations. The design process for HPC and the associated developments has been an iterative one informed by the EIA and has considered alternative designs, locations, construction activities and operational procedures where applicable. The final proposals are assessed in the ES, which also provides an overview of the alternatives considered,

at both a project-wide and site-specific level.

3.3.113 Separately, and in response to comments received during the formal consultation process, an Alternative Site Assessment (ASA) (appended to the Planning

Statement) has been prepared and provides the rationale for the choice of site for the associated developments. This ASA assesses the alternative site options that have been considered in selecting the preferred associated development proposals; the associated developments provide essential supporting infrastructure for the construction of HPC. The purpose of the ASA is to determine whether the sites proposed for associated development are appropriate and suitable sites, through consideration of the potential alternatives.

3.3.114 Site-specific design comments received during the formal consultation process related primarily to the potential impacts on designated sites, particularly those of ecological and heritage importance. The EIA has assessed the potential impacts and, where applicable, has described the alternative design options considered to mitigate potential impacts. Details of the assessment outcomes and mitigation are provided in the relevant topic chapters (e.g. terrestrial ecology, marine ecology and




historic environment) and within the site-specific Alternative and Design Evolution

chapters of the Environmental Statement (ES). For the Hinkley Point C Development Site, the Alternative and Design Evolution chapter considers:

• local site selection;

• land uses;

• landscaping;

• HPC proposals including the sources of cooling; length and location of the cooling water tunnels; the cooling water intake structures; the fish recovery and return system; and interim spent fuel storage; and

• material transportation to the development site during construction.

3.3.115 Queries were also raised relating to the Preliminary Works applications (the Site Preparation Works and the temporary jetty) and how these would be dealt with in the ES. The ES supporting the DCO application presents and assesses the undertaking of the site preparation works and the jetty works on the assumption that they are undertaken as consented through their respective preliminary applications. The principal reasons for the inclusion of the Preliminary Works are:

• The Preliminary Works are essential to the construction of a new nuclear power station at HPC, and their inclusion enables a more coherent assessment to be provided for the full construction phase of the HPC Project;

• At the time of preparing this EIA, neither element of the Preliminary Works had commenced;

• Whilst the Preliminary Works, if approved, are expected to have commenced development by the time the DCO application is determined, their progressive development would create a constantly changing baseline. A more coherent assessment is possible if the preliminary works are assessed as part of the overall HPC project.

3.3.116 However, the ES recognises that the scale and complexity of the HPC Project means

there is the potential for variation in the construction programme. On a project of this scale and complexity, any number of factors could arise which would alter the dates or timescales indicatively shown in the programme. To manage this, controls or limitations are proposed on the nature of construction activity, with the consequence that the principal effect of any changes to the construction assumptions would be to extend the overall construction period.

3.3.117 Comments were also received on the requirement to consider the cumulative impacts of the Project as a whole. At Stage 2, the early cumulative assessment work, which considered the potential Project-wide cumulative impacts, was presented in the preliminary Environmental Appraisal. The final cumulative impact assessment, submitted as part of the ES for the DCO application, presents in detail both the project-wide cumulative impacts and also those potential cumulative impacts with other non-HPC developments, taking into consideration all comments received both through the formal consultation process and direct informal consultation.




3.3.118 Finally, general comments received during the pre-application consultation noted a lack of commitment to mitigation within the preliminary environmental information provided for all phases of the Project from construction through to operation. At Stage 1 and Stage 2, when the majority of comments received related to the lack of mitigation proposals, many of the impact assessments were still ongoing, therefore, the need for measures to mitigate significant adverse impacts could not be fully defined. It should be noted that the design process for the HPC Project has been undertaken in parallel with the EIA and has taken into account emerging assessment outcomes. Therefore, wherever possible, measures to manage or mitigate adverse significant environmental impacts associated with the Project constitute an integral component of the overall design.

3.3.119 The ES supporting the DCO application provides details on the design options that

have been considered with respect to identified environmental impacts. Where significant environmental impacts have been identified through the EIA, the ES provides a commitment to implement mitigation measures (including monitoring and management), where possible at the appropriate time, either during construction or once the development is complete and operational.

3.3.120 Through the consultation process, EDF Energy has considered recommended mitigation measures and, where appropriate, entered into dialogue with the relevant statutory bodies and other interested groups on the proposed mitigation and its implementation.




i) Habitats Regulations Assessment

3.3.121 The majority of comments on the Habitats Regulation Assessment (HRA) have been received from the relevant statutory bodies, in particular, Natural England, the Environment Agency, The Countryside Council for Wales, the Marine Management Organisation and advisors to the relevant local authorities.

3.3.122 Consultation and dialogue has not been confined to the formal stages. There have been ongoing discussions with the key parties since 2008, initially to ensure work necessary to understand the baseline environment was properly scoped. This was followed by a process of information dissemination leading to discussions over design and location of infrastructure, taking account of sensitivities, and the most appropriate means of mitigating impacts.

3.3.123 The habitats interest within Bridgwater Bay tends to focus on bird assemblages, coral and marine vegetation and fish populations. Terrestrial interest centres on barbastelle bats. Key impacts can be divided into those associated with the construction of the power station, particularly the cooling water infrastructure and temporary jetty which lie within the habitat areas and, during operation, the impact of cooling water discharges on the marine environment.

3.3.124 The construction of the temporary jetty involved a number of detailed discussions - firstly, over where best to locate the facility and, secondly, how best to design the facility and carry out its construction. A number of locations in the vicinity of the development site were considered and discussed before the proposed location at the north-west end of the site was chosen, this area being the least sensitive for birds, marine vegetation and coral features. The design of the jetty was given special attention to avoid impacts on sediment transport within the estuary and to limit disturbance to the foreshore rock platform and vegetation. This led to an open latticed design being proposed. Construction methods were also discussed, with the approach being to avoid disturbance as far as possible to the rock platform and cliff line.

3.3.125 Discussions on cooling water infrastructure design focused initially on where best to locate the intake and outfall heads, taking account of operational requirements and environmental sensitivity. The principal aim of this work was to ensure adequate dispersion of warm water into the marine environment to avoid recirculation at the intake heads. An equally important consideration was to locate the structures so as to ensure good dispersion with respect to environmental sensitivity. The combined impact of both the Hinkley Point B and C stations operating at the same time was also an important consideration in terms of avoiding cumulative impacts of the warm water discharge from the two power stations.

3.3.126 Once the design fundamentals had been established, there followed a lengthy assessment of impacts and detailed design iterations which were discussed with the statutory consultees via the Marine Authorities Liaison Group and, more latterly, Habitats Regulations meetings. EDF Energy has provided evidence that the location of the intakes and outfalls and the resultant chemical and thermal behaviour of the cooling water discharges is unlikely to affect the integrity of the designated features.




3.3.127 With regard to more specific mitigation to deter fish and other marine life from becoming caught up in the cooling water system of the power station, a number of measures have been employed including the design and orientation of the intake heads, the addition of an Acoustic Fish Deterrent (AFD) system adjacent to the intakes to deter fish from the vicinity and for those fish and organisms that do enter the pipes, a Fish Return and Recovery (FRR) system at the intake screens.

3.3.128 These measures comply with guidance issued by the Environment Agency, and all necessary measures would be taken to ensure they work effectively when the power station becomes operational. The consultees have been made aware of these measures and commented on designs aspects, but further discussions on precise details and modes of operation will take place.

3.3.129 Finally, the ability to introduce bio-fouling agents to clear the intakes and outfalls is a measure EDF Energy would wish to maintain, although such action has not been necessary in connection with A and B station operation due to the inherent conditions of the estuary.

3.3.130 With regard to potential impacts on barbastelle bats, a mitigation package has been suggested and agreed. This includes providing an alternative roost and habitats for foraging.




j) Hinkley Point C Development Site

3.3.131 A substantial number of responses were received from statutory consultees and the local community about the Hinkley Point C Development Site during Stage 1, 2 and 2 Update consultations. These related to the life cycle of the Project from Preliminary Works through to decommissioning.

3.3.132 Key themes to emerge included the rationale behind seeking permission for Preliminary Works in advance of the main DCO application, as well as allied concerns over the ability to reinstate the site in the event of DCO permission not being granted. With regard to the construction of the power station, concerns over the amount of land required and the proximity of construction activities to neighbouring communities were strongly voiced in Stage 1, in particular from those living in the vicinity of the Development Site. There were particular concerns over potential environmental impacts such as noise, dust and light and visual impact.

3.3.133 In terms of the permanent development, while there was general support for the masterplan and landscape scheme, specific comments were made to encourage improvements to the layout and configuration of the plant.

3.3.134 With regard to operation and decommissioning of the plant, comments mainly focused on arrangements for managing spent fuel and radioactive waste.

3.3.135 EDF Energy made its case for Preliminary Works to go ahead in advance of DCO consent being granted on the grounds, essentially, that the works would bring construction timescales forward and in doing so bring the power station into operation earlier. The proposal was underpinned by parliamentary approval of the National Policy Statement for nuclear energy, which included strategic endorsement of the potential Hinkley Point site on safety, environmental and planning grounds. West Somerset Council approved the scheme in July 2011, subject to resolution of planning conditions and agreements.

3.3.136 Many local residents were concerned that the construction site was too close to their homes. In response to these comments, EDF Energy revised its working areas by pulling back from the Shurton valley to grid reference 144750mN, which generally runs along the valley’s northern crest. This amendment would reduce impacts of most concern to neighbouring communities. Allied to this proposal, at the start of main construction, the area below 144750mN will be subject to re-contouring works which would raise levels from 27m Above Ordnance Datum (AOD) up to 35m AOD at its western end, lowering to generally 30m towards the east. Once these levels were established, the area would be planted with trees to establish woodland with screening, amenity and ecology value. These measures would further mitigate impacts of the development by providing a more substantive barrier between the construction areas to the north and the villages to the south.

3.3.137 Responses to comments on the permanent layout and design of the development focused on making improvements to mostly peripheral elements, including relocating the Public Information Centre so as to allow the public to view the development from a more central location. Modifications to fencing on the northern edge of the development were also made which would help improve the experience of walkers using the coastal path incorporated into the sea wall. Efforts have also been made to




consult upon and seek enhancements to the landscape scheme proposed within the areas to be restored after construction, as large tracts of land would become available, and this was considered a great opportunity to improve the setting of the development.

3.3.138 At Stage 1 and Stage 2, consultees were interested in a number of aspects associated with the disposal of spent fuel and Intermediate Level Waste from Hinkley Point C. These included safety and environmental concerns, plus queries over the disposal strategy and the future availability of disposal facilities. Furthermore, comments were expressed regarding the transport, management and storage of waste and decommissioning funding.

3.3.139 With regard to spent fuel and radioactive waste management, EDF Energy’s response has been to set out its strategy and proposals from both a planning and a regulatory perspective, set against the backdrop of the Government’s long-term strategy for the storage of radioactive materials.

3.3.140 In terms of decommissioning, information has been provided on the legal requirements to put in place the necessary funds to ensure decommissioning can be carried out at the end of the operational phase. The planning and environmental implications of decommissioning would be subject to separate consent, at a later date, before the plant ceased operation.




k) Hinkley Point C Development Site Environmental

3.3.141 The proposals for Hinkley Point C and supporting environmental information, including studies undertaken to inform the Environmental Impact Assessment (EIA), have been shared and consulted upon throughout the pre-application consultation.

3.3.142 Throughout the pre-application phase, iterative development of the EIA and the design process has been ongoing. Where the design of the development has altered as a consequence of further environmental understanding, this has been detailed and consulted upon. Furthermore, comments received from both the formal and informal consultation with the statutory consultees and the local community have been taken into consideration and responded to accordingly, either through the formal consultation or informally through meetings or correspondence. See Chapter

4 of this report for more on informal engagement undertaken by EDF Energy.

3.3.143 Stage 1 consultation provided preliminary environmental information and a summary outlining the status of the EIA process for the HPC Development proposals. Appendix A.1 of the Stage 1 consultation document provided an Environmental Status Report which outlined the environmental baseline for the project area, a summary of the work undertaken to date, and further studies in progress or planned. It also provided a preliminary view of the potentially significant impacts, as well as viable mitigation measures. Environmental studies undertaken and proposed were generally welcomed by respondents.

3.3.144 All of the comments were reviewed following Stage 1 and, where applicable, addressed in the Environmental Appraisal provided at Stage 2, and in some cases through direct informal engagement with the statutory bodies and other interest groups. An overview of the key environmental issues raised during pre-application consultation is provided below:

ii. Contaminated Land and Groundwater

3.3.145 In general, comments demonstrated that a satisfactory level of baseline information was provided during Stage 1. Whilst the methodology was deemed adequate and appropriate, the consultees welcomed further detail on the ongoing survey data collection and analysis results when available. A number of comments were received raising concern over the potential for existing land contamination to have an impact during construction. This related to existing contamination within the site, in particular the identified asbestos in the north-east of the Development Site and also contamination at the adjacent Hinkley Point A site where there is the potential for contaminant transport to occur during the dewatering activities at HPC. As a result of the early assessment findings, and through the consultation process, it was identified that the assessment needed more detail on the dewatering operations during construction and that reference should be made to how potential land contamination and groundwater impacts could be addressed and mitigated. Statutory consultees commented on groundwater in terms of disposal of discharged waters from the dewatering process. EDF Energy engaged with the Environment Agency specifically on the issue of dewatering and contaminant transport and concluded, through detailed modelling, that there would be no impact of a regulatory or a health and safety concern. With regards to clearing and removing the asbestos located in the




north-east of the Development Site, EDF Energy has progressed with a separate application to Somerset County Council to remediate this area of land. This work commenced in early summer 2011 and is due to be completed in early 2012 prior to earthworks commencing.

iii. Flood Risk Assessment and Surface Water

3.3.146 A number of comments were received with respect to flood risk, requiring a comprehensive Flood Risk Assessment (FRA). The FRA prepared for the DCO application has been undertaken in accordance with the Government’s Planning Policy Statement 25: Development and Flood Risk (PPS25). It also takes into account the revised Draft National Policy Statements (NPS) for Energy (EN-1) and Nuclear Power Generation (EN-6). Key comments related to the scope of flood risk assessment, risks to third parties, safe access and egress and flood warning. Further clarity on the scope of the FRA has been achieved through ongoing dialogue with the Environment Agency. Early in the pre-application consultation period, the EA specifically advised on its national policy on culverting streams, and that consent for the proposed Holford Stream culvert would only be forthcoming if the need was proved to be exceptional and that there would be no adverse impact on flood risk, third party land drainage or environmental quality. In response, EDF Energy undertook a detailed review of the proposals to culvert Holford Stream and concluded that the culvert was the best available option to meet the engineering needs of HPC whilst ensuring no direct environmental impact occurs.

3.3.147 With regard to third party risk, the area of concern at Stage 2 ‘Preferred Proposals’ consultation related to the potential increase in flood risk at Stolford village due to infilling of Holford Stream Valley. In addition, there was concern relating to wave overtopping/breach of the defences protecting Stolford. The FRA has been subject to significant amendments since Stage 2 consultation, including further modelling and studies to inform and support the final assessment. There has been regular consultation with the Environment Agency, throughout the pre-application stage, on the scope, modelling outputs and drafts of the FRA prior to submission of the DCO application. The proposed mitigation measures identified in the FRA, together with potential adaptation measures to be actioned in the event of extreme climate change, demonstrate that flood risk could and would be managed for the lifetime of HPC. EDF Energy would create a flood compensation fund for those identified to be at increased risk as a result of the HPC development. Further information is provided in the Flood Risk Assessment.

iv. Terrestrial Ecology

3.3.148 Generally, comments received throughout the pre-application consultation confirmed that the baseline studies were sufficient to inform the EIA. However, comments received at both Stages 1 and 2 advised that more work was required to address overall impact of the development together with the associated development sites in order to assess overall ecological impact. EDF Energy also received feedback that further consideration should be given to the in-combination effects with other projects or plans. A comprehensive cumulative impact assessment was therefore undertaken, which assesses the Project-wide and cumulative impacts with non-HPC developments.




3.3.149 EDF Energy has undertaken regular dialogue with the relevant statutory bodies and interested parties (including Natural England, Somerset County Council and the Somerset Wildlife Trust) particularly in relation to landscaping proposals during construction to mitigate for potential impacts, and on the consideration of habitat creation and avoidance of habitat fragmentation within the landscape restoration plan. Species of significance with regards to designated sites (including the Special Protection Area, Special Area of Conservation, Sites of Special Scientific Interest and the Ramsar site) have been considered and consulted upon through both EIA and HRA processes.

v. Marine Environment

3.3.150 The potential impacts on the marine environment have been consulted upon throughout the pre-application period, including the effects of changes to coastal geomorphology and hydrodynamics, impacts on marine water and sediment quality, and marine ecology. Given the location of the site in relation to European designated sites, there has been considerable interest in the assessment of potential impacts on these designated sites and species of conservation value. It was recognised that the development has the potential to affect the integrity of designated sites and there is a potential need to undertake an appropriate assessment. Accordingly, in parallel with the EIA, a habitats regulations assessment has been undertaken to inform the appropriate assessment. This draws upon the assessment work undertaken for the EIA and has been subject to an ongoing consultation process with the key statutory bodies and interested parties, including the Environment Agency, Natural England and the Countryside Council for Wales. This ongoing work has informed the final design proposals for Hinkley Point C, identifying the need to provide mitigation measures to avoid having an impact on the integrity of the designated sites of European importance, including intakes designed to mitigate fish capture, and the need to provide a system to return fish to the marine environment.

3.3.151 It should also be noted that EDF Energy has engaged with the Environment Agency on environmental permitting requirements to discharge to watercourses. This is in particular reference to the Bridgwater Bay area during construction and operation phases where discharges will initially be via the construction outfall, switching to the operational outfall in the early phases of commissioning.

vi. Noise, Vibration and Air Quality

3.3.152 Specific comments on the environmental topic of noise and vibration, as well as that of air quality, requested that the assessments should consider both human and non-human impacts. It was also recommended that the consultation with local authority environmental health officers (EHOs) is undertaken to agree the scope and methodology of the noise and vibration assessment, and similarly the air quality assessment for the construction and operation of Hinkley Point C, including transport-related impacts. Early engagement was held with the relevant EHOs at the local authorities on the impact assessment. Since Stage 2 consultation, EDF Energy has consulted with West Somerset Council and Sedgemoor District Council on specific matters raised, reaching consensus on the initial findings, scope of the assessment and its outcomes.




vii. Landscape and Visual

3.3.153 A Landscape and Visual Impact Assessment (LVIA) was undertaken to determine the likely impacts on landscape character, and visual impacts resulting from the construction and operation of HPC. Comments received during the pre-application consultation process advised that the Environmental Statement should

demonstrate how the landscape proposals would integrate with the wider green infrastructure around the site and incorporate mitigation measures. Feedback also advised that further work was required on the actual visual representations of the Development Site on the existing landscape and heritage assets. The visual representations were agreed in consultation with statutory bodies and other interested parties following the Stage 2 consultation process, which also identified the representative views for verifiable visual images to support the assessment. The proposed landscaping, including mitigation measures, such as boundary treatment, have been secured through an iterative design process and in consultation with the relevant consultees. Mitigation of construction effects has been secured through the consideration of construction phasing and zoning of certain activities, and the establishment of boundary screening measures addressing views from nearby settlements and views along the coast from the west. This includes proposals to undertake early landscaping works to the south of the southern construction phase area to act as a screen for residents to the south of the site, both during the construction and operation of HPC.

viii. Cumulative Effects

3.3.154 A number of comments were received which reiterated the EIA regulatory requirement to provide an assessment of cumulative effects, in particular the in-combination effects with other consented or reasonably foreseeable projects or plans that have a spatial or geographical overlap with the potential effects associated with the Hinkley Point C Project. These included the proposed National Grid transmission infrastructure from Avonmouth to Bridgwater; the existing Hinkley Point power station complex; the decommissioning of Hinkley Point B; the development of Oldbury nuclear power station in Gloucestershire; the Steart Managed Realignment Project; and other major projects in the area. EDF Energy has undertaken a comprehensive cumulative impact assessment that assessed the Project-wide and cumulative impacts with non-HPC developments. The methodology and scoping of potential environmental impacts has undergone informal consultation with the relevant consultees.

3.3.155 In summary, during the pre-application consultation EDF Energy set out its environmental mitigation strategy for the HPC Project and identified the need to ensure that any significant adverse impacts would be appropriately managed or mitigated in ways which would be environmentally responsible and sensitive to both the needs of the community and the strategies of the relevant authorities. A best practice approach to EIA, including the identification of likely significant impacts and mitigation measures, has been adopted. Further discussions on proposed mitigation measures were held with relevant statutory bodies and other interested parties, including local residents, particularly during the construction phase. As a result of this consultation, EDF Energy made significant changes to the proposals and, amongst other measures, this included a change to the southern limit of the main construction area and provision of early landscaping, as described above.




l) On-site Accommodation Campus

3.3.156 EDF Energy proposes a 510-bed Hinkley Point C on-site accommodation campus and associated facilities on land within the wider HPC Development Site. The proposals for the on-site accommodation campus have been informed by formal and informal consultation responses received during Stage 1, Stage 2 and Stage 2 Update consultations.

3.3.157 Respondents chiefly commented on the need, suitability, siting, size and operation of the accommodation campus. It was considered by some, especially many of the residents closest to the HPC Development Site, that the accommodation campus and associated leisure facilities were too large for the proposed location and, in particular, that they were too close to the villages of Stogursey and Shurton. Many comments received suggested that the campus accommodation should be moved further north-east and away from the nearest local residents. Other respondents believed that the proposed development should not be located on a ridge and that it should be hidden from public view. Some felt that providing campus accommodation close to the HPC Development Site was the best option. Particularly in the Stage 1 consultation, respondents commented that the accommodation campus should only be temporary and that the post-operational priority should be to return the land to open space.

3.3.158 Sedgemoor District Council (SDC) and West Somerset Council (WSC), in particular, sought a robust examination and justification for the need and size of the accommodation campus, including alternative siting (for example, Hinkley Point A land). Alternative design proposals were also requested, such as a reduction in building heights and the relocation of facilities to reduce potential impacts on the character and environmental quality of the area. SDC and WSC requested connections between the accommodation campus and the wider community, seeking access to parts of the accommodation campus by local residents. SDC and WSC acknowledged that the provision of some on-site construction accommodation was essential for security or emergency cover and would reduce traffic movements on the wider road network.

3.3.159 EDF Energy has taken into account the comments and concerns made by respondents and evolved the design, scale and location of the accommodation campus throughout the pre-application consultation period. Although there was significant local opposition, the concept of an on-site accommodation campus was generally supported by those living further afield and statutory consultees. As explained in the Accommodation Strategy, there are two main benefits to locating campus facilities on, or adjacent to the HPC Development Site: transport benefits; and greater efficiency, safety and security of the construction programme. On-site accommodation is the best location for a campus, as it:

• enables workers to get to the site quickly and easily;

• removes the need to commute;

• is likely to be popular with workers, particularly those working night shifts or irregular/unsocial hours; and

• will ensure a rapid and effective response to any on-site issues or incidents.




3.3.160 The comments received during the consultation process influenced the size and siting of the on-site accommodation campus. The initial proposal was scaled down from 700 to 510 bedspaces to respond to local concerns regarding the number of workers. Careful consideration has been given to the public feedback about the size of the on-site accommodation campus. While some consultees, especially in the hamlets closest to the main site (Shurton, Burton, Knighton, Wick and Stolford), would like to see either no on-site accommodation or an even smaller on-site accommodation campus, this would materially reduce the operational efficiency of construction. A 510-bed campus was considered appropriate, balancing the clear advantages of locating as many workers as possible close to the main construction site against the range of local impacts that may arise. For more information regarding the size and principle of the on-site campus development, please refer to the Accommodation Strategy.

3.3.161 In considering the best siting of the accommodation campus at the HPC Development Site, EDF Energy looked at alternative locations in close proximity. Alternative sites included land north of Green Lane next to the existing Hinkley Point A site and land to the south of the existing Hinkley Point A and B stations.

3.3.162 It is considered that the most suitable location for the accommodation campus is within the area proposed, south of Green Lane. In response to requests from many local residents, and for efficient use of construction land, the campus has been located as far north as possible, away from the village of Shurton and in close proximity to the highway. Land directly north of the chosen site forms part of an area allocated as common land and is not in EDF Energy’s ownership or control.

3.3.163 EDF Energy has continued to develop the masterplan for the on-site accommodation campus to address the concerns raised by many local residents and consultees. Full details are provided with the HPC Accommodation Campus Design and Access

Statement. The key changes include:

• lower ground and embankment levels would reduce the visibility of the accommodation blocks from the south;

• the use of timber exterior cladding to blend in with the rural landscape to the south;

• moving the external sports pitches and associated car parking and toilet facilities to the north-east corner of the site to improve public access; and

• relocation of the accommodation campus car park to the north-west of the site to reduce potential noise impacts.

3.3.164 EDF Energy has responded further to concerns from local residents by proposing a number of mitigation measures, such as screening the campus with a planted landscape bund, minimising light spill towards properties south of the site, as well as providing visual mitigation and some noise attenuation for properties nearest to the campus location.

3.3.165 In response to requests from some respondents, and in line with the HPC Development Site final landscaping scheme, EDF Energy also intends to restore the site to greenfield/countryside once it is no longer needed. Details of this are set out




in the legacy restoration strategy, appended to Volume 2, Chapter 2 of the

Environmental Statement and will include the removal of all services and associated infrastructure that are no longer required and, along with new landscaping, would help to return the area to its original character.

3.3.166 In summary, EDF Energy believes that the proposed on-site accommodation campus represents the best balance between the operational requirements of the HPC Project and local considerations. Locating a proportion of personnel close to the construction site would not only reduce traffic impacts of the development but would also improve construction efficiency. If the overall proposals are approved, EDF Energy will continue to work closely with the local community to address concerns arising from the operation of the accommodation campus.




m) Cannington

3.3.167 The Cannington park and ride site, together with the other park and ride sites, forms part of an overall transport strategy to reduce the impact of traffic associated with the construction of the HPC Project on the local highway network. The park and ride sites would intercept car traffic at strategic points and provide parking and a direct bus service to the HPC construction site, thereby reducing car journeys and thus carbon emissions. The Cannington park and ride site is proposed to cater for those workers within the immediate catchment of the HPC Development Site (i.e. west of Bridgwater and within the Cannington area) and for visitors to the HPC Development Site. See Transport Assessment for more details.

3.3.168 At the Stage 1 consultation, EDF Energy also proposed a freight consolidation facility adjacent to the park and ride and campus accommodation in Cannington.

3.3.169 EDF Energy has carried out a thorough and iterative consultation process on the proposals. At each stage statutory consultees, other relevant stakeholders and the local community were invited and encouraged to comment on the proposals to help shape and influence their development by EDF Energy. The proposals at Cannington significantly changed as a result.

3.3.170 There were significant concerns raised, particularly during the Stage 1 consultation, about the scale of development proposed and its impact on the community of Cannington. There was strong local opposition to the idea of an accommodation campus in the village and a freight consolidation facility. The need for a park and ride in Cannington was also questioned by some respondents. In determining the most appropriate location for accommodation and freight facilities, EDF Energy has had regard to the character of the areas in which they are located and, as such, has removed all such proposals from Cannington, as explained below. Therefore, the proposals now include a much reduced park and ride site, which is located within one field boundary to the south of the village. This is considered to be of an appropriate scale, whilst reducing traffic travelling through the village. Many consultation responses welcomed the reduction in scale and supported the proposals presented at the Stage 2 Update consultation.

3.3.171 At the Stage 1 consultation, EDF Energy presented outline proposals for the ‘CAN-A search area’ which included a park and ride facility to accommodate up to 900 cars, together with a freight consolidation facility and campus accommodation for up to 200 construction workers. At this stage, the ‘CAN-A search area’ covered approximately 32ha, with proposals for development taking up approximately 17-20ha of this land.

3.3.172 Following the Stage 1 consultation, and in response to written responses received by statutory and other consultees, EDF Energy refined its proposals for the ‘CAN-A search area’, removing both the campus accommodation and freight consolidation facility, and reducing the size of the park and ride facility to 381 car parking spaces. The revised proposals were presented during EDF Energy’s Stage 2 consultation.

3.3.173 Following Stage 2 consultation, in response to additional written responses from statutory and other consultees, further amendments have been made to the design of the park and ride facility, including a reduction to 252 car parking spaces. These changes were designed to minimise and mitigate environment impact and enhance




the sustainability of the proposals. These proposals were presented at the Stage 2 Update and further comments were received. EDF Energy believes the scale of the park and ride development now proposed respects the scale and character of Cannington in that it is contained within a single field, within a limited area defined by Cannington and the A39. The development is for a temporary period of seven years and, once the park and ride facility is no longer required by EDF Energy for the construction of the HPC development, it will be returned to agriculture.

3.3.174 In response to feedback received during the Stage 2 and Stage 2 Update consultations about perceived environmental impacts, particularly in relation to lighting, noise and visual impact, further amendments were made to the proposals and mitigation proposed to minimise local impact, including:

• limiting the scale of the proposed park and ride so that it is within one field boundary and does not require any public footpaths to be diverted and includes limited disturbance to existing hedgerows;

• providing supplementary hedgerow planting and new trees in the field to the east of the park and ride site to help screen the development from homes at Oak Tree Way and Brownings Road;

• providing shields on lighting to minimise outward spill;

• proposing a security strategy which minimises risk to the operation of the park and ride site;

• limiting the size of the proposed small scale, temporary buildings on-site and proposing an elevational treatment to respond to similar buildings in the locality;

• locating development outside of areas of flood risk; and

• providing bunding (earth banking) along the western edge of the park and ride site to help screen the development from homes on Mill Close.

3.3.175 Further details on these proposals are provided in the Chapter 15, Volume 6 of the Environmental Statement.




n) Cannington Bypass

3.3.176 Over the course of the pre-application consultation period, EDF Energy’s proposed bypass around the village of Cannington has evolved to respond, where possible, to comments received from statutory consultees, other relevant stakeholders and the local community. Feedback has been received on a number of issues, including those relating to location, design and suitability of the development. Questions and comments were also received relating to the proposed development’s possible impacts on footpaths, landscaping, the character of the area and noise and light pollution, as well as potential legacy uses and benefits for the local community.

3.3.177 Comments were received which sought further justification of the need for a Cannington bypass and requested more information regarding the traffic modelling and a full environmental impact assessment. Many comments from the public sought further consultation on the potential route options for the bypass, including a Bridgwater bypass and a bypass around the eastern side of Cannington. Concerns were also raised about Cannington becoming a ‘rat-run’, and information was requested regarding what measures would be put in place to encourage use of the bypass. A number of the consultees suggested that the bypass should be completed before any construction at Hinkley Point C begins. Mitigation measures would be introduced ahead of the bypass being built.

3.3.178 Throughout the consultation, EDF Energy presented the western route around Cannington as the ‘preferred’ routing option. This preferred route runs approximately south to north commencing at the existing western roundabout on the A39 southern bypass and ending at the C182 north of Cannington. The principle of the development and preferred routing option remained consistent throughout the consultation period. However, the design and layout of the bypass has evolved in response to the feedback listed above.

3.3.179 At the Stage 1 consultation, EDF Energy presented the first outline proposals for the Cannington bypass. The western bypass was referred to as the ‘preferred’ routing option. However, a bypass on the eastern side of the village was also included at this stage.

3.3.180 Following the Stage 1 consultation, and in response to the written comments received by consultees, EDF Energy discounted the eastern bypass because, among other reasons, it was determined that it would result in a greater loss of high-quality agricultural land and impact on a greater number of properties. Also, any eastern bypass would need to be elevated to mitigate flood risk, which would have a consequential impact on visual impacts and transport movements required for construction of a more significant structure.

3.3.181 Feedback from the Stage 1 consultation also helped to inform alterations and improvements into the design of the preferred western bypass. These alterations are as follows:

• Inclusion of a signal-controlled crossing to enable pedestrians, in particular schoolchildren, to cross the proposed bypass safely.




• Inclusion of an oversized culvert to cross Mill Stream along the Brymore School access road and two balancing ponds to mitigate flood risk.

• Further development of the landscaping strategy, through the inclusion of planting, shrubs and hedgerows, having regard to the site context and visual impacts.

3.3.182 EDF Energy published the Stage 2 consultation to give consultees the opportunity to comment on these more specific proposals. Following the Stage 2 consultation, further amendments were made to the masterplan in order to minimise and mitigate any perceived impacts that were highlighted in the Stage 2 consultation. These improvements included.

• The addition of a cattle crossing and associated corral in the southern part of the site to enable cattle to cross safely.

• The inclusion of bat ‘hop-overs’ to minimise potential ecological impacts.

• Further development of the ecological mitigation strategy to respond to additional survey results.

• The use of noise bunds (earth banks) rather than acoustic fences to mitigate noise impacts, which respond more appropriately to the character of the area.

3.3.183 The improved bypass proposals were then presented to the consultees for a third time at the Stage 2 Update consultation.

3.3.184 On completion of Hinkley Point C, some members of the local community would like to see the bypass land returned to its original state. However, EDF Energy considers that the bypass should form an integral and lasting part of the public highways network. The bypass, once adopted by the highways authority, would continue to provide an alternative route to Hinkley Point C for the increased number of operational employees and for the additional workforce needed when maintenance works are carried out on the reactors. It would also help to absorb the traffic associated with the decommissioning of Hinkley Point A. Therefore, the bypass would continue to provide significant traffic mitigation for Cannington even after peak construction is complete.

3.3.185 It has also become clear from the consultation process that many people would prefer a Bridgwater bypass and think that this should be provided instead of the western Cannington bypass. EDF Energy does not consider a Bridgwater bypass is necessary to mitigate the impact of the Hinkley Point C construction. The reasons are fully explained in the Bridgwater Bypass Study, which is an Appendix to the Transport Assessment (Annex 7 to the Environmental Statement).

3.3.186 It is envisaged that the proposed development would take approximately 21 months to construct (including the preparatory works). It is anticipated that the development would be fully operational by the final quarter of 2014. For more information, see Chapter 3 of the Environmental Statement.

3.3.187 Traffic calming measures, such as road markings, speed limit changes and speed reduction measures, are proposed in Cannington village and on the C182 Rodway.




3.3.188 Throughout the pre-application consultation period, EDF Energy has committed to listening to the views of local residents, statutory consultees and other relevant stakeholders, and the Cannington bypass proposal has been developed following consideration of all the comments and views provided.




o) Combwich

3.3.189 The proposals for a freight laydown facility at Combwich and the refurbishment and extension of Combwich Wharf are designed to support the construction of Hinkley Point C (HPC). The facilities form part of the overall HPC Project transport strategy, and specifically the Freight Management Strategy, to promote sustainable transport. EDF Energy supports the principle of using water as a preferred means of transporting freight. The Freight Management Strategy is appended to the Transport Assessment, in Annex 7 of the Environmental Statement.

3.3.190 The existing Combwich Wharf would be refurbished and extended to maximise the water-borne transport of bulky construction goods and Abnormal Indivisible Loads (AILs). The new laydown facility would be used for the handling and storage of water-borne and, on occasion, road freight construction goods. When HPC has been completed, subject to approval, the refurbished Combwich Wharf would be retained and used by EDF Energy for occasional deliveries to Hinkley Point. The area of the freight laydown facility would be restored to its current use (agricultural land).

3.3.191 The proposals at Combwich have been developed after taking into account comments provided in the various stages of EDF Energy’s public consultations. The views of local residents, statutory consultees and other relevant stakeholders have been integral to the design development process.

3.3.192 It is clear from comments received that there is widespread support for the use of Combwich Wharf for the delivery of AILs, especially from statutory consultees. However, there has also been strong local concern within the community in Combwich about certain aspects of the proposals. A key feature of the comments from both the statutory consultees and other relevant stakeholders was the need to ensure that potential environmental impacts associated with the use of Combwich Wharf are minimised. Comments were also received, principally from statutory consultees but also the public, about the potential to create a new wharf facility at the HPC site in Bridgwater Bay, or to use the temporary jetty at HPC or Dunball Wharf for AIL deliveries in order to avoid using Combwich Wharf.

3.3.193 The appropriateness of locating the freight laydown facility at Combwich on a greenfield site within the floodplain was questioned from statutory consultees, other relevant stakeholders and the local community, including Combwich residents, who were concerned about the impact this development could have on the character of the village, increased traffic, noise and visual impact. Justification was sought for the need to locate the facility in Combwich, and questions were asked about what other sites had been considered and the reasons for discounting them.

3.3.194 Concerns were also specifically raised about proposals for fabrication activities; bus parking/servicing and a park and ride facility at Combwich; and the associated ancillary buildings. There was some support for the freight laydown facility at Stage 1 from statutory consultees, including Sedgemoor District Council and West Somerset Council, given their proximity to Combwich Wharf and location relative to the HPC Development Site.

3.3.195 At the Stage 1 consultation, EDF Energy presented proposals for the potential use of Combwich Wharf for the delivery of freight by water via refurbishment of the wharf




and use of nearby land as a freight consolidation/storage facility for water-borne goods. The locations for the freight consolidation/storage facility included land adjacent to Combwich Wharf and land to the north-west of Cannington (CAN-B). The Stage 1 consultation included details of other alternative options, including the use of other principal ports and the jetty at the HPC Development site, as well as the reasons why they were discounted (see Volume 7 Chapter 6 of the Environmental

Statement and the Alternative Site Assessment appended to the Planning

Statement for further information). The Combwich Design and Access Statement details how the proposals for development were amended as a result of comments made at Stage 1.

3.3.196 Following the Stage 1 consultation, and in response to the comments received from consultees, EDF Energy presented its preferred option for Combwich in its Stage 2 consultation. This comprised: refurbishment and extension of the existing Combwich Wharf facility to accommodate a range of water vessels; development of a freight logistics/storage facility on land to the south of Combwich Wharf and temporary unrestricted use of the EDF Energy-owned Combwich Wharf access road for transporting AILs during construction; and improvements to the Combwich Wharf access road and C182.

3.3.197 There were many comments raised by statutory consultees, other relevant stakeholders and the local community at this time about the adequacy of the consultation process. This included the fact that the proposals for the freight laydown facility, including use of the facility for fabrication, park and ride and for the storage of road freight, were not given at Stage 1 and only presented at Stage 2. It was not the intention at Stage 1 to provide detailed proposals – this was provided at subsequent stages of the consultation process.

3.3.198 In response to the Stage 2 consultation feedback, further amendments were made to the masterplan and were presented at the Stage 2 Update consultation. These amendments were in response to comments and were aimed at minimising and mitigating any perceived environmental impacts. In particular, the plans for fabrication facilities were removed, the size of the freight storage area reduced and bus parking was also removed. The key principles that influenced the design approach to the scheme at the Stage 2 Update, and the changes made to the scheme following comments raised at Stage 2, are detailed in the Combwich

Design and Access Statement.

3.3.199 Further amendments have been made to the masterplan in response to feedback received as part of the Stage 2 Update consultation. These are also detailed in the Combwich Design and Access Statement.

3.3.200 Specifically in response to concerns raised by Combwich residents about the proposed operations at Combwich Wharf and the freight laydown facility, EDF Energy has revised the proposed hours of operation from those stated at the Stage 2 Update consultation. The proposed hours of operation are set out in Volume 7,

Chapter 4 of the Environmental Statement.

3.3.201 For more information, please see Volume 7 of the Environmental Statement and the Combwich Design and Access Statement.




p) Williton

3.3.202 The Williton park and ride site, together with the other park and ride sites, forms part of an overall transport strategy to reduce the impact of traffic associated with the construction of the HPC Project on the local highway network. This would take place by intercepting car traffic at strategic points and providing parking and a direct bus service to the HPC construction site, and reducing car journeys and thus carbon emissions.

3.3.203 A park and ride site has been proposed at Williton to intercept workforce trips on the A39 from workers living to the west of the HPC Development Site and to reduce impact on the local highway network between Williton and the HPC Development Site. Williton is one of the most easterly places in the catchment to the west of the HPC Development Site, and therefore the location of a park and ride at Williton also helps to avoid workers travelling further away from the site in order to access the park and ride facility.

3.3.204 At the Stage 1 consultation, EDF Energy also proposed campus accommodation in Williton.

3.3.205 EDF Energy has carried out a thorough and iterative consultation process on the proposals. At each stage, statutory consultees, other relevant stakeholders and the local community were invited and encouraged to comment. This was to shape and influence the proposals being developed by EDF Energy, with the proposals at Williton significantly evolving as a result of this process. There was strong local opposition to the idea of an accommodation campus in Williton, the need for a park and ride was questioned by some, and there were concerns about the proposed location of the park and ride at the greenfield site in Mamsey Lane. In response EDF Energy’s proposals have evolved, with the park and ride site changing to the brownfield site at the former Smithyard Terminal and the removal of all accommodation proposals from Williton. A significant number of consultation responses welcomed the change in the park and ride site.

3.3.206 At the Stage 1 consultation, EDF Energy presented outline proposals for the ‘WIL search area’ which included a park and ride facility to accommodate up to 350 cars, together with campus accommodation for up to 200 construction workers. At this stage, two search areas were considered (WIL-A and WIL-B), covering 15.5ha and 20ha respectively, with the proposals taking up approximately 8.5ha of land. These search areas were to the immediate east and west of Williton respectively.

3.3.207 Following Stage 1 consultation, and in response to responses received from consultees, EDF Energy refined its proposals for the ‘WIL-A search area’, removing the campus accommodation completely and reducing the size of the proposed park and ride to approximately 328 car parking spaces. The revised proposals were presented during EDF Energy’s Stage 2 consultation.

3.3.208 Following Stage 2 consultation, EDF Energy proposed to change the location for the proposed development from the greenfield site at Mamsey Lane (WIL-A) to the brownfield site at the former lorry park, B3190, when the reduction in the number of workers anticipated to be using the Williton park and ride facility enabled further sites to be considered which could not previously accommodate the larger facility. The




park and ride facility was reduced to 160 car parking spaces. This was both in response to further responses from consultees and in order to provide a more sustainable development solution which would not result in the need to develop a greenfield site, whilst retaining the sustainability benefits of being able to pick up workers living within Williton en route to HPC.

3.3.209 There were a very limited number of consultee responses regarding the principle or detail of development from the Stage 2 Update consultation. No objections were received about the choice of site, although some raised concerns about the park and ride strategy generally. Notwithstanding this, the proposals include a number of mitigation measures to minimise local impact of the proposals, including supplementary landscaping and hedgerow planting, particularly around the perimeter of the site; shields on lighting to minimise outward spill; and limiting the size of the proposed small-scale, temporary buildings on site and proposing an elevational treatment in keeping with similar buildings in the locality. Further details on the proposed mitigation strategy are provided in Chapter 15, Volume 6 of the

Environmental Statement.




q) Bridgwater A

3.3.210 The proposals for a temporary construction workers’ accommodation campus at Bridgwater A are intended to create a high-quality environment and complement the ongoing redevelopment of the North East Bridgwater area. The campus would be well-designed and provide football pitches that would be open to the public to offset the loss of the Bridgwater Sports and Social Club facilities. On completion of the Hinkley Point C construction phase, the accommodation campus site would be returned to a state appropriate to facilitate future development. The proposed site at Bridgwater A is recognised to be contaminated, which acts as a barrier to its redevelopment. By remediating this contamination, EDF Energy would provide a serviced site which can be quickly developed once the campus has been decommissioned.

3.3.211 Throughout the consultation phase, EDF Energy has been committed to listening to the views of local residents, statutory consultees and other relevant stakeholders, with the result that the Bridgwater A accommodation campus has been designed following consideration of the comments and views provided.

3.3.212 Comments included those on the size, location and design of the development, the site’s suitability for development purposes, potential legacy uses and benefits for the local community.

3.3.213 Many respondents generally supported the location and principle of the proposed development, with others supporting specifically the siting of development on brownfield land. However, others respondents opposed the siting because they believed it may cause negative social impacts. Some consultees also expressed concern that the proposed development would result in the loss of playing pitches at the Bridgwater Sports and Social Club.

3.3.214 At the Stage 1 consultation, EDF Energy identified the ‘BRI-A search area’ (of which the site forms part) as a potentially suitable location to provide accommodation (in part or as a whole) for up to 500 construction workers. The site was identified on the basis of its size, availability and suitability.

3.3.215 Following the Stage 1 consultation, and in response to the comments received by statutory consultees, non-statutory consultees and local residents, EDF Energy selected the Bridgwater A site as a ‘preferred site’ option, and at the Stage 2 consultation it was proposed to construct a 1,075-bed accommodation campus with associated facilities.

3.3.216 At this Stage 2 consultation, some concerns were raised by local residents and stakeholders about potential impacts of the resident workforce on local community cohesion, crime and safety, and the capacity of local community facilities. In response, and to support demand from additional people living in the area, EDF Energy has proposed a strategy to manage any issues through a Worker Code of Conduct.

3.3.217 EDF Energy is also proposing to make contributions to local emergency services and other community provision to ensure that there is no detrimental impact from the




influx of workers on the wider area. For more information, please see the Community Safety Management Plan, Annex 6 to the Environmental Statement.

3.3.218 In response to the Stage 2 consultation and concerns about perceived environmental impacts, further amendments were made to the masterplan. This was not only to minimise and mitigate any perceived environmental impacts, but also to enhance the overall sustainability of the proposed development. Subsequently, it was proposed at the Stage 2 Update consultation to reduce the number of bedspaces, from 1,075 to 850, and to better align the masterplan with the principles of the North East Bridgwater Masterplan. The recreational facilities were also moved outside of the secure perimeter fence to allow the public and local community to access the sports pitches.

3.3.219 In response to consultation concerns that the proposed development would lead to the loss of playing pitches at the Bridgwater Sports and Social Club, EDF Energy plans to offer sports and leisure facilities at this and other campus environments for public use.




r) Bridgwater C

3.3.220 Over the course of the pre-application consultation period, EDF Energy’s proposed accommodation campus at Bridgwater C has evolved significantly to respond, where possible, to comments received from statutory consultees, other relevant stakeholders and the local community. Comments were received on a number of issues, including those relating to size, location and design of the development. Questions and comments relating to the site’s suitability for development purposes, as well as potential legacy uses and benefits for the local community, were also received.

3.3.221 Many comments supported the location and principle of the proposed development. There was particularly strong support for EDF Energy’s plan to make the site available to Bridgwater College after the campus was no longer needed for EDF Energy’s construction workers. However, consultees also expressed concern that the proposals would mean the loss of playing pitches at Bridgwater and Albion Rugby Football Club. Others raised concerns about the campus’s proximity to Bridgwater College and developing on land that may be contaminated. Clarification was also sought as to whether the site would be consistent with the Bridgwater Vision.

3.3.222 At the Stage 1 consultation, EDF Energy presented outline proposals for a 150-bedspace accommodation campus and associated leisure facilities on land currently used by Bridgwater and Albion RFC. The site was identified on the basis of its availability, suitability to accommodate a temporary campus and for its potential legacy benefits.

3.3.223 Following the Stage 1 consultation, and in response to the comments received from consultees, EDF Energy selected Bridgwater C as a ‘preferred site’ option. However, the extent of the site was reduced to omit the football pitch to the south of the site, as the club management did not wish to relocate. The first team rugby pitch was also removed from the proposed development area, with the proposed site reduced to the second team pitch only. In response to consultees who expressed concern that the proposal would still result in the loss of the playing pitch, the Bridgwater and Albion RFC will be relocating its training pitch to another site in Bridgwater.

3.3.224 EDF Energy published the Stage 2 consultation to give consultees the opportunity to comment on the more specific proposals. Following the Stage 2 consultation, further amendments were made to the masterplan to minimise and mitigate against any perceived environmental impacts. These masterplan amendments to enhance the overall sustainability of the scheme were highlighted in the Stage 2 consultation. It was proposed at Stage 2 Update consultation to remove the ancillary facilities to enhance operational efficiency and minimise the development area further by sharing facilities with those on the proposed Bridgwater A campus. It was also proposed to create a new safe and accessible access road off College Way to the accommodation campus for both vehicles and pedestrians, thereby maintaining security on-site and reducing the impact on the existing college car parking provision. It was also proposed that a new bus stop would be situated close to the accommodation campus for workers travelling to the Hinkley Point C Development Site. The proposed site boundary was amended to reflect the changes in the proposals.




3.3.225 EDF Energy is committed to working with Bridgwater College by designing the Bridgwater C campus to be adaptable for student accommodation when the construction at Hinkley Point is complete, subject to a separate planning permission being granted.

3.3.226 With this proposed development, EDF Energy has sought to identify ways to assist in meeting broader aspirations for legacy development outside of the Development Consent Order (DCO). However, a DCO may only grant consent for a Nationally Significant Infrastructure Project and any “associated developments”. By definition, a legacy use unconnected to the construction and operation of the power station cannot be an associated development and cannot, therefore, be consented through the IPC/DCO process. That is why a separate application would be needed to permit the site to be turned into a student accommodation.

3.3.227 Throughout the pre-application consultation period, EDF Energy has been committed to listening to the views of local residents, statutory consultees and other relevant stakeholders, and the Bridgwater C proposal has been designed in accordance with the comments and views provided.




s) M5, Junction 23

3.3.228 EDF Energy is proposing to construct a park and ride facility, freight management facility, consolidation facility for courier deliveries and induction centre to the west of Junction 23 of the M5 at Bridgwater. The proposed development is a key element of EDF Energy’s comprehensive transport strategy for moving workers and material to and from the Hinkley Point C construction site while minimising disruption to local communities.

3.3.229 Over the course of the pre-application consultation period, the proposed development at Junction 23 has evolved significantly to respond, where possible, to the comments provided. These ranged across a number of issues, including the size, location and suitability of all (or part) of the proposed development. Questions and comments from statutory consultees, the local community and general public also related to the site’s possible impact on the local road network, potential legacy uses and benefits for the local community.

3.3.230 Support for the proposed development was received from many of the consultees. Specifically, the location and principle of the park and ride facility were widely supported by respondents.

3.3.231 At the Stage 1 consultation, EDF Energy identified the ‘J23-A search area’ as a potentially suitable location to accommodate some or all of the following land uses:

• a park and ride facility to accommodate up to 750 cars; and

• a freight consolidation facility for road freight.

3.3.232 Land around Junction 23 was considered an appropriate location for this development given its proximity to the strategic and local highway network to transport freight and workers to and from the HPC site. The J23-A search area was located directly to the west of the A38 Dunball Roundabout and incorporated the majority of the proposed Junction 23 development site.

3.3.233 The J23-A search area was identified as EDF Energy’s proposed location at the Stage 1 consultation. However, the Alternative Sites Assessment explains that

five alternative sites around Junction 23 had originally also been considered, but were later ruled out as unsuitable against one or more of EDF Energy’s three key criteria: size/availability, location and access.

3.3.234 Amendments were made to the proposal and presented at the Stage 2 consultation. The preferred development consisted of a park and ride facility (748 car parking spaces) and a freight logistics facility (75 HGV parking spaces) to be used during the construction phase of HPC. Supporting facilities included 16 mini-bus and van parking spaces, motorcycle and bicycle parking, a bus terminus, on-site offices, a freight logistics facility building, highways infrastructure and landscaping, including landscaped spoil mounds to provide screening.

3.3.235 The proposed layout was amended along the southern boundary to omit an existing hedgerow and watercourse from the site and thus minimise any ecological impact. Additionally, a triangle of land immediately to the west of Dunball Roundabout was




removed from the layout because Sedgemoor District Council (SDC) supported the use of this land for a gateway development. The omission of this land from the layout would enable permanent development of the site to be advanced by other parties.

3.3.236 Following the Stage 2 consultation, and again in response to responses received from consultees, further amendments were made to the masterplan in order to avoid, or mitigate against, any perceived environmental impacts and improve the suitability of the proposed development. For example, the proposed park and ride facility was increased to 1,300 parking spaces to accommodate a larger estimated workforce. The freight management facility was also increased to 85 spaces to match the larger estimated quantity of materials. In response to the feedback, the position of the park and ride and the freight management facility were switched so that the park and ride would be on the north side of the site and the freight management facility on the south. An induction centre was also added to the proposed development to create a secure and accessible facility for HPC construction workers.

3.3.237 The amended proposals were then presented to consultees at the Stage 2 Update consultation.

3.3.238 At the Stage 2 Update consultation, many comments were received regarding the operation of the induction centre as well as the reason for its location at the Junction 23 site. As stated in the Planning Statement, there is a clear requirement to ensure

that workers involved in the HPC construction phase are properly inducted. Junction 23 was chosen as the most appropriate location for this facility as it has good access from the national motorway network and is easy to find. It is also logical from an operational and security perspective to cluster together, where possible, EDF Energy’s associated developments on single sites. For the majority of workers, induction is planned as a one-off, full-day session on safe working practices, code of conduct and procedures for the Hinkley Point C site. Workers would arrive at the induction centre trained and ready for employment, and the induction centre will not be used for continued learning or professional training.

3.3.239 A number of comments were received throughout the consultation process that expressed a desire to make Junction 23 the location of more, if not all, of the HPC park and ride facilities. As part of the transport strategy, EDF Energy proposes four separate, strategically-located park and ride facilities covering a wide geographical area to reduce trips on the local highways network. To make Junction 23 the only park and ride site would be incompatible with the transport strategy and result in increased local traffic. A full explanation of the rationale behind the location of the park and ride sites is set out in the Transport Assessment.

3.3.240 Comments were received which objected to the principle of the development on the basis that it would result in the loss of greenfield land. As explained in the Post-

operational Strategy appended to the Planning Statement, the proposed Bridgwater park and ride would be removed once the HPC construction is complete and EDF Energy proposes to reinstate the land to its current agricultural use.




t) M5, Junction 24

3.3.241 EDF Energy is proposing to construct a park and ride facility, freight management facility, temporary consolidation facility for postal/courier deliveries and temporary induction centre to the north-west of Junction 24 of the M5. The proposed development is a key element of EDF Energy’s comprehensive transport strategy and would help move workers, materials and deliveries to the Hinkley Point C construction site, while minimising disruption to local communities.

3.3.242 The proposed development at Junction 24 has evolved to respond, where possible, to the comments provided. Comments were received on a number of issues, including those relating to size, location and suitability of all, or part, of the proposed development. Questions and comments relating to the site’s possible impact on the local roads network were also received. There was significant opposition from residents of the new housing at Stockmoor village to the proposed location of these facilities on the adjacent greenfield site, with particular concerns expressed about noise, lighting, traffic and visual impact.

3.3.243 The most significant change to the J24 proposals has been the relocation from the greenfield site adjacent to Stockmoor village to the south-west of A38 (Huntworth) Roundabout to the brownfield site north-west of Junction 24 of the M5.

3.3.244 At the Stage 1 consultation, EDF Energy identified three search areas (J24-A, J24-B and J24-C) around Junction 24 of the M5 as potentially suitable for a park and ride facility and a facility for road-borne freight. At Stage 2 consultation, EDF Energy identified J24-A search area (land to the south-west of A38 (Huntworth) Roundabout) as its ‘preferred site’ in the vicinity of M5 Junction 24. The scale of development in this location was refined, increasing the size of the park and ride facility to 698 parking spaces and proposing 45 HGV parking spaces. At the Stage 2 Update consultation, further amendments were made to the ‘preferred site’ masterplan.

3.3.245 Following the Stage 2 Update consultation, EDF Energy became aware that the existing Somerfield storage/distribution site at Junction 24 would be vacated by the current occupier towards the end of 2011. Given that the Somerfield site was a brownfield site, due to become vacant and could come forward earlier than the other proposed associated development sites, EDF Energy consulted on the Somerfield site as a potential alternative to the ‘Preferred Proposals’ at Junction 24. Following the outcome of this consultation, EDF Energy took the decision to include the Somerfield site as part of the application for Development Consent, instead of the J24-A site.

3.3.246 Due to the existing infrastructure on the Somerfield site, EDF Energy was presented with the opportunity to provide additional park and ride spaces (a total of 1,300) and freight management facility spaces (a total of 140), as well as a temporary consolidation facility for postal/courier deliveries and a temporary induction centre until other associated development sites become operational. Once the associated development site at Junction 23 becomes available to use, the number of park and ride spaces at Junction 24 will reduce to 698 and the number of freight management spaces will reduce to 55. The consolidation facility for postal/courier deliveries and induction centre would also be removed from the Junction 24 site.




3.3.247 On this basis, a number of site-specific concerns relating to the development of a park and ride facility and freight management facility on the J24-A site have been addressed through the relocation of the proposals to the Somerfield site.

3.3.248 Overall, there was strong support from statutory consultees, local residents and members of the public for the change to the Somerfield site. In their joint response to the M5 Junction 24 and Highways Improvements consultation, SDC and WSC stated that the proposal to provide a park and ride facility and freight management facility was acceptable in land use terms. SDC and WSC acknowledged that the development would support the delivery of the HPC Project, which in turn would provide jobs and has the potential to support economic development in both Sedgemoor and West Somerset. Comments from local residents and members of the public also stated a preference for the Somerfield site over the previously proposed site at Junction 24. The main issues that respondents commented on related to the temporary induction centre and the agreement of a robust, deliverable and effective transport strategy for the HPC Project and an assessment of environmental impacts.

3.3.249 The Alternative Site Assessment which is appended to the Planning Statement

explains the requirement for the induction centre at an associated development site and at a motorway junction. Due to the functions accommodated as part of EDF Energy’s induction process, including drug and alcohol testing and the collection of biometric data, EDF Energy requires the induction centre to be in an accessible, secure and well-defined location and remote from the HPC Development Site. A bespoke building would be required to ensure the efficient movement of workers through the process and to provide secure storage of the data collected.

3.3.250 Providing an induction centre facility at Junction 24 is not a long-term solution for EDF Energy because the available facilities would not be suitable for the Company’s induction requirements. The Alternative Site Assessment explains that once the Junction 23 site becomes operational, the induction centre function would be transferred from Junction 24 to Junction 23.

3.3.251 The Transport Assessment describes the analysis of the impacts of the

construction and operation of HPC on the local and strategic highway network. Further details and a robust assessment of the impacts of the proposed development at Junction 24 are included in Volume 9 of the Environmental Statement.




u) Planning Strategy

3.3.252 The status and relevance of planning policies and the way in which they should affect the Hinkley Point C proposals has been the subject of extensive comment, mainly by statutory bodies, throughout the different stages of consultation. The engagement with stakeholders on planning matters has been helpful in clarifying the status and requirements of planning policy.

3.3.253 The principal issues can be grouped under the following four headings:

• the status and effect of national policy;

• the relevance and importance of local formal and informal policies;

• the extent to which the Hinkley Point C Project should be designed to generate a legacy for local communities; and

• the impact of planning policies on the mitigation of impacts.

i. The Significance of National Planning Policy

3.3.254 Some respondents expressed concern through the consultation process at EDF Energy’s apparent reliance upon emerging national policy, particularly when it was only draft policy. Others expressed concern at the nature of national policy and, in particular, were concerned that it did not take sufficient account of local considerations. Additionally, respondents expressed concern that EDF Energy cannot simply rely on national policy and that national policy provides no excuse for not undertaking comprehensive assessment of impact.

3.3.255 Government policy on nuclear power was established in a White Paper on Nuclear Power in January 2008.

3.3.256 The documentation of national policy has changed throughout the evolution of the Hinkley Point C Project. National Policy Statements (NPSs) for Energy and for Nuclear Power Generation were considered by Parliament and designated by the Secretary of State in July 2011. Draft NPSs were available from an early stage in the project and were subject to their own extensive consultation exercises.

3.3.257 The principal reliance which EDF Energy has placed on NPSs through the emergence of the Hinkley Point C Project is to anticipate that the finally designated NPSs would confirm the potential suitability of Hinkley Point as a location for a new nuclear power station. This appears to be a common expectation among respondents, principally as a result of the Strategic Siting Assessment and related exercises undertaken by the Government from 2008. Most stakeholders also recognised the likelihood that Government would endorse the need for new nuclear power generation and the urgency of meeting that need as set out in the Energy White Paper in May 2007 and the White Paper on Nuclear Power published by Government in January 2008. These statements of national policy gave EDF Energy the confidence to proceed with the preparation of the Hinkley Point C DCO application.




3.3.258 A consistent feature of emerging national policy, however, is that it has identified the “potential” suitability of sites for new nuclear power generation. The emerging drafts of policy have stressed that the ultimate decision, by the Infrastructure Planning Commission (IPC) or by the Secretary of State, would have to be based on a thorough assessment of the impacts and benefits of the development. In other words, EDF Energy has taken nothing for granted and has recognised an obligation to prepare its proposals thoroughly and comprehensively and to engage in detailed consultation with all stakeholders.

3.3.259 The Planning Act 2008 (the Act) set up a new regime for the consideration of Nationally Significant Infrastructure Projects (NSIPs). The related guidance stresses the important role played by local planning authorities in the process, including the requirement for planning authorities to prepare a Local Impact Report (LIR), which should give details of the likely impact of the proposed development on the authority’s area. This requirement, together with the expectation that there would be extensive public engagement, ensures that any decision will be fully informed by local considerations.

3.3.260 Nevertheless, the Act makes clear that the NPSs will provide the primary policy guidance for the IPC and contains a presumption that the IPC’s decision would be made in accordance with the NPS, unless a range of limited circumstances arise including, importantly, whether the overall impacts of the development outweigh the benefits.

3.3.261 EDF Energy has been conscious, therefore, that the regime requires the NPSs to provide the principal policy guidance for the determination of an application for development consent. The Act also enables the IPC to take into account any other matter that it considers both important and relevant, and this could include local planning policies. Consequently, EDF Energy has had careful regard to local policy in the formulation of its proposals (see further below).

3.3.262 It is important to understand, however, that the NPSs are intended, in principle, to provide a single source of reference for the main planning policy considerations. Paragraph 4.1.5 of NPS EN-1 (Over-arching National Policy Statement for Energy) makes clear that the energy NPSs have taken account of relevant Planning Policy Statements and Planning Policy Guidance Notes, so that it should not be necessary to consult those national policy documents as well as the NPSs in considering applications for energy NSIPs.

3.3.263 The same paragraph also recognises that local planning policy may be considered by the IPC to be both important and relevant, but:

“in the event of a conflict between these or any other documents and an NPS, the NPS prevails for the purposes of IPC decision making, given the national significance of the infrastructure.”

3.3.264 The reliance placed by EDF Energy on the NPSs, therefore, is appropriate and understandable.

3.3.265 EDF Energy does not agree, however, that the NPSs pay insufficient regard to local considerations. Both NPS EN-1 and NPS EN-6 (National Policy Statement for




Nuclear Power Generation) stress the full range of considerations which the IPC will be required to take into account in determining an application for development consent. These include all matters which are potentially capable of having a significant environmental effect on the local or wider area. The NPSs, therefore, ensure that EDF Energy must address local impacts on matters such as archaeology, ecology, landscape and visual impact, transport, noise and air quality. These considerations are directly addressed within the Environmental Statement.

3.3.266 Some respondents expressed concern that the NPSs do not address the particular requirements for associated development. It is certainly true that the NPSs only identify the potential suitability of the Hinkley Point C Development Site itself for nuclear power generation and provide no direct guidance on the extent or location of any necessary associated development. Nevertheless, the Act establishes a single consent process for the NSIP and development associated with it, namely development which is subordinate to and necessary for the development and efficient operation of the NSIP. Sites which may be required to support the construction or long-term operation of the nuclear power station, are appropriately included in the application for development consent. The NPSs make sure that those proposals would be subject to the same scrutiny of environmental and other issues as the main power station itself.

3.3.267 EDF Energy has not significantly changed its proposals as a result of consultation responses relating to national policy. Those consultation responses have ensured, however, that EDF Energy is aware of the need for a comprehensive assessment of the impacts of the Hinkley Point C Project and to ensure that proper account is taken of all relevant local considerations.

3.3.268 These and related issues are reviewed in detail within the Planning Statement.

ii. Local and Other Policy documents

3.3.269 The above paragraphs have explained that National Policy Statements (NPSs) provide the primary policy for the determination of nationally significant infrastructure projects (NSIPs) but also that the IPC may take into account any other matters which it considers both important and relevant and that this may well include local planning policy. It is clearly important that the Act establishes a new and separate regime for national infrastructure and that there is no statutory requirement for proposals for development consent to comply with local planning policy or for Local Development Frameworks to be the starting point for consideration. Nevertheless, local policy can provide helpful context for the consideration of proposals.

3.3.270 In relation to existing local planning policy, both the West Somerset Local Plan and the Sedgemoor Local Plan pre-date the Strategic Siting Assessments and other developments associated with national policy. They did not anticipate the national identification of Hinkley Point as a potentially suitable location for a new nuclear power station and, therefore, the plans are out of date. It would not be appropriate to judge the Hinkley Point C proposals on the basis of whether they complied or not with pre-existing local planning policies.

3.3.271 Similarly, it would not be appropriate for emerging local policy to set tests or requirements for national infrastructure which duplicate or go beyond the policy tests




already set out in the NPSs. This much has recently been confirmed by the Inspector who examined the Sedgemoor Core Strategy. Consequently, it would not be appropriate for the planning authorities to develop formal or informal (supplementary) planning documents which set tests or policies for Hinkley Point C.

3.3.272 None of this means, however, that existing local policy is unimportant. The planning designations of individual sites are certainly important considerations (for example, the County Wildlife site designation is part of the Hinkley Point C Development Site), and local policy documents are helpful in flagging up a wide range of considerations that have been taken into account in the evolution of the Hinkley Point C proposals. They cannot, however, determine the acceptability of the proposals, which will be assessed against the detailed assessment principles set out in national policy.

3.3.273 EDF Energy’s proposals have been influenced by the principal themes apparent in local policy and directly affected by discussions with key stakeholders on policy issues. Examples of local policy considerations which have influenced the Project include:

• the preference for brownfield rather than greenfield land;

• the appropriateness of Bridgwater as a centre for development;

• the need to respect the character and amenity of local settlements;

• the importance of nature conservation, landscape and other designations affecting the application sites;

• the importance of avoiding adverse impacts, for instance on the local housing or tourism market; and

• the importance of ensuring that Hinkley Point C maximises its local economic benefits and contributes to the councils’ strategies for restructuring and growing the local economy.

3.3.274 Again, these issues are reviewed in more detail in the Planning Statement.

iii. Legacy Strategy

3.3.275 Some respondents emphasised that the development of Hinkley Point C should leave a long-term beneficial legacy for the local area. Others have gone further and suggested that the selection of sites for associated development should be driven by a legacy strategy so that the development of Hinkley Point C brings indirect, as well as direct, benefits to the local area. For example, respondents have suggested that EDF Energy must select contaminated brownfield land and regenerate it to meet its associated development requirements, leaving a legacy, for instance, of affordable housing on associated development sites.

3.3.276 In practice, EDF Energy has been conscious of a much wider range of considerations that need to be taken into account in the selection of associated development sites and also of the constraints imposed by legislation and policy.

3.3.277 In this latter respect, the fundamental purpose of the new regime set up under the Planning Act 2008 is to secure nationally important infrastructure in an




environmentally acceptable and sustainable way. It is the delivery of the infrastructure that the nation needs which is the most important consideration. Accordingly, the new regime exists only for proposals which fall within the strict definition of NSIPs, and applications for development consent cannot extend to housing, or to other short or long-term proposals which are not directly required for the construction and/or operation of the power station. EDF Energy, therefore, cannot include within its development consent application proposals for alternative long-term uses of land which are not directly related to the power station.

3.3.278 Some respondents suggested that EDF Energy could make Town and Country Planning Act applications for permanent housing. However, EDF Energy has been conscious of its necessary focus on delivering nationally important infrastructure and also of the clear advice provided in national policy about planning obligations. It would not be appropriate to include obligations that are unnecessary for the construction or operation of the HPC Project or not directly related to its development.

3.3.279 Partly for this reason, but mainly to guide the evolution of the overall Project, EDF Energy adopted its own vision for the Project and consulted on that vision as part of its Stage 2 proposals. That vision is as follows:

“EDF Energy intends to deliver a nuclear power station at Hinkley Point C that

will make a major contribution to the nation’s low-carbon energy needs. The

development, operation and ultimate decommissioning of the power station will be

undertaken in a manner consistent with the highest standards of safety, reliability

and sustainability.

“EDF Energy will strive to ensure the inherent benefits of its investment at Hinkley

Point C are captured in a way which maximises its practical contributions to the

local and regional economy.

“EDF Energy will ensure that any significant adverse effects of the construction,

operation or decommissioning of the power station are appropriately mitigated in

a way that is environmentally responsible and sensitive both to the needs of the

community and to the strategies of the relevant authorities.”

3.3.280 EDF Energy’s emphasis, therefore, has been maximising the inherent benefits of Hinkley Point C, rather than seeking to secure support by offering extraneous benefits.

3.3.281 The Alternative Site Assessment details the many considerations that have gone into the selection of sites for associated development. Legacy has not been a principal determinant. Other considerations have been more important, including the need to ensure that sites meet the operational requirements of the Project and that they respect local amenity considerations. Where some flexibility has been available in site locations, brownfield sites have been preferred. Remediation benefits would arise, for instance, through the development of the BRI-A site in Bridgwater, and the design of sites has had regard to potential future uses of the land. A Post-

Operational Use Strategy has been developed, which would allow an appropriate

determination of the extent to which facilities constructed to serve the construction process of Hinkley Point C may be retained in the longer term to serve other needs.




3.3.282 By far the more important legacies generated by the development, however, will be its long-term contribution to the nation’s low-carbon energy supply and its long-term contribution to the local economy. In addition, proposed development consent obligations would secure a comprehensive range of benefits locally, including the legacy of a skilled and trained workforce and a legacy of transport, leisure, environmental and other enhancements to which EDF Energy has committed. These inherent benefits of the Project meet EDF Energy’s vision for the Project and ensure that substantial net local benefit would arise from the development of Hinkley Point C.

iv. Mitigation

3.3.283 Much of EDF Energy’s engagement, with planning authorities in particular, has been concerned with proposals for mitigation to be contained within the requirements and obligations attached to any development consent. This has been a detailed and instructive debate that has served to enhance the Project.

3.3.284 Planning policies for mitigation are clear. National policy set out in the Energy and Nuclear Power Generation NPSs identifies, for the benefit of the IPC, the approach which applicants are expected to take to limit the impacts of development and to mitigate significant residual impacts. Local planning policies should not alter those principles, although the detail of local policy has been helpful in defining specific mitigation, such as the contribution to the Bridgwater Strategic Flood Defence Tariff, which is based on a levy established in local planning policy.

3.3.285 The principal mitigation for the Project, however, has been defined based on an understanding of the likely impacts of the development – an approach directly consistent with national policy.

3.3.286 National policy does not require applicants to compensate for the impacts of development, except in the limited circumstances where compensatory habitat needs to be created to offset significant impacts on designated nature conservation interests which cannot be avoided or mitigated. There is no obligation to provide wider compensation or extraneous community benefits. Instead, EDF Energy has sought to ensure that the inherent benefits of the project are captured locally, where practical. The process of consultation has enabled detailed discussions to take place around precise mitigation proposals, and this has significantly informed the draft

Heads of Terms set out in the Planning Statement.




v) Consultation

3.3.287 EDF Energy has undertaken long and extensive consultation on its proposals for the Hinkley Point C Project over a period of nearly three years, between 2008 and 2011.

3.3.288 This has consisted of a combination of formal and informal consultation and has taken place with statutory and non-statutory stakeholders, local community and general public. The formal consultation took place in four stages: Stage 1, Stage 2, Stage 2 Update, and Junction 24 and Highways Improvements.

3.3.289 Although comments were received on a large range of issues from all types of consultees, some aspects of the consultation were of more interest to specific types of consultees than others. The local community and general public, for example, tended to focus on the areas of the consultation specifically targeted at them, such as the questionnaires and public exhibitions, whilst statutory consultees focused more on the level of detailed information available to them. The local authorities, in their dual roles as statutory consultee and consultee with an interest in land, along with their ability to submit adequacy of consultation representations (pursuant to section 55(4)(b) of the Planning Act 2008), generally made comments on the full range of issues, including the consultation strategy that they were consulted on during preparation of the Statement of Community Consultation (SoCC).

3.3.290 The process of the formal consultation stages received particular attention from all consultee groups, with issues raised covering the overall consultation strategy and scope, the timings of the formal consultation periods, the types of consultation events, consultation fatigue, how feedback was being taken into account, and how the consultation was communicated. Where possible, EDF Energy amended its consultation strategy and processes following the feedback received in the early stages of consultation.

3.3.291 The content of the consultation material was also raised by a large number of consultees. Much of this focused on a desire to see different levels of information in the documentation, but consultees also commented on the accessibility and consistency of the documentation, how their feedback was being represented within it and overall readability. Some statutory consultees wanted more information than was currently available at that consultation stage, whilst the general public and local community focused more on the summary material and, variously, wanted more or less information.

3.3.292 EDF Energy took account of feedback received at Stage 1 in the design of consultation materials used in subsequent stages of consultation, in an effort to make relevant information accessible to different audiences according to their different needs. Summary documents were designed to provide key information relevant to all, while technical information primarily aimed at statutory consultees was also made available.

3.3.293 Connected with the consultation material were the questionnaires used by EDF Energy as a tool to encourage feedback. Comments on the questionnaires were mainly received from members of the local community, as the primary audience for this format of feedback. Issues were raised about the choice of questions, as well as the phrasing, order, and contextual information for each question.




3.3.294 The development proposals at each stage of consultation were presented by a variety of methods. Exhibitions, in particular, which were staffed by EDF Energy and its specialist consultants, received attention from consultees, especially the local community. Comments were received about the staffing and availability of exhibitions, the location of venues and timings of events.

3.3.295 Although critical comments were received regarding some exhibitions in particular, where there were high numbers attending, independent exit surveys showed that most visitors found the exhibition material useful and the staff helpful.

3.3.296 The question of further consultation was raised throughout the consultation stages, with statutory and non-statutory consultees, the local community and general public wanting more information or to see revised proposals taking their comments into account. As a result of this feedback, and due to ongoing development work on the Project requiring material change, two additional stages of focused formal consultation were undertaken after the Stage 2 consultation.

3.3.297 In February 2011 Somerset County Council (SCC) provided EDF Energy with its draft assessment of EDF Energy’s Stage 1 and Stage 2 consultations. In it, the Council acknowledged that the consultation had complied with the published SoCC at each stage and followed the “spirit and letter of CLG guidance”. Positive comments were also made about the breadth of communication channels used; the consultation website; the questionnaire; the quality of consultation materials and the consistency of messaging; and the knowledge, courtesy and helpfulness of EDF Energy staff at the public exhibitions. However, concerns were expressed about the extent of engagement with hard-to-reach groups, although the Council recognised that this had improved since Stage 1. In its reply, EDF Energy did not accept the Council’s criticism of hard-to-reach engagement up to Stage 2, but since Stage 2 there has been further engagement with these groups.

3.3.298 SCC’s response to EDF Energy’s comments on the Council’s assessment of Stage 1 and 2 consultation noted that, in some instances, people who have strong concerns about a particular aspect of the Project’s proposals may find it difficult to distinguish between their view of the adequacy of consultation and their response to specific issues raised during the consultation.




w) Issues Beyond the Scope of the Consultation

3.3.299 A number of responses throughout the consultation process offered both positive and negative comments on the need for new nuclear power and whether other sources, such as renewable technologies, are more appropriate to meet UK energy needs. These responses also raised various issues around the cost, safety, security and waste management of nuclear power stations, and the impacts on the local environment.

3.3.300 As explained further in the Planning Statement, a number of these issues are beyond the scope of the DCO process, having been reviewed at a national policy level or covered by other regulatory regimes.

3.3.301 There was a mix of views expressed, with most responses from the individual members of the general public divided between those concerned and against nuclear development in general – for reasons of safety, cost and ethical concerns – and those who were supportive and felt that new nuclear power stations and Hinkley Point C were urgently needed to provide local jobs, energy security and reduced reliance on fossil fuels. There were also a number of responses that were generally supportive of nuclear power but concerned as to whether local impacts on issues, such as traffic and community resources, would be properly addressed. Some individuals responded that they had no objection in general to nuclear power, but did object to the proposed development at Hinkley Point due to the perceived impacts on the local community and its infrastructure.

3.3.302 With a few exceptions, statutory consultees were supportive of the development, some pointing out the likely benefits, but they were also concerned about the impacts on the community, particularly as a result of the construction and length of time that waste may be stored on the site. A number of non-governmental organisations stated their reasons for objecting to nuclear development as a whole but provided no specific comment on the detail of EDF Energy’s proposals at Hinkley Point.

3.3.303 There were a number of responses at all stages of consultation from respondents, both individuals and organisations, who stated they had no preference on the proposals or who felt they would not be affected by the development. These were largely from consultees who felt they were located too far from the proposed site for the development to have an impact. This included a number of statutory bodies that the Act requires the developer to consult.




3.4 Qualitative Summary of Workshops and Focus Groups

a) Introduction

3.4.1 This section provides a more detailed breakdown of the key issues raised during the stakeholder workshops, focus groups and the tourism survey that took place as part of the Stage 2 consultation on EDF Energy’s ‘Preferred Proposals’ for Hinkley Point C (HPC).

3.4.2 Draft minutes of stakeholder workshops and focus groups were sent to attendees to ensure that their comments had been accurately captured and recorded (these can be found in Appendix F). The exception is the Cannington bypass workshop, as not all attendees provided their contact details and, as such, the minutes could not be verified. A summary of the comments raised and the issues discussed at the workshops is provided below.

3.4.3 EDF Energy has taken into consideration the issues raised during these discussions in developing its proposals for HPC.

b) Results of Stakeholder Workshops

3.4.4 At the stakeholder workshops, undertaken as part of the formal consultation on EDF Energy’s ‘Preferred Proposals’ for Hinkley Point C, local councillors and representatives from key local stakeholder groups debated the key issues likely to impact on and benefit the local community.

ii. Vale of Glamorgan Workshop

3.4.5 As only four people attended the stakeholder workshop for the Vale of Glamorgan (9 September 2010), attendees had a round table discussion about the potential impacts and benefits they felt a new nuclear power station at Hinkley Point C could have on people living in the area.

3.4.6 The main issues raised were:

• visual impact of the proposed new power station and what would be visible from the other side of the Severn;

• the technology being used and the duration of decommissioning;

• nuclear safety; and

• storage and disposal of waste.

3.4.7 They expressed an interest in the proposals and the technology, but concluded that the building of Hinkley Point C was unlikely to have a significant impact on people living and working in the Vale of Glamorgan.




iii. Minehead Workshop

3.4.8 The stakeholder workshop held, in Minehead on 13 September 2010, was attended by 13 people representing a wide variety of interests from the local community including business, education, amenity and tourism.

3.4.9 Following a presentation on the proposals, attendees were divided into two groups to discuss the likely impacts and benefits of a new nuclear power station at Hinkley Point C.

3.4.10 The key issues raised were in relation to:

• Transport – the potential for electric transport and the need to have effective transport solutions, including a regular bus service, use of rail transport and the possibility of a ferry service link to south Wales. They also felt that the park and ride at Williton was in the wrong location and wanted traffic planning on the A39 (especially in relation to Butlins/peak holiday season traffic) as well as cycle paths in Minehead.

• Tourism – concern about potential impacts, particularly on Butlins but also recognised the possibilities of legacy benefits for tourism if managed effectively.

• Community Fund – the request that it should be larger than £1million, given the scale of the project.

• Employment – need to give jobs to local workers, but that needs to be balanced with recruitment needs of other local employers.

• Contractor behaviour – concern was expressed about anti-social behaviour among workers.

• Affordable housing – was suggested as a potential legacy benefit.

3.4.11 In general discussion, attendees also acknowledged the need for secure, low-carbon energy, but expressed concern about safety and removal/storage of waste.

iv. Taunton Workshop

3.4.12 The Taunton workshop, held on 14 September 2010, was attended by 16 people representing a range of local interests, including the emergency services, business and local authorities (in West Somerset, Sedgemoor, Somerset, Taunton Deane, South Gloucestershire, South Somerset and Devon).


• Transport – the need to manage and enforce park and ride and have shift patterns to avoid school start and finish times. Infrastructure improvements should be more widely spread (e.g. A358), more information needed on the routing and sourcing of people and materials, innovative ideas needed to link to




accommodation (e.g. rapid transit system) and concern at overloading existing roads and junctions (including motorways).

• Accommodation – impact on tourist accommodation, support legacy of (affordable) housing and concern about related issues such as the night-time economy.

• Skills and training – need to create opportunities for local people by starting training early, opportunities for local schools/universities - need to ‘up-skill’ workers, potential issue for existing employers (boom or bust).

• Community Fund – should be larger than £1million.

• Flooding – concern that there is floodplain in the area and the need for the temporary jetty to be able to withstand storm damage.

• Visual impact – final design and landscaping of the reactor buildings.

• Anti-social behaviour – concern was expressed about night-time economy issues, crime and disturbance, as well as recreation and cultural issues.

• Review and monitoring – the need for ongoing review of all aspects of the Project to ensure the most effective solutions to issues.

3.4.14 In general discussion, attendees also raised economic and employment benefits as well as concerns about safety and storage/disposal of waste.

v. Weston-super-Mare Workshop

3.4.15 Ten representatives of the local community, including the emergency services, education, parish councils and North Somerset Council, attended the Weston-super-Mare workshop on 15 September 2010.


• Benefits – the group discussed the positive elements of EDF Energy’s proposals, which included secure, sustainable energy supply and employment opportunities, as well as the potential to improve access to the area.

• Potential impacts – the group was concerned about storage and long-term disposal of spent fuel, disruption to the area during construction, that new workers would put pressure on public services and concern about increased pregnancy rates and anti-social issues.

• Business and training – responsibility of managing contractors/sub-contractors and links with schools/education providers.

• Policing – concern was expressed about capacity, potential to deal with protesters and an increased workforce. Need to have a code of conduct, not just on-site but in the wider community.




• Community Fund – the group felt that EDF Energy should take greater responsibility for local impacts beyond mitigation and Section 106 as local services are also likely to struggle.

• Transport – need for flexible shifts, no car journeys to work, question on adequacy of park and ride facilities, which would need to be enforced and use of West Somerset Railway link to Williton to park and ride and Hinkley Point C.

• Accommodation – variety of housing types required, property prices could be affected, concern at creating ghetto, need to ensure accommodation is suitable for the post-construction period and potential legacy for more affordable, quality housing.

• Tourism – sea wall path, visitor centre, school visits, impact on availability of tourist accommodation, need to positively affect tourism.

3.4.17 The group also questioned whether local services could cope with the demands of the Hinkley Point C workforce, particularly in relation to health/medical facilities and felt EDF Energy should be putting more money into the proposed Community Fund.

vi. Bridgwater Workshop

3.4.18 The Bridgwater workshop, held on 16 September 2010, was attended by 14 people representing a wide variety of interests from the local community, including the emergency services, health, tourism and ecology, as well as town/parish councils and local authorities.


• Transport – in particular the inadequacy of the existing highways infrastructure, the need for a Bridgwater bypass and improvements to the C182. Rail should be considered. Need to look at alternative travel plans if A39 closed.

• Accommodation – campuses need to be good quality, concern about impact on Bridgwater (night-time economy, policing and community), possible impact on tourist accommodation available, need for religious provision and interpretation. Potential for permanent housing on the Innovia site.

• Impact on services - concerns about the capacity of local health provision.

• Concern about the stages of consultation, the information available and a desire for a third stage of consultation.

• Community Fund – the amount, who would benefit and how it would be operated.

• Social cohesion – concern about how to integrate workers successfully into local communities.

• Access to the shoreline – important to divert the coastal path to ensure local access to the coast.




• Tourism – need to address potential impact.

3.4.20 The importance of skills development and jobs was a key benefit discussed by the groups and the need for long-term economic growth in the area. The groups also raised the need for transparency of communication from EDF Energy, the need to deliver proposals that respond to local policy and local needs, the importance of running a safe/secure site and dealing with nuclear waste.

vii. Cannington Bypass Workshop

3.4.21 In order to give local people an opportunity to discuss the proposals for the Cannington bypass in more detail, EDF Energy organised a topic-specific workshop that took place on 27 September 2010. This workshop was attended by 48 representatives from the local community, including Cannington Parish Council, Save Cannington Action Group, Brymore School (including three students) and residents from Withiel Drive, Chads Hill, Cannington High Street and Putnell Cottages.

3.4.22 The key issues raised were as follows:

• The principle of the western bypass.

• Noise mitigation required to reduce impact on the village.

• Crossing points for cattle, horses, schoolchildren and pedestrians were concerns and should be considered further – particularly in relation to people and cattle using a tunnel (issues of hygiene and anti-social behaviour were raised).

• Landscaping should be provided on both sides of the bypass and trees lost replaced like for like. Retention and linking up of existing screening is important.

• Isolation of Brymore School from the village was a problem and concern for students crossing the bypass.

• Withiel Drive – residents were concerned about proposed access/egress onto the bypass as well as noise, lighting and pollution.

• Road maintenance going forward was a concern.

• Increased traffic impact and need for detailed figures on use of the bypass.

• Putting the whole length of the road into a cutting would reduce the visual impact.

• Speed limit – enforcement and extension of 40mph speed limit.

• The toucan crossing should be specified as a school crossing with a 20mph speed limit – this was a safety issue for schoolchildren.

3.4.23 There was also some debate as to whether the Cannington bypass should be temporary and if the proposed route provided the best solution. It was also




suggested that a dedicated haul route from Dunball to Hinkley Point C would eradicate the need for a Cannington bypass.

c) Focus Groups

3.4.24 The focus groups were undertaken to communicate with and understand better the key issues and benefits of EDF Energy’s proposals for Hinkley Point C on specific groups within the local community that might not otherwise engage in the consultation process. As such, EDF Energy held focus groups with black, minority and ethnic (BME) groups, working parents, accommodation providers and job seekers. Attendees at some of the focus groups were paid a nominal amount to cover out-of-pocket expenses.

ii. BME Groups

3.4.25 This focus group was held on 20 September 2010 and was attended by representatives of 15 black, minority and ethnic (BME) groups in Somerset, who were recruited to attend by Somerset Racial Equality Council. The key issues raised during discussion at the focus group were:

• Importance of employment for local people. Need to explain what skills/qualifications would be needed and what job opportunities there would be.

• Funding to help train local people is needed. Training is essential and needs to start straightaway. Outreach programme so people can learn whilst working.

• Need to operate a policy of equal opportunities for BME community in training – special language training (technical, engineering etc).

• Take account of and assess overseas qualifications – give support to ‘add on’ rather than having to start from scratch.

• Language barriers and cultural issues need to be addressed – e.g. support filling out forms (translation and explanation).

• Impact on services – in particular healthcare, police and schools.

• Nuclear safety and waste disposal.

• Roads and parking were a key concern and suggestions included a Dunball bypass and widening the A39.

3.4.26 Also of concern to the BME representatives was that more immigration would lead to more discrimination against BME communities in Somerset. It was suggested that induction training/guidance be given to migrant workers, in particular continuous community support, welfare and counselling services.

3.4.27 At the stakeholder workshops, undertaken as part of the formal consultation on EDF Energy’s ‘Preferred Proposals’ for Hinkley Point C, local councillors and




representatives from key local stakeholder groups debated the key issues likely to impact and benefit the local community.

iii. Working Parents

3.4.28 This focus group was held on 21 September 2010. It was organised by a market research company and was attended by 14 working parents from the local area, including Combwich, Cannington, Nether Stowey, Stogursey and Bridgwater. The key issues raised during discussion were:

• Concern about the impact of EDF Energy’s proposals on village life and children growing up in those villages, especially during periods of 24-hour working. The group was concerned about the impact during the construction period but viewed the Community Fund in a negative light, with villages pitted against each other and it was perceived as a form of bribery.

• Concern that the road network already struggles to cope and EDF Energy’s proposals would put more pressure on it. Safety improvements need to be made to roads, especially close to schools, and a Bridgwater bypass would resolve this. It was agreed that as much be brought in by sea as possible and it was suggested that the temporary jetty be upgraded to a wharf. It was also suggested to make use of railways and that an airstrip be put onto the main site to bring materials in by air.

• Concern about the impact of workers, especially if predominantly single men. Also impact on services, in particular health provision and schools.

• Important that jobs go to local people and that these include skilled jobs – both in construction and in the supply chain. Training for local children was also considered important and boosting the local authority was seen as a priority. It was important to balance the opportunity for jobs against the disruption caused during construction.

3.4.29 The group was less concerned about the operational phase of the power station, with their main concern being the disruption caused during the construction period.

iv. Accommodation Providers

3.4.30 This focus group was held on 23 September 2010. It was recruited by writing to accommodation providers (from large hotel chains to holiday home owners and owners of guesthouses). It was attended by 18 accommodation providers in Somerset and the key issues raised during discussion at the focus group were:

• Accommodation providers were generally keen to maximise the opportunities provided by EDF Energy’s proposals whilst avoiding displacing tourists. Some hotels outlined other facilities they could provide, such as meeting and conference facilities.

• Some potential issues were also identified and discussed. These included shift patterns and when meals would be required, the need for quiet rooms for those on




night shifts who need to sleep during the day and how advance planning might help resolve some of these issues.

• Concern was also expressed about the possibility of unruly behaviour and whether additional security would be required.

• It was suggested that the influx of workers to the area could help boost local tourism, as workers may feel inspired to bring their families to visit. It was noted that the visitor centre could also attract more tourists to the area.

3.4.31 The majority of accommodation providers were confident that EDF Energy’s proposals would bring opportunities that could be managed in order to prevent a negative impact on the local tourism industry.

v. Jobseekers

3.4.32 This focus group was held on 28 September 2010. It was recruited through leaflets in the Jobcentre Plus branches in Somerset. It was attended by four jobseekers and the key issues raised during discussion at the focus group were:

• The need for jobs for local people was stressed and the group felt it was important to assess skill requirements and start training early – look to the future and involve schools and apprenticeships. The need to help people upgrade was felt to be important and to explain opportunities to women.

• It was felt that park and rides were good and the buses should be used to pick people up en route as well in order to help local people with transport issues. Motivating young people and making it easy for them to get to work was felt to be important.

• Concern was expressed that an influx of new workers might push up house prices and make it more difficult for local people to get on the property ladder.

• A range of suggestions were made about the best way to communicate job opportunities and these included Jobcentre Plus, events, information points, website, bus stop advertising and billboards.

3.4.33 Training and communicating in a clear and accessible way was felt to be extremely important so that local people could make the most of the opportunities presented by EDF Energy’s proposals.

vi. Tourism Survey

3.4.34 In order to gain a better understanding of the likely views of tourists visiting the Minehead area in relation to its proposals at Hinkley Point C, EDF Energy commissioned a survey of people holidaying in the area over two days in September 2010.

3.4.35 Interviews were carried out with 21 tourists in Minehead on 21 September 2010 and with 32 tourists at Dunster Castle on 22 September 2010.




3.4.36 Of those interviewed, 21 (40%) were aware there were existing nuclear power stations approximately 20 miles down the coast in Somerset (Hinkley A and B), and 32 (60%) were not aware of them. Only 8 (15%) of those interviewed were aware of EDF Energy’s proposals for Hinkley Point C.

3.4.37 Only 5 people surveyed (9%) thought that the existence of nuclear power stations in the region would affect their choice of holiday destination. Reasons included concern about emissions and potential impact on asthma.

3.4.38 Only 3 people (6%) were aware of plans for a visitor centre but, when provided with more information, 22 (42%) said they would be interested in visiting such a facility.

3.4.39 When asked to rate the existing road system in the area, 36 (68%) said it was very good or good. In contrast, 6 (11%) said it was poor or very poor.

3.4.40 When asked if an additional 2-5% of vehicles (cars, lorries and buses) on the A39 between Bridgwater and Minehead would make you less inclined to holiday in the area, 38 (72%) said ‘not at all’, 7 (13%) said ‘maybe’ and 8 (15%) said definitely.

3.4.41 The majority of people interviewed 21 (40%) were staying at Butlins in Minehead. The rest were staying in a range of holiday accommodation including holiday cottages, bed and breakfasts, hotel/guest houses and mobile home/static caravans. A few were staying with friends or were day visitors.



CHAPTER 4: INFORMAL SUPPLEMENTARY ENGAGEMENT


Consultation Report Chapter 4 - Informal Supplementary Engagement | October 2011 1


CONTENTS 4. INFORMAL SUPPLEMENTARY ENGAGEMENT...........................................................3

4.1 Introduction......................................................................................................................3

4.2 Overarching Consultation with the Joint Local Authorities...............................................6

4.3 Local Authority Work Streams .........................................................................................9

4.4 Engagement with Regulators.........................................................................................27

4.5 Statutory Consultees .....................................................................................................29

4.6 Emergency Services and Local Authorities Group ........................................................60

4.7 Health Impact Assessment and Associated Engagement .............................................64

4.8 Habitats Regulations Assessment .................................................................................67

4.9 Engagement with Landowners ......................................................................................74

4.10 Non-statutory Consultees/Stakeholders ........................................................................80

4.11 Engagement with the Local Community, Parish Councils and Other Local Representatives.............................................................................................................91

4.12 Business and Supply Chain Stakeholders...................................................................103

4.13 Telephone Surveys......................................................................................................106

TABLES Table 4.1: Summary of Environment Agency comments on flood risk for AD sites ...................34

Table 4.2: Summary of Environment Agency comments on surface water for AD sites ............36

Table 4.3: Summary of Environment Agency comments on land contamination and groundwater for AD sites............................................................................................................39

Table 4.4: Summary of Environment Agency comments on ecology for AD sites .....................41


2 Consultation Report Chapter 4 - Informal Supplementary Engagement | October 2011






4. INFORMAL SUPPLEMENTARY ENGAGEMENT

4.1 Introduction

4.1.1 In addition to the formal stages of pre-application consultation, EDF Energy held extensive, informal discussions with key statutory consultees and a wide range of other stakeholders. A full list of all the organisations consulted under section 42 of the Planning Act 2008 (the Act) during this period can be found in Appendix G. This chapter concentrates on the statutory consultees and other interested stakeholders with whom EDF Energy held on-going and detailed informal engagement, supplementary to the formal stages of consultation.

a) Definition of Informal Consultation

4.1.2 Informal consultation is defined as any engagement undertaken with consultees and stakeholders, on issues relating to the DCO application proposals, that took place outside of the formal Stage 1, 2, 2 Update and Junction 24 and Highway Improvements consultation periods and/or was not undertaken as a requirement of the Act.

4.1.3 Many groups and individuals are not statutory consultees as defined by the Act, but still have an interest in the plans for Hinkley Point C and its associated development. Much informal engagement involved Project updates to such groups at relevant points in the process, rather than in-depth discussions, and as such are not described in this chapter. The information provided below does, however, detail the informal engagement undertaken with those consultees who have been involved in more extensive discussions with EDF Energy.

4.1.4 Many of the views raised through the informal engagement reflect those submitted as part of the consultees’ formal responses. As such, where stakeholder engagement resulted in changes to the proposals, it was often as a result of a combination of formal and informal engagement.

b) Scope of Informal Consultation

4.1.5 EDF Energy has endeavoured to engage informally with as many consultees as possible during the pre-application stage for HPC.

4.1.6 Informal engagement with stakeholders on proposals for HPC started in 2008, prior to EDF Energy’s acquisition of British Energy, and focussed on the scope of the Environmental Impact Assessment and the Government’s Strategic Siting Assessment. This engagement has helped shape and develop the Project proposals and is likely to continue with a number of consultees throughout the construction phase of HPC and beyond, into the operational period, should consent be granted.

4.1.7 A list of key issues identified during this early stage of engagement, together with EDF Energy’s response, can be found in the Stage 1 ‘Consultation on Initial Proposals and Options’ document (see Appendix B).




4.1.8 Following on from the early consultation exercises EDF Energy’s informal consultation programme has developed and expanded with an aim to engage as many stakeholders as possible on its proposals.

4.1.9 Engagement with the Somerset local authorities continued outside of the formal consultation stages, with meetings usually taking place via the subject-specific work streams (described further in this chapter). EDF Energy’s engagement with the local authorities has been extensive over the pre-application consultation period and whilst it would not be feasible to include every point raised, every effort has been made to accurately capture the key issues.

4.1.10 Informal engagement with local elected representatives has also been an integral part of the consultation. EDF Energy has undertaken extensive and regular engagement with a large number of local parish councils about the HPC proposals. This includes attendance at parish council meetings, detailed briefing sessions and one-to-one meetings with parish council members. EDF Energy has also regularly updated elected representatives, such as the Member of Parliament for Bridgwater, and district and county councillors.

4.1.11 A large part of the informal engagement took place with the local community, with many people contacting EDF Energy raising a range of different issues and queries. EDF Energy used a variety of communication channels, including a dedicated email address, freepost address, freephone number and the EDF Energy Bridgwater office to deal with all such contacts quickly and effectively. EDF Energy staff at the Bridgwater office also provided home visits when and wherever possible.

4.1.12 In addition to responding to incoming enquiries, EDF Energy also sought to provide stakeholders with as much information as possible, which often related to works planned at the various development sites. Initially EDF Energy informed residents of planned works via the newsletter and letters sent to the homes of those in the immediate vicinity. However, EDF Energy subsequently organised ‘drop-in’ sessions, providing local residents with the opportunity to discuss the works with an EDF Energy staff member or specialist consultant.

4.1.13 This strategy continued throughout the pre-application consultation phase, with a permanent drop-in session for residents of Stogursey taking place from August 2011 to allow those likely to be most affected by the proposals the opportunity to engage with EDF Energy on a regular basis. This engagement is likely to continue into the construction phase and beyond, should development consent be granted.

4.1.14 A number of forums have also been established to discuss the proposals for HPC and related topics. These are not executive bodies that make decisions; rather they are a mechanism by which EDF Energy can accurately capture the concerns and views of local people on matters relating to HPC. They are also a useful method of feeding back information to the local community in a consistent manner. Each forum is independently chaired by a third party who is not directly affected by the Project and is not an employee of EDF Energy.

4.1.15 The issues raised at each forum are varied and often reflect the comments received in response to the formal consultation stages. This chapter therefore discusses the mechanics of the engagement more than the issues raised and EDF Energy’s




responses. Issues raised through the forums were, however, taken into account in the development of the proposals for HPC.

4.1.16 Details of informal engagement with the local community and its representatives are included in the section titled ‘Engagement with the Local Community, Parish Councils and other Local Representatives’.

4.1.17 As part of the ongoing engagement to shape and prepare the development proposals for HPC, EDF Energy has also carried out informal engagement with its statutory stakeholders, as prescribed under the Planning Act 2008. These discussions were held to progress the proposals for HPC and to take advice from the relevant statutory bodies where necessary. A number of statutory stakeholders have provided significant input in progressing the HPC development proposals and are described in the section entitled ‘Statutory Consultees’. All stakeholders are listed alphabetically for ease of reference.

4.1.18 EDF Energy has regular meetings with the ONR (CNS) (Office for Nuclear Regulation Civil Nuclear Security), the Environment Agency (in its capacity as a regulator) and the Civil Nuclear Constabulary at all of its sites. Given the confidential nature of meetings with these bodies, the detail of this engagement is not reported in this chapter. However, a high level overview of the nature of EDF Energy’s engagement is provided; please see ‘Engagement with Regulators´ for further information.

4.1.19 Other statutory consultees include those with an interest in land generally, classified as Landowners. EDF Energy has undertaken extensive engagement with Landowners across all stages of consultation and has endeavoured to take account of issues raised wherever possible. Much of the informal engagement with Landowners relates to commercial issues, which are not discussed in this chapter. The main points raised in relation to the HPC proposals, however, can be found in the ‘Informal Engagement with Landowners’ section below.

4.1.20 Working with local schools and education providers to ensure that skills, training and the legacy benefits of the HPC Project are maximised has also been central to EDF Energy’s consultation. Engagement with Bridgwater College and the commitment to create a Construction Skills Centre in partnership with the College is one example of the results of this engagement.

4.1.21 The work and discussions with education providers has been supplemented by the extensive engagement EDF Energy has had with local businesses, job providers and regional and local trade bodies. The focus of this engagement has been to ensure that local companies understand the opportunities that HPC would provide and the potential routes into the Project supply chain. Further information on EDF Energy’s informal engagement on education and supply chain issues can be found throughout this chapter.

4.1.22 In addition to consulting directly with stakeholders on the proposals for Hinkley Point C, EDF Energy also commissioned polling and surveys during the course of its consultation in order to gauge public opinion. The methodology and results of the surveys are documented in this chapter under ‘Polling and Surveys’, with the full results included in Appendix E.




4.2 Overarching Consultation with the Joint Local Authorities

4.2.1 As key stakeholders in the pre-application process for Hinkley Point C, a close working relationship has been established with the two district councils nearest to Hinkley Point – West Somerset Council and Sedgemoor District Council - and also Somerset County Council, in its role as County Planning Authority and Highway Authority. All three councils have a long-term relationship with nuclear power at Hinkley Point and all have detailed, in-depth knowledge of the site and the associated development sites.

4.2.2 The local planning authority for Hinkley Point, West Somerset Council (WSC) has, to date, dealt with planning issues for the HPC Development Site (including the site preparation planning application), as well as the associated development proposals at Williton. As a result, the Council has played an important role in commenting on the proposals for the HPC Development Site and will be a key consultee for the IPC during the examination phase of the DCO process.

4.2.3 The administrative area of Sedgemoor District Council (SDC) borders West Somerset and much of the off-site associated development is located within the district. So EDF Energy has sought to consult SDC and WSC concurrently.

4.2.4 Somerset County Council (SCC) played an important role within the consultation process as the authority responsible for transport, minerals and waste. SCC also has interests in education, archaeology, rights of way, ecology and healthcare, and input from the Council has helped to develop the HPC proposals and strategies.

4.2.5 In 2007, in advance of the formal consultation process and prior to EDF Energy’s involvement in the Project, British Energy started engagement with members and officers from the three authorities on the plans for the proposed HPC power station. The need for a forum to discuss emerging strategic proposals, design and engineering issues was recognised at an early stage in the process and a regular session was identified, culminating in a monthly meeting known as the Strategic Officer Group (SOG). On acquiring British Energy in 2009, EDF Energy continued with the SOG meetings, which were used as a high level steering group, sharing information and issues between EDF Energy and officers at the three authorities.

4.2.6 The SOG meetings were held jointly with other stakeholders, including the Environment Agency, Natural England, English Heritage and other statutory consultees. This allowed EDF Energy to address key issues at a single meeting and facilitated the sharing of views, which in turn helped guide and shape the proposals. Issues such as proposed shift patterns, home-based to non-home-based worker splits and transport proposals were among those matters considered at the SOG and a steer was given to the relevant task groups to assist in concluding the final proposals. There were clear advantages in meeting and sharing information with all three local authorities on an equal basis, as this involved the pooling of resources and knowledge, which guided the Project at a strategic level.

4.2.7 Consensus was not always possible at these meetings. To resolve differences of opinion two specific mechanisms were put in place:

A clear reporting structure was implemented to ensure areas for resolution were escalated to senior members of the Project team.




Works packages and work streams were put in place, to ensure technical specialists were available and met regularly to review technical issues.

4.2.8 During preliminary consultations, it was recognised that the scale and complexity of the proposed Project would need continuous engagement and consultation. In order to enable effective engagement with the authorities, and to ensure they had the capacity and funding to fully partake in the consultation process, EDF Energy voluntarily entered into a Planning Performance Agreement (PPA) as defined below.

“A Planning Performance Agreement, or ‘PPA’, is a framework agreed between a local planning authority and a planning applicant for the management of complex development proposals within the planning process. A PPA allows both the developer and the local planning authority to agree a project plan and programme which will include the appropriate resources necessary to determine the planning application to a firm timetable.”

(Implementing Planning Performance Agreements – CLG and Atlas 2007)

4.2.9 On 9 October 2009, a PPA was signed between EDF Energy and WSC, SDC and SCC, which set out the vision of what the Project should achieve.

4.2.10 A management structure for the PPA, and therefore the engagement process, was agreed with the three local authorities, which included a strategic project board and a core project team.

4.2.11 The Strategic Project Board (SPB) was set up, meeting on a monthly basis from October 2009. The SPB manages the PPA and is the ultimate project decision-making forum with responsibility for setting the overall strategic direction for joint working. As part of its role, the SPB addresses:

key risks;

project resources and timing, including major consultation events;

issues highlighted and resolution of tasks; and

agreement of work packages to guide and fund the authorities and their consultants.

4.2.12 The SPB is chaired by each of the local authorities, rotating on a three-month basis. The board members consist of two representatives from each of the three local authorities and EDF Energy, with each party having a number of observers who act as advisers to its members.

4.2.13 The SPB forms an important strategic role for the Project, allowing a close working relationship with and between the authorities and EDF Energy.

4.2.14 Running in parallel to the SPB has been a series of informal directors’ meetings. These sessions allow the directors of the three local authorities and EDF Energy’s director of Planning and External Affairs to talk informally about progress within the Project and review issues of concern.




4.2.15 To assist in the management and programming of the pre-application consultation process, a Joint Core Project Team (JCPT) was also set up in October 2009 and has met fortnightly since. The JCPT reports to the SPB on issues such as the content and scope of work packages (which can change on a bi-annual basis) and has, more recently, collated fortnightly reports from the work streams set up to focus on key working areas.

4.2.16 Work packages are designed to identify specific areas or additional work/input required by the authorities in response to reports or work carried out by EDF Energy and to identify the resourcing and funding needs of the local authorities to allow them to adequately assess EDF Energy’s proposals. The JCPT signed off the requests and ensured that funding was in place to assist this collaborative working.

4.2.17 Following the completion of Stage 2 consultation, the need for a meeting to cover planning strategies and detailed aspects of several key planning documents was identified. Planning meetings covered discussions across a wide range of strategic planning and land use issues, including the Development Consent Order and supporting documentation, the Local Impact Report and Statement of Common Ground.

4.2.18 The focus of the planning meetings was to allow a better understanding of how the application material would be presented and the key elements to be considered in the documents. The frequency depended on other key meetings and the progress of the DCO and Site Preparation Works application documentation.

4.2.19 These meetings are likely to continue beyond the submission of the DCO application as negotiations progress on the Statement of Common Ground and other matters relevant to the IPC’s consideration of the DCO application.

4.2.20 As the relationship with the authorities has progressed through various Project phases, the requirement for more detailed technical working relations emerged. The SOG was therefore replaced by the Joint Project Update (JPU) in summer 2010. The JPU focused solely on the relations with the local authorities; narrowing down the number of invitees and the scope of the meeting, focussing instead on reviewing and reporting on the local authorities’ work streams set up by the Strategic Project Board. The key work streams covered accommodation, socio-economics, transport and environment and are described in more detail in this chapter.

4.2.21 Through these main work streams, the JPU continued to report on other programming and technical issues, including construction, procurement and design issues, as well as environmental, archaeological and marine topics.

4.2.22 Although strategic views and key issues were dealt with jointly with the local authorities through the SPB, JCPT and JPU, more technical work and detailed engagement was undertaken at a second layer of meetings based on the work streams. Details of these meetings and the key issues raised are set out in the work stream summaries in the following section.




4.3 Local Authority Work Streams

4.3.1 A number of topic-specific work streams were established to assist EDF Energy, the local authorities and relevant stakeholders to discuss the detailed strategies linked to the HPC Project. A high-level summary of the work streams and the key issues raised plus, where possible, EDF Energy’s response to them is detailed below.

a) Accommodation

4.3.2 EDF Energy’s engagement with West Somerset Council (WSC) and Sedgemoor District Council (SDC) on accommodation for the construction workforce started in mid 2009, prior to Stage 1 consultation. Meetings took place on an ad-hoc basis up to the publication of the Stage 2 consultation in July 2010. Following these discussions with the councils, in autumn 2010 a more formal Accommodation Task Group (ATG) was established, which had regular meetings on a monthly basis up to May 2011, in advance of EDF Energy finalising the DCO application.

4.3.3 The membership of the ATG included planning and housing officers from WSC and SDC. Elected members and key local stakeholders (e.g. Homes in Sedgemoor) were invited to attend some meetings.

4.3.4 During this period, the local authorities and EDF Energy discussed all aspects of its accommodation proposals, including the approach to accommodating the workforce, proposals for accommodation campuses (location, size, facilities), use of existing accommodation in the local area, the anticipated impacts of the proposals and plans for managing and mitigating those impacts, including a proposed Housing Fund.

4.3.5 While the local authorities agreed with the principle that EDF Energy should make use of existing accommodation in the local area and supplement this with some campus accommodation, the scale of the campus proposals was of concern to them. EDF Energy therefore scaled back the capacity of the campuses over time, both in reaction to feedback from the councils and public consultation, as well as the further objective analysis presented in the Accommodation Strategy, which is included within the DCO application. The local authorities also had a preference for EDF Energy to build more permanent housing. In response EDF Energy evaluated potential housing sites suggested by the councils and included the proposed Housing Fund.

4.3.6 A summary of the issues raised during this informal engagement and how they were addressed by EDF Energy follows below.

i. Use of Existing Accommodation

4.3.7 The local authorities agreed that using some local tourist and private rented accommodation could have positive economic benefits for the local area, but they expressed some concern about the possibility of HPC workers displacing tourists or local residents if EDF Energy relied too heavily on these resources.

4.3.8 In response to these concerns, EDF Energy did further work to refine its understanding of the availability of existing local accommodation following Stage 2 consultation. The results of this work were presented in a Draft Accommodation Strategy that was published alongside the Stage 2 Update consultation. From the results of its detailed investigation into the local housing market, EDF Energy




considers that the anticipated scale of use of existing accommodation will not have a harmful impact on the availability of accommodation for tourists or local people. However, in the unlikely event that periods of strained capacity do occur, EDF Energy will use its Accommodation Office to signpost workers to alternative sources of accommodation. EDF Energy has also proposed the establishment of a Housing Fund which can be used by the local authorities to support the local housing market (see below for further information).

4.3.9 An Accommodation Management Strategy is presented alongside this application. EDF Energy believes it strikes the right balance between supporting workers in finding accommodation, and local providers in making accommodation available, without being overly prescriptive or bureaucratic.

ii. Use of Temporary Campuses

4.3.10 The local authorities accepted that some campus accommodation was necessary, and in particular that EDF Energy needed an on-site accommodation campus. They agreed that Bridgwater was the best location for additional campus accommodation. However, they argued that the on-site and Bridgwater A campuses should be smaller and that EDF Energy should build permanent housing instead.

4.3.11 In response to this feedback, EDF Energy reduced the campuses to the minimum size necessary to ensure that undue pressure was not put on existing local accommodation and to maintain the operational efficiency of the campuses.

4.3.12 At Stage 1 consultation EDF Energy proposed campus accommodation on-site (700 bed spaces) and in Cannington (up to 320 bed spaces, including some at Cannington College), Williton (up to 200 bed spaces) and Bridgwater (up to 500 bed spaces). In response to consultation, EDF Energy announced in Stage 2 that it would focus requirements for campuses on-site (700 bed spaces) and in Bridgwater as the nearest major urban centre (up to 1,075 bed spaces on Bridgwater A and 150 bed spaces on Bridgwater C).

4.3.13 In the Stage 2 Update consultation, following the review of existing local accommodation mentioned above and in response to comments received during public consultation as well as the views expressed by the councils, EDF Energy reduced the overall requirement for campus accommodation to 1,510 bed spaces, split between 510 bed spaces in the on-site campus, 850 bed spaces on Bridgwater A and 150 bed spaces on Bridgwater C.

4.3.14 The local authorities suggested a number of sites where EDF Energy could build permanent housing. EDF Energy’s evaluation of these sites indicated that they would not meet its accommodation needs. In particular, EDF Energy considered it was better from an operational and transport perspective to have accommodation concentrated in a small number of locations rather than dispersed over a number of sites, and that temporary campus accommodation is better suited to the needs of construction workers than permanent housing.




iii. Impacts of Accommodation Proposals

4.3.15 EDF Energy presented information on the anticipated impacts of its accommodation proposals but these were not agreed with the local authorities. EDF Energy further refined its assessment of the impacts and remains of the view that the combination of its proposed campuses, Accommodation Management Strategy and Housing Fund should ensure that its proposals have no unacceptable impact on local housing markets. The local authorities have questioned this but EDF Energy believes it has based its conclusions on the best current data and evidence available.

iv. Housing Fund

4.3.16 The local authorities agreed with the principle of establishing a Housing Fund, and the sort of interventions it should be used to support, but they questioned whether the size of the Fund was sufficient.

4.3.17 Since the Stage 2 Update consultation, EDF Energy has done further work to assess the types of intervention that could be brought forward by the Housing Fund. Initiatives suggested include:

improvement grants to increase the supply of private rented sector accommodation;

the provision of rent deposits for households moving to the private rented sector;

grants to facilitate household moves from the social rented into intermediate or market accommodation;

equity investment to assist developers to ‘kick start’ stalled development opportunities; and

grant payments to subsidise the provision of affordable housing developed by Registered Social Landlords.

4.3.18 The local authorities have agreed that these interventions are appropriate. Please refer to the Accommodation Strategy for more information on the Accommodation Management Strategy and the Housing Fund.

v. Monitoring

4.3.19 The local authorities and EDF Energy agreed that a robust monitoring framework was required but disagreed on some areas of its scope. EDF Energy is proposing to monitor issues that could affect its assessment of impacts and therefore trigger a requirement for additional mitigation, such as the number of non-home-based workers, the types and locations of their accommodation, and the time of year (to take account of the seasonal availability of tourist accommodation). These are the factors where there is inevitably some uncertainty about outcomes and changes could affect the impacts of the development and, therefore, the need for mitigation.

4.3.20 The local authorities wanted EDF Energy to monitor a much wider range of local indicators – e.g. levels of homelessness and local rent levels. EDF Energy disagreed with this approach because these issues could be influenced by a much wider range of factors not in EDF Energy’s control and it would be impossible to assess the extent to which the HPC Project had contributed to any change.




b) Environment

4.3.21 Informal consultation was held with WSC and SDC on the Environmental Impact Assessment (EIA) through the environment work stream which was set up in February 2011. The aim of the work stream was to agree the requirements for baseline monitoring (methodology, locations and duration of monitoring), and also to enable progressive outcomes on the EIA studies, focussing specifically on:

issues raised during the Stage 2 consultation as set out in the WSC and SDC consultation response;

other areas of concern that had arisen since the Stage 2 consultation or through the environment work stream meetings;

the technical assessment outcomes which were not completed and presented during the Stage 2 consultation, but where assessment work was ongoing or had since been completed;

discuss alternatives considered, and mitigation measures proposed to prevent, reduce or off-set identified adverse impacts; and

monitoring measures and procedures focused on the potential key impacts identified during the EIA.

4.3.22 Whilst the formal environment work stream was only established in February 2011, there has been ongoing consultation with WSC and SDC since 2009 on the scope of the baseline studies and assessment methodology.

4.3.23 Information was provided to WSC and SDC via subject-specific technical reports, relevant extracts and/or full chapters of the Environmental Statement (ES), face-to-face meetings and exchange of correspondence. Where appropriate, and where there was a commonality of issues, other stakeholders, such as Natural England also attended meetings.

4.3.24 The environment work stream involved consultation on the overarching EIA approach and methodology and topic specific assessments as described below.

i. EIA Approach and Methodology

4.3.25 The EIA approach and methodology was discussed in light of comments received during the Stage 2 consultation. There was consensus that an approach in line with the EIA Regulations and relevant guidance had been applied to the assessment.

4.3.26 The absence of a ‘very high’ category, with regards to the value/sensitivity criteria was raised as a concern by WSC and SDC. The local authorities were of the view that this could result in the potential for an overall suppression of the determined significance of impact, thereby giving rise to an under prediction across the appraisal of harm, particularly in relation to the applied levels of value for the internationally important sites, such as Special Protected Areas (SPAs), and national sites such as Sites of Special Scientific Interest (SSSIs). The local authorities suggested that such sites should come under a ‘very high value’ but instead fall under either high or medium value.




4.3.27 EDF Energy undertook further technical appraisal of the assessment criteria and concluded that such differentiation is not required in order to undertake a robust impact assessment. This was supported by legal advice confirming that the proposed approach was robust and would not affect the validity of the assessment outcomes. The applied criteria are detailed in the Environmental Statement (ES) (ES Volume 1, Chapter 7). The conclusions were further discussed and it was advised that this criteria acts as a guidance tool for the assessment and expert judgement would also be exercised in determining the significance of the impact.

4.3.28 Further points discussed also included the applied baseline year for the assessment; key assessment years and operational life; the temporal scale for temporary impacts; and the inclusion of the Site Preparation Works and temporary jetty proposals within the DCO and in the ES accordingly.

4.3.29 EDF Energy also presented the proposed approach to the Cumulative Impact Assessment (CIA) to Arup (working on behalf of the local authorities) which was followed up with a discussion on the detailed methodology. It was recognised that the approach was in line with the EIA Regulations and relevant guidance. Particular points of discussion and consensus in approach included the following:

the use of ‘certainty’ as criterion to determine whether a potential scheme should be ‘scoped in’ to the CIA;

the consideration of a Supplementary Planning Document (SPD) and emerging Core Strategy, even if proposals within these are ‘scoped out’;

the degree to which the assessment can be undertaken based on information available in the public domain submitted with the planning applications. However, where information is not accessible through this route, EDF Energy would seek further information through consultation with the promoters of the other schemes;

the determination of Zones of Influence and the use of GIS mapping to scope for potential cumulative impacts;

the assessment of community impacts; and

the assessment of impacts on the ‘quality of life’.

4.3.30 With regards to the assessment of community impacts, it was not considered appropriate to assign significance criteria to the additive impacts on community receptors, but instead the CIA would clearly describe, as far as possible, the impacts that would be experienced. The impacts on ‘quality of life’ would be considered in the Health Impact Assessment.

ii. Environmental Impact Assessment Technical Assessment

4.3.31 Meetings were held with WSC and SDC to established consensus with respect to the requirements for baseline monitoring (methodology, locations and duration of monitoring) and enable the progressive outcomes of the assessments to be communicated and where applicable assessment criteria to be agreed. Key technical assessment areas discussed within the work stream included:

Noise and vibration; Air quality; Soils and land use;




Contaminated land; Surface water and flood risk; Groundwater; Terrestrial ecology and ornithology; Landscape and visual; Historic environment; Amenity and recreation; and

Waste.

4.3.32 The format of the meetings generally covered: a presentation of work undertaken and consulted on at Stage 2; further assessment work and emerging outcomes; and key issues raised through the formal Stage 2 consultation process.

4.3.33 An initial meeting on noise and air quality outlined the key assessment outcomes following Stage 2 consultation and defined the assessment criteria for discussion and agreement with WSC and SDC, particularly with respect to operational noise at the nearest sensitive receptors to the HPC Development Site. Specific agreement was reached on the approach to be used for the determination of effects of varying wind conditions on noise propagation in the context of predictive noise modelling.

4.3.34 Agreement was reached that vibration was unlikely to be a significant issue for receptors in the locality of the HPC Development Site.

4.3.35 In addition to face-to-face meetings, technical notes were also issued for comment, as necessary.

4.3.36 Similarly, the requirements for baseline monitoring for air quality was also agreed and progressive outcomes of the assessment discussed, particularly with respect to criteria for the assessment of dust arising from construction works. Consensus has been achieved with respect to the use of monitoring data collected by WSC and SDC as part of their ongoing air quality monitoring programmes and the use of published data from the national air quality archive.

4.3.37 In response to comments received, the scope of the assessment was extended to include predictive assessment of pollutant emissions from vessels which will use the temporary jetty at the HPC Development Site and the wharf at Combwich.

4.3.38 The approach to modelling of emissions from traffic was debated and consensus reached on the geographical scope of the model and the generation of outputs to be indicative of groups of receptors.

4.3.39 Similarly, meetings were held on groundwater and surface water, including flood risk. Within this meeting information was shared on the assessment methodologies and emerging outcomes. Discussions on the groundwater assessment focussed on the key areas of concern raised both through the formal consultation process and through detailed informal consultation with the Environment Agency (EA), particularly on the potential for contaminant transport from Hinkley Point A during the dewatering activities associated with the excavations for the two reactors.

4.3.40 Surface water and flood risk aspects were also considered. The modelling work undertaken in support of the Flood Risk Assessment (FRA) formed the basis of




discussion, as consulted upon with the EA as the statutory consultee and regulator on flood risk.

4.3.41 A joint EIA work stream meeting on landscape and visual impact, historic environment and amenity and recreation was held with representatives from WSC, SDC, Somerset County Council (SCC), Natural England and the Quantock Hills Area of Outstanding Natural Beauty (AONB) during which the EIA work undertaken to date was presented and discussed. There was general consensus on the archaeological and the amenity and recreation assessments which had previously been consulted on in detail with SCC. The landscape and visual assessment was, however, discussed in significant detail, in particular the impacts upon the Quantocks and the amenity value of the user. Further information on EDF Energy’s informal engagement with the AONB Partnership offices and Natural England is covered in this chapter.

4.3.42 Meetings were also held with SCC, WSC, SDC and Natural England on terrestrial ecology impacts which were mainly consulted on at Stage 2 for the HPC development. However, further details and issues, including potential mitigation measures, were covered for the associated development sites at work stream meetings.

4.3.43 A number of meetings have been held with (SCC), together with the EA and the Somerset Waste Partnership on the management of waste arisings from the HPC Project, including during the construction and operation of HPC and the associated developments. Key discussion points included:

the proposed development and waste arisings including engineering wastes; construction and demolition waste; and radioactive waste;

the existing capacity in the region;

an Options Appraisal for the management of waste arisings;

sustainable transportation, handling and management of waste; and

permitting.

4.3.44 Following this engagement, EDF Energy consulted upon the Waste Management Implementation Strategy as it has evolved reflecting all aspects of the HPC Project, including the jetty. This forms part of the DCO application and responds to comments received from the EA.

4.3.45 Due to the magnitude of transport and socio-economic effects in the are, and interest raised through the formal consultation events, two separate work streams addressing socio-economic and transport issues were established. The scope of these work streams are detailed in the sections below.

4.3.46 Due to the comprehensive coverage of issues through the socio-economic and transport work streams, only a brief overview of the impact assessment work was presented within the environment work stream.

4.3.47 Similarly, the environment work stream did not address impacts associated with the marine environment as those areas have been consulted upon through the Habitats




Regulations Assessment (HRA) forum, further details of which can be found in this chapter.

c) Socio-Economics

4.3.48 The Socio-Economic Task Group (SETG) was formed in November 2010 as a co-ordinating group for the socio-economic work stream between the district and county authorities, their technical advisors and EDF Energy. Key topics relating to socio-economic issues were discussed, such as evidence and assessment, community wellbeing, economic development, education, employment and skills and commercial property.

4.3.49 The SETG was attended by officers from EDF Energy, Sedgemoor District Council, Somerset County Council and West Somerset Council (jointly referred to as the Somerset local authorities). The South West Regional Development Agency (SWRDA) was also represented.

4.3.50 The SETG agreed the areas in which work would be co-ordinated and the following information provides an overview of the significant areas of discussion, highlighting the key issues raised and, where appropriate, EDF Energy’s response. Some of the work areas had dedicated working groups and more detail can be found in this chapter. Where work areas do not have a specific task group, a brief summary has been provided of the key points raised.

i. Socio-Economic Evidence and Assessment

4.3.51 The Socio-Economic Evidence and Assessment work area did not have a specific task group, but technical leads for both EDF Energy and the Somerset local authorities attended the SETG. The purpose of joint working in this area was the provision of the socio-economic evidence, identifying and filling gaps in evidence and reviewing methods for assessing the socio-economic impacts of the Hinkley Point C Project.

4.3.52 The initial socio-economic assessment was submitted to the SETG by EDF Energy in 2010 and provided information on the likely impacts of HPC based on information from other projects, such as Sizewell B and Flamanville 3.

4.3.53 EDF Energy built upon this original report, making it more specific to the Project by using labour forecast estimates from Tier 1 contractors, labour forecasting models and the workforce numbers from Flamanville 3. .

4.3.54 This was combined with previous assessments undertaken by Professor John Glasson, an expert in socio-economic impact assessment, to provide as robust a picture as possible of the workforce. The workforce forecasts were then used to inform projects within the socio-economic workstream and also across transport and accommodation work streams.

4.3.55 With regard to education capacity, representatives from EDF Energy and officers from SCC worked towards the production of an assessment of the likely workforce, the number of workers who would move to work at Hinkley Point (non-home-based workers), the likely numbers and ages of children and the places that they are likely to live. These documents are included as technical annexes to Chapter 9, Volume 2 of the Environmental Statement.




ii. Community Wellbeing

4.3.56 The Community wellbeing work area covered a number of topics, including health, community safety, emergency response and tourism.

4.3.57 Health and community safety had specific working groups in which discussions on the development and potential impacts and mitigations took place, before referring key issues to the SETG. Tourism and leisure did not have formal working groups, but the leads of both working areas attended the SETG meetings, where items of significance were discussed and agreed upon where appropriate.

4.3.58 The Community Safety and Emergency Response group considered the potential impacts arising from the accommodation of non-home-based workers. A Task and Finish Group was formed to progress the Community Safety Management Plan, the Accommodation Strategy and the Worker Code of Conduct. In May 2011, the strategies were presented to the SETG forum by EDF Energy. The documents were reviewed by the local authorities in June 2011.

4.3.59 The SETG commissioned a Health Task and Finish Group to address the impacts of the Project. The group was attended by representatives from EDF Energy, the local authorities, the Somerset Primary Care Trust and the Bridgwater GP Federation.

4.3.60 The group supported both the refinement of the Health Impact Assessment focus, the collection of appropriate health and health care data and provided key input into the development of a bespoke health action plan, intended to further address and support matters of public health within the region (i.e. health protection, health promotion and health care). Further information on EDF Energy’s informal engagement with the Emergency Services and the Health and Task Finish Group can be found in this chapter.

Tourism

4.3.61 As part of the socio-economic workstream, a workshop focussing on tourism took place in January 2011. This was a one-off event although the workshop was suggested and discussed regularly at the Socio-Economic Task Group in late 2010.

4.3.62 The purpose of the workshop was to provide an update on the Project and to listen to the views of local people, businesses and organisations in relation to tourism opportunities and impacts arising from the HPC development, during both construction and operational stages.

4.3.63 The workshop was jointly organised by SCC, SDC, WSC and EDF Energy. Invitations were issued to approximately 130 people, including hoteliers, publicans, West Somerset Railway and the Somerset Tourist Association. The invitees were identified by the local authorities and EDF Energy.

4.3.64 The session began with an introduction and overview followed by a question and answer session. Attendees were then divided into six separate discussion groups to allow them to express their personal views and opinions.




4.3.65 Group discussion followed and the Chairman invited presenters from each group to summarise their discussions from the previous stage. The main points raised are listed below:

There was a willingness to address issues such as the effect of a number of construction workers moving into the area. A balance needed to be reached between giving tourists adequate information about the Project and its potential impacts whilst trying not to dissuade them from visiting the area. There was a need to work collaboratively to emphasise the positive aspects of HPC and to promote Somerset’s key tourist attractions. Any negative perceptions of nuclear power and traffic congestion would need to be carefully managed. The importance of day visitors to Somerset was highlighted and it was noted that they could easily choose to visit other destinations such as Dorset or the Cotswolds if they were worried about traffic and other impacts from construction;

The public information centre (PIC) offers a huge opportunity to increase the appeal of Somerset as a tourist destination, as well as showcasing the nuclear industry and HPC in particular. There was a great deal of interest in working with EDF Energy to develop the PIC plans. EDF Energy has subsequently worked with SCC to assess and determine the scope and appeal of the PIC. Other stakeholder engagement has also taken place and more is planned.

Greater certainty about how accommodation brokerage will work in practice was requested. Local tourism associations and information centres could be used to accredit providers and act as the broker. The need to give careful consideration to the legacy of accommodation campuses and other infrastructure was identified. The need for a single EDF Energy point of contact to deal with any issues which accommodation providers have with residing workers was also suggested.

Concern was expressed about the detrimental effect that construction-related traffic congestion could have on local people and businesses and the perception and experiences of tourists. Adequate mitigation plans need to be put in place and the provision of traffic congestion updates was identified as important. It was noted that traffic congestion, on for example the A39, is currently a problem even before construction commences.

The provision of a passenger ferry (from south Wales) terminal was identified by a number of groups as an important issue to be considered further.

4.3.66 Attendees were assured by EDF Energy that detailed consideration would be given to the comments received and many of the issues were addressed during the formal Stage 2 Update consultation.

4.3.67 In February 2011, an overview of the workshop was presented to the SETG and EDF Energy undertook to inform the accommodation and transport workstreams of the issues raised. Since February 2011, EDF Energy has met with the Somerset Tourist Association and presented at the Exmoor Tourist Association AGM in March 2011.

4.3.68 Hoteliers and publicans have been engaged via the EDF Energy accommodation office which has been set up to identify suitable accommodation providers and manage and monitor the uptake of these providers by the HPC workforce.




4.3.69 EDF Energy is also actively exploring opportunities for the creation of a specific task group with representatives from local communities, businesses and organisations to help develop plans for the Public Information Centre (PIC).

4.3.70 As part of the Site Preparation Works to advance DCO mitigation, EDF Energy has offered to support a Tourism Strategy and Action Plan.

iii. Economic Development

4.3.71 The broader economic development impact of the Project was addressed by the Low Carbon Delivery Team (LCDT), which was formed in February 2011 as a direct response to a number of joint visions that were agreed between the Somerset local authorities and EDF Energy. The remit encompassed economic development; a low-carbon future; and education, employment and skills. It was understood that a group was needed to address the impact of HPC in the wider economy and ensure that potential benefits could be identified and maximised.

4.3.72 The LCDT included representatives from SWRDA, SCC, SDC, WSC and EDF Energy. Its primary role has been to establish a strategic framework to support the rebalancing of the Somerset economy and, at the same time, the transition to a low-carbon economy. Four themes were identified for development, including: a nuclear business cluster; low-carbon energy; natural environment and tourism; and built environment and infrastructure. The key theme (and the catalyst for other initiatives) is the development of a nuclear business cluster, which would encourage nuclear-related businesses and related agencies to develop and locate in Somerset. EDF Energy’s involvement was primarily to encourage and support the development of a local infrastructure to support the nuclear business cluster.

4.3.73 Meetings were held regularly to progress proposals, which included collaboration to support a successful funding bid for Superfast Broadband for Somerset. Consultation will continue beyond the submission of the DCO. The Employment, and Skills Operations Group’s remit relates not only to the strategy but also to the implementation of skills interventions and these will continue throughout the construction of HPC and into its operational phases.

iv. Commercial Property

4.3.74 EDF Energy funded the local authorities to develop a commercial property database to identify land and premises that could be used by potential suppliers working on the Project. EDF Energy will continue to engage with the local authorities to ensure this database is updated as construction progresses.

d) Employment and Skills Operations Group

4.3.75 An Employment and Skills Operations Group (ESOG) was created in October 2010 to develop employment and skills interventions for the HPC Project. Representatives from EDF Energy, SWRDA, SDC, WSC, SCC, Bridgwater College, West Somerset Community College, Jobcentre Plus and Construction Skills attended its monthly meetings.

4.3.76 The remit of the ESOG was to progress the development of education, employment and skills across the construction phase. Full information on the employment and




skills strategies can be found in the Construction Workforce Development Strategy (CWDS) submitted as part of this application.

4.3.77 A range of employment and skills projects, described below, were developed and discussed with members of the ESOG. Feedback from members was embedded into the Project plans, and captured as part of the CWDS.

i. Education Strategy

4.3.78 The Education Strategy, known as ‘Inspire’ has been developed by EDF Energy in collaboration with the authorities in Somerset and other key education stakeholders, including, but not limited, to schools across Somerset, Bridgwater Education Trust and Bridgwater College.

4.3.79 The primary focus of the Education Strategy relates to encouraging young people to participate in science, technology, engineering and mathematics subjects (STEM), with EDF Energy’s proposals detailing the development and implementation of initiatives to do so. The informal engagement undertaken with schools and education providers as part of the Education Strategy scoping exercise is detailed in this chapter.

4.3.80 The ESOG members reviewed the Education Strategy and provided valuable feedback, which was supplemented through frequent meetings with EDF Energy and SCC, as well as regular email and telephone conversations.

ii. Construction Workforce Development Strategy

4.3.81 The employment, skills and education work areas cover a number of projects detailed in the Construction Workforce Development Strategy (CWDS) and Education Strategy. Detailed discussions on these projects took place via the Employment, Education and Skills Operations Group, which fed into SETG.

4.3.82 The CWDS details the strategic implementation of employment and skills projects throughout the construction phase of the Project, including:

Employment Brokerage;

Employment Outreach;

Construction Skills Centre;

Hinkley Ready Skills Project;

Hinkley Enterprise Centre Project; and

Apprenticeship Strategy

Employment Brokerage

4.3.83 Interaction with stakeholders, including Jobcentre Plus, on the Employment and Skills Operations Group provided a detailed understanding of the employment brokerage model. For example the dispersed nature of the population in some areas of Somerset led to the agreement to have a ‘Hinkley champion’ at each of the Job Centres in the region to specialise in HPC job opportunities. Further information on EDF Energy’s informal engagement to develop the employment brokerage programme can be found in the Jobcentre Plus section of this chapter.




4.3.84 Discussions on the employment outreach strategy mainly focused on the scope and nature of possible interventions. The members of the Skills Operations Group agreed a definition of employment outreach at their meeting on 24 June 2011 as follows:

“It was agreed that for the purposes of the strategy Employment Outreach would focus on making ‘work ready’ people ‘job ready’ to undertake roles at Hinkley Point C. ‘Work ready’ refers to people who are capable of entering into full time, or part-time jobs, whilst not possessing the requisite skills to obtain sustainable employment.” Note from ESOG meeting, 24.06.11.

4.3.85 As a result of these discussions, EDF Energy has provided for the following personnel to support the work of the authorities to undertake community outreach work, which will complement EDF Energy’s employment project activities:

Community Outreach Worker for Sedgemoor District Council;

Community Outreach Worker for West Somerset Council;

Employment and Skills Manager to work within the Brokerage Management Unit on secondment to EDF Energy from Sedgemoor District Council;

Youth Worker for Somerset County Council; and

Support for each Community Worker to facilitate their activities.

4.3.86 Further information on EDF Energy’s informal engagement on the Employment Brokerage and Outreach programme can be found in the Jobcentre Plus section of this chapter.

Construction Skills Centre

4.3.87 EDF Energy published a draft Construction Workforce Development Strategy for review and consultation at Stage 2. At this time, EDF Energy proposed to create a partnership with a local training provider, Bridgwater College, to establish a Construction Skills Centre (CSC) in Sedgemoor.

4.3.88 The members of the Skills Operation Group discussed ways to better link the skills offer provided at the CSC with the projects being undertaken in West Somerset Community College. In addition, discussions took place to ensure the CSC provision underpinned the employment brokerage and employment outreach projects.

4.3.89 Further details of EDF Energy’s informal engagement on the CSC can be found in the Bridgwater College section of this chapter.

Hinkley Ready Skills Project

4.3.90 The Hinkley Ready Skills Project (HRSP) is designed to align training provision from West Somerset Community College (WSCC) with the requirements of the Project. EDF Energy will be providing assistance to WSCC to achieve this objective, through the construction of a new mechanical and electrical workshop and updating of other existing facilities.




4.3.91 Initial discussions at the ESOG revolved around the location of the facility which would deliver the training output of the HRSP. West Somerset District Council initially suggested that a facility, either new build or a leased building, should be located in Williton.

4.3.92 Following group discussions, it was decided that the HRSP should be located at the main West Somerset Community College site in Minehead. The site has adequate space adjacent to existing vocational provision.

4.3.93 Further information on EDF Energy’s informal engagement on HRSP can be found in the West Somerset Community College report in this chapter.

Hinkley Enterprise Centre Project

4.3.94 During the Stage 2 consultation, proposals included provision for an apprenticeship hub to be located in West Somerset. Feedback from consultees, discussions with West Somerset Community College and WSC resulted in a change to the skills approach and the proposal to develop a broader skills offer. At the Stage 2 Update consultation, EDF Energy proposed to replace the apprenticeship hub with a more appropriate project in West Somerset. It was agreed that this would centre on the provision of sustainable opportunities and the Hinkley Enterprise Project (HEP) was conceived.

4.3.95 Consultation has taken place with both Williton Parish and Stogursey Parish councils about the HEP and to seek their feedback on its possible location. EDF Energy, WSC and West Somerset Community College are working in a collaborative manner to progress proposals and are undertaking a feasibility study on the HEP that will be scrutinised by the Skills Operations Group on completion. Further information on EDF Energy’s informal engagement on the HEP can be found in the West Somerset Community College section of this chapter.

Apprenticeship Programme

4.3.96 An apprenticeship project has also been discussed at the ESOG. However, detailed proposals for this project will be progressed when EDF Energy Tier 1 contractors are appointed onto the scheme, as these contractors will be the main potential employers for apprentices. Details on the approach for apprentices are included in the Construction Workforce Development Strategy.

e) Transport

4.3.97 The Hinkley Point C proposals will have an impact on transport networks across a number of local authorities. The decision was taken at an early stage to consult the relevant local authorities and the Highways Agency (HA), ensuring effective engagement at a technical level and allowing stakeholders the opportunity to co-ordinate their responses. The stakeholders, referred to as the ‘relevant authorities’ within this section are:

Highways Agency (HA)

Sedgemoor District Council (SDC)

Somerset County Council (SCC)

West Somerset Council (WSC)




4.3.98 In addition to the relevant authorities, local community stakeholders and the wider public were also engaged prior to the formal Stage 1 consultation process. These included the following:

Parish, town and community councils;

Councillors and officers from local planning authorities;

Local and national trade associations and NGOs;

Hinkley Point Site Stakeholders Group (SSG);

Education organisations;

Business groups;

Hinkley Point Power station staff; and

Political groups.

4.3.99 The Strategic Officers Group (SOG), referred to in 4.3 above, met monthly up to Stage 1 and Stage 2 consultation and served as a forum to consider transport issues prior to the formal consultation exercises. In addition, a number of technical meetings were held with the highway authorities and their consultant representatives.

4.3.100 Preparation of the transport strategy associated with nuclear new build at Hinkley Point began in late 2007. At this time British Energy (prior to its acquisition by EDF Energy) was developing plans relating to a new planning application and discussions with the relevant authorities took place. This consultation informed the development of a strategic transport masterplan in July 2008, which detailed the transport accessibility issues associated with HPC.

4.3.101 The strategic transport masterplan formed the basis of the scoping discussions throughout 2008, taking the form of meetings with the relevant authorities. During this period the scope of the data collection exercise required to inform the transport modelling process was agreed.

4.3.102 The informal scoping discussions with the relevant authorities from 2008 to submission of the DCO were facilitated with regular monthly meetings on transport matters with all transport stakeholders present and with other specialist transport meetings held in intervening periods. Officers or representatives of the local planning authorities attended many of these meetings.

4.3.103 Direct consultation was undertaken with officers of SCC and SDC between September and December 2008 in relation to specific aspects of the highways works associated with HPC. This included email correspondence and telephone dialogue with various Somerset transport and highway officers. EDF Energy’s transport consultants, met on two occasions in late 2008 with highway officers of SCC. This allowed EDF Energy to agree the details of the data-collection exercise to inform the Transport Assessment and the modelling methodology to be adopted. The following items were agreed:

the geographic cordon for the traffic surveys;

the times and dates of surveys to be undertaken;

their methodology;




the appropriateness of the application of the SCC’s SATURN strategic traffic model with regard to the assessment of traffic matters associated with the proposed development; and

to discuss relevant data already in the public domain.

4.3.104 A further meeting was held with officers of SCC and SDC in November 2008 on transport matters. The following key issues were addressed in the 2008 and 2009 pre-application scoping discussions:

planning policy context of proposal;

catchments/study area for the proposed development;

assessment years – year of opening and horizon year(s);

assessment of public transport capacity, walking/cycling capacity and the road network capacity;

person trip generation and trip distribution methodologies;

measures to promote sustainable travel; and

mitigation measures (where applicable) – scope and implementation strategy.

4.3.105 Following the submission of the strategic transport masterplan in July 2008 a number of informal submissions relevant to all of the above key issues were made to the relevant authorities, prior to the formal Stage 1 consultation in December 2009.

4.3.106 A transport baseline report was completed in December 2008 and was submitted informally to the relevant authorities for comment in 2009. This report predominantly detailed data collection exercises and their methodology. The principal function of the report was to detail the 2008 baseline transport and traffic scenario as identified in October 2008 so as to inform future assessment work and to scope out certain transport data. Comments were received from the Highways Agency and their consultants and these were addressed in subsequent transport assessment studies.

4.3.107 Meetings were held with SCC in January 2009 to agree the transport assessment and in particular the traffic modelling strategy that informed the assessment. A draft strategic travel plan was subsequently submitted to the relevant authorities and the Local Planning Authorities for comment in September 2009. This document detailed the emerging transport strategy that was then subsequently detailed in EDF Energy’s Stage 1 Pre-Application Consultation Document on ‘Initial Proposals and Options’ issued in November 2009.

4.3.108 EDF Energy and its consultants worked in close association with local authorities to help determine and refine the direction and format of the transport strategy. SCC issued a key recommendations technical note dated 1 October 2009 that reviewed transport-related work undertaken to date. This summarised the local Highway Authority’s key comments for issue to EDF Energy and their consultants for consideration.

4.3.109 A transport sub-group met in January 2009 where the traffic modelling methodology for assessment was discussed. This was attended by officers of the relevant authorities, together with Atkins Transport Planning, in their capacity as consultants




to SCC for their SATURN role. The assessment approach was subsequently ratified by the relevant authorities and their consultants.

4.3.110 Following agreement of the assessment approach, EDF Energy and its transport consultants met in February 2009 with SCC and Atkins Transport Planning to agree the specific parameters of the strategic network model. The HPC Transport Model was developed throughout 2009, taking account of points discussed with the highways stakeholders and assessing the transport impacts of the proposed development.

4.3.111 Throughout the period from August 2009 until DCO application numerous meetings were held with the relevant local authorities. In the majority of these meetings the subject matter under discussion was usually transport strategy or highway mitigation proposals. Key issues raised included:

the impact construction worker and HGV traffic would have on the capacity and safety of the road network;

the perceived need for a northern Bridgwater bypass;

the rationale behind the proposed Cannington bypass;

the need for freight to travel by water;

the provision of parking on-site; and

the need to promote and facilitate non-car modes of transport.

4.3.112 It was concluded at the meetings that the Transport Strategy and Assessment must demonstrate that the traffic associated with the construction and operation would be fully mitigated by highway improvements.

4.3.113 As well as Sedgemoor County Council, Somerset County Council, West Somerset Council and the Highway Authority, other bodies attending these meetings included:

Bridgwater Town Council;

Cannington Parish Council;

Nether Stowey Parish Council;

North Petherton Parish Council;

Otterhampton Parish Council;

The Sedgemoor Area Planning Group;

Stogursey Parish Council;

Taunton Deane Borough Council;

Wembdon Parish Council; and

Williton Parish Council.

4.3.114 A special meeting held in August 2009 to discuss traffic modelling, included members of SCC, together with attendees from the Highways Agency, Atkins Transport Planning and EDF Energy’s transport consultants. It was resolved that the County




Council’s traffic model SATURN and their consultants, Atkins, should be used initially to test the potential impact of traffic diversion to a Bridgwater bypass.

4.3.115 From the period of March 2010 until December 2010, weekly update meetings were held between EDF Energy and the relevant local authorities.

4.3.116 During the period from January 2011 until June 2011 these weekly updates were rescheduled to become fortnightly workstream meetings with the same stakeholders in attendance. The transport topics discussed were traffic modelling, freight management, public transport, highway safety, traffic management, transport assessment, mitigation, the Cannington and Bridgwater bypasses, travel plan, transport policy and programming. The final transport proposals can be found in the Transport Assessment document, submitted as part of the DCO application.




4.4 Engagement with Regulators

4.4.1 In the UK, nuclear safety, security and environment protection is controlled through a comprehensive framework of legislation and regulations, overseen by appropriate regulators. The regulations apply throughout the lifetime of a nuclear power station, from the design stage through to its eventual decommissioning.

4.4.2 The key regulators for the nuclear industry are the Environment Agency (EA) and the Office for Nuclear Regulation (ONR).

4.4.3 The licensing and permitting of nuclear power stations by the nuclear regulators is an important regulatory process which nuclear power stations have to undergo.

4.4.4 The Department for Energy and Climate Change (DECC) advises that applicants should involve the nuclear regulators early enough during the pre-application stage so that they have the opportunity to incorporate the relevant regulators’ requirements in their proposals, where appropriate. EDF Energy followed this advice and has engaged with the nuclear regulators throughout the development of the Hinkley Point C Project.

4.4.5 The framework through which operators liaise with the regulators in the context of specific permits and licences is formal and structured. This engagement framework facilitates the early sharing of information between regulators and operators and provides a clear process for reaching formal agreement.

a) Environment Agency

4.4.6 The Environment Agency has two key roles within the IPC process. As a regulator, the EA provides information to the IPC on the applications it has received from the developer (EDF Energy) and its progress in determining them.

4.4.7 In its role as a statutory consultee, the EA has been heavily involved in EDF Energy’s consultation on the proposals for Hinkley Point C, having provided feedback at all stages of formal consultation, as well as engaging informally. As a statutory consultee in the planning process, the EA may also be asked to provide advice to the IPC on environmental issues relating to the HPC proposals.

4.4.8 It is important to note that EDF Energy and the EA have always been careful to distinguish the respective roles of the EA in terms of the information submitted to the organisation. It should be noted that the EA cannot share information across its responsibilities as a statutory consultee and regulator. Further information on EDF Energy’s informal engagement with the EA as a statutory stakeholder is detailed in this chapter.

4.4.9 EDF Energy has engaged with the EA in its regulatory capacity on the various environmental permits that are being submitted for the HPC development. The purpose of this engagement, prior to submission, has been to ensure that all applications contain the appropriate information to enable the EA to carry out its determination process.

4.4.10 The three main operational environmental permit applications are Radioactive Substance Regulation, Combustion Activity and Water Discharge Activity. All environmental permit applications are made to the EA under the Environmental




Permitting Regulations 2010. The applications relate to discharges and disposals of radioactive waste, cooling water and trade effluents, and the operation of standby power supply systems.

4.4.11 The Radioactive Substance Regulation and Combustion Activity permit applications were submitted to the EA in July 2011 and the Water Discharge Activity permit application was submitted in September 2011.

4.4.12 The Environment Agency is now seeking views on these applications for environmental permits. Further information can be found at http://www.environment-agency.gov.uk/news/132542.aspx

b) Office for Nuclear Regulation (ONR)

4.4.13 The Office for Nuclear Regulation (ONR) is an independent regulator, formally responsible in law to regulate the nuclear power industry. It sets national regulatory standards and helps to develop nuclear safety standards.

4.4.14 There has been engagement with the ONR on the HPC proposals throughout the development of the Project. This includes formal and structured engagement in particular in relation to:

1) The Generic Design Assessment, which reviews the EPR technology, assessing whether it is licensable. Both the EA and ONR have been involved in this process.

2) The Nuclear Site Licence (NSL) process, which assesses whether the technology can operate on the specific site, the capability of the organisation including the arrangements to comply with the conditions of a nuclear site licence.

c) Health and Safety Executive (HSE)

4.4.15 EDF Energy has engaged jointly with the HSE, EA and ONR in the context of Hazardous Substance Consent. Several meetings and discussions have taken place with the key regulators, along with West Somerset Council in its capacity as Hazardous Substances Authority (HSA). The application for Consent will be sought from WSC, outside the DCO process, and discussions with each Regulator will therefore continue into 2012 and up to the point of application.




4.5 Statutory Consultees

a) CABE

4.5.1 EDF Energy has engaged with the Commission for Architecture and the Built Environment (CABE), now part of the Design Council, since August 2009. Due to the nature of the engagement with CABE, it is necessary to summarise some of its formal response to consultation to put the outcomes of the informal engagement into context.

4.5.2 Engagement with CABE, a prescribed body under section 42 of the Act, has allowed EDF Energy to gain guidance in developing the proposals at the HPC permanent Development Site, particularly in relation to the work on the masterplan, building design and landscaping.

4.5.3 EDF Energy has met with CABE through a number of formats, including informal meetings, a site visit and CABE design review panel presentations held since September 2009. An initial site visit with CABE representatives took place in August 2009, to allow for familiarisation of the site and its setting.

4.5.4 Informal meetings have taken place during the pre-application period in order to prepare for the CABE design review panel presentations and to reflect on the progress made on the masterplan and building design.

4.5.5 Three design review panel presentations have been held in September 2009, July 2010 and July 2011. These presentations gave an opportunity for EDF Energy’s design team, including architects and landscape architects, to present the development of the design, providing a forum for discussion, ideas and comments from CABE for further consideration. The third presentation in July 2011 focused on responding to CABE’s comments received at Stage 2 consultation.

4.5.6 At each design review panel presentation 12 boards were presented which illustrated the masterplan and design development. Two physical models were also presented at the second CABE design review panel.

4.5.7 Following each design panel review CABE provided written feedback. As the presentations held in September 2009 and July 2010 were closely tied to Stage 1 and Stage 2 consultations, these comments have been included in full and responded to in Appendix H of this report. A summary of CABE’s comments and EDF Energy’s response is necessary to provide context for the informal engagement outcomes details below.

4.5.8 In summary, at Stage 1 CABE was encouraged by the masterplan for the site but sought further design development in order to establish meaningful concepts and principles for the site. It was keen to see the buildings treated with honesty as powerful industrial objects, and urged EDF Energy to invest in high quality architecture and landscaping. As a result EDF Energy developed the masterplan with the design team further, using structured ordering principles in the form of stripes (bands) across the site.




4.5.9 At Stage 2 CABE recommended further refinement of the stripes throughout the development and the relationship with the buildings. More work on the treatment and definition of site edges was requested including suggested improvements to the design of fencing in the vicinity of the coastal path, which is incorporated into the sea wall.

4.5.10 Further consideration of the architectural approach and relationship between buildings, namely the turbine halls and operational service centre, was encouraged, alongside ensuring that materials were durable for long term use and that informal eating space was provided for staff during their working breaks. The Commission requested that the location of the Public Information Centre be given further consideration in respect of improving vistas of the power station from the public viewing gallery.

4.5.11 CABE also commented on consideration of lighting design and the opportunities for sustainable measures to be incorporated into the design of auxiliary buildings.

4.5.12 EDF Energy sought to address the key issues raised by CABE and responded through the design review panel held in July 2011. CABE responded to EDF Energy by letter in August 2011, indicating its support for the use of the ordering device for the site and the straightforward treatment of the industrial buildings.

4.5.13 CABE’s letter also stated that more planted areas within the operational site would significantly improve the quality of the environment for staff and visitors.

4.5.14 Durability of materials and the approach to lighting on the site was commented on by CABE, who also encouraged the design team to develop the sustainability strategy further and sought reassurance on the wider impacts and on sea levels following the events at Fukushima in Japan in March 2011.

4.5.15 EDF Energy clarified its position on points raised by CABE, including where issues were already in hand, and where issues would be addressed through the detailed design. Where EDF Energy was unable to take into account CABE’s comments this was clearly set out. EDF Energy’s detailed response to CABE is provided in the Hinkley Point C Development Site Design and Access Statement.

4.5.16 Key areas of change as a result of engagement with CABE can be summarised as follows:

The ordering principles of the concept have been developed and refined to provide a grid pattern of more varied landscape bands aligned north-south and the principal roads in the east-west direction;

Building lines have been introduced to align the frontage of the ancillary buildings south of the Nuclear Island to improve the geometric ordering in this part of the site;

The Public Information Centre (PIC) has been repositioned to a more central location to reinforce the status of the PIC as the point of engagement with the local and wider community. The positioning to the side of the north-south axis provides views of all the key buildings and the Bridgwater Bay beyond which would be obscured if the building was located exactly on the axis;




A pedestrian square for the public has been formed between the PIC and Simulator Building/Training Centre (STC). This reorganisation indicated that the option of tightening the layout should be adopted; the access route to the PIC has been improved to enhance the visibility of the PIC as it is approached;

The experience along the coastal path has been improved by widening the space between the path and the security fence;

Further consideration of building materials and design has been made;

The relationship between the Operational Service Centre (OSC) and Turbine Halls has been improved with the introduction of the linking ‘skybridges’ and the standardisation of the architectural approach and materials to be used; and

The OSC design includes a sheltered outside space (terrace) linked to the restaurant on the third floor for use by staff and benefits from views across the site and Bridgwater Bay beyond.

4.5.17 At each stage of consultation, EDF Energy has sought to address CABE’s comments and respond directly to CABE. EDF Energy intends to continue its engagement with CABE in the working up of the detailed design proposals for HPC, in order to ensure a high quality development.

4.5.18 In addition to the engagement with CABE on the HPC Development Site, EDF Energy has also held meetings the South West panel of CABE in order to discuss the associated developments.

4.5.19 The masterplans for the proposed off-site associated developments were presented to the South West Design Review Panel, in collaboration with CABE, in July 2010. Those layouts were the same as those presented within the Stage 2 consultation documents.

4.5.20 The principal response related to the level of information that was available for review at the time. Queries were raised in respect of the transport and socio-economic strategies which underpin the HPC Project, as well as queries regarding the potential legacy and sustainability benefits of the proposed developments. Details of these aspects have been developed since this time and are detailed in the documents which are submitted in support of the application for Development Consent.

b) Environment Agency

4.5.21 The Environment Agency has a dual role in the IPC process as both a regulator and as a statutory stakeholder. As a prescribed statutory consultee under section 42 of the Act, EDF Energy has conducted ongoing engagement with the Environment Agency (EA) on the HPC proposals and the surveys and assessment work which inform the Environmental Statement (ES) for the Project.

4.5.22 Early engagement with the EA commenced in 2008 to agree the scope of the baseline studies (including monitoring plans for surface water, marine water, groundwater and gas) on the HPC Development Site. Subsequent consultation has been held to review the results of the monitoring campaigns agreed; consider proposals for further monitoring and assessment work for the HPC Development Site and the off-site associated developments sites; agree assessment methodologies; review the assessment outputs including draft and final environmental impact assessment; and other project documentation of interest.




4.5.23 EDF Energy and the EA have had weekly telephone conferences since December 2010 to maintain progress and ensure that issues arising from the different workstreams (set out in detail in later sub-sections) were being addressed. These conference calls were supplemented by regular review meetings, typically monthly, which monitored progress across the workstreams. Prior to this, regular telephone conferences and meetings were held, albeit they were scheduled on a less regular basis, at the request of either party to discuss specific matters.

4.5.24 These progress meetings were supplemented with technical meetings to focus on specific sites or workstreams. These are detailed in the technical assessments within the Environmental Statement. For the topics consulted on with the EA, EDF Energy has shared draft documents (including draft ES chapters) upon which the EA has commented and EDF Energy acted on where appropriate.

4.5.25 Having regard to the EA’s consultation responses to Stages 1, 2, 2 Update and Junction 24 and Highway Improvements consultations, the following workstreams were identified between the parties:

flood risk assessment, including modelling;

hydrology, drainage and water quality (surface water);

land contamination;

groundwater;

marine water quality;

marine and terrestrial ecology;

environmental management and monitoring plans; and

conventional waste.

4.5.26 Pollution prevention was a cross-cutting theme for all of the workstreams.

4.5.27 Dialogue has been held with the EA for each of these workstreams for each of the sites, where applicable. In many cases, informal engagement with the EA occurred as a result of the formal stages consultation, which highlighted key issues relating to the Project. The nature of EDF Energy’s relationship with the EA means that an iterative process was adopted in finalising the proposals, with ongoing discussions taking place throughout the pre-application consultation period. As such, many of the issues raised during informal engagement are reflective of the EA’s formal responses. A summary of the dialogue undertaken is provided below. In each case a summary of the key issues and how these were addressed is provided below.

i. Flood Risk


4.5.28 In response to EDF Energy’s Stage 1 consultation, the EA provided comments on the requirement for a Flood Risk Assessment (FRA) and the EA’s national policy on the culverting streams, in this instance Holford Stream, advising that consent to culvert would only be forthcoming if the need was proved exceptional, and that there would be no adverse impact on flood risk, third party land drainage and environmental quality.




4.5.29 Following a request from the EA, EDF Energy undertook a detailed review of the proposals to culvert Holford Stream, which concluded that culverting Holford Stream within the development site is the best available option to meet the engineering needs of HPC whilst ensuring that no significant environmental impact occurs as a result of its construction and operation.

4.5.30 Following the Stage 1 consultation there have been ongoing scoping discussions on the FRA with the EA which have included the preparation and review of a scoping report, modelling, draft Flood Risk Assessment and modelling material. Key flood risk issues consulted upon with the EA, included:

tidal and fluvial flood risk (including the C182 crossing points, emergency access road bridge, culvert and influence of the development platform);

other sources of flooding including groundwater, pluvial and flooding from sewers and artificial sources;

modelling methodologies;

climate change allowances;

modelling scenarios to include the 1 in 30, 1 in 100, 1 in 200 and 1 in 1,000 year events in accordance with requirements dependant on the source of flood risk and receptors assessed;

the sea wall design (including details on the physical modelling);

the EA’s flood warning service;

the drainage strategy, including construction and operational drainage, and the transition from construction to operational drainage;

consideration of cumulative schemes on the Steart Peninsula proposed by The Bristol Port Company and the EA; and

the approach to mitigation.

4.5.31 The EA provided comments on these and EDF Energy has taken on board this feedback. Specific details on the nature of these comments are documented in the individual site-specific Flood Risk Assessments.

Off-Site Associated Development Sites

4.5.32 In response to EDF Energy’s Stage 1 consultation the EA provided comments on the merits of each of the proposed off-site associated development options presented and gave guidance on the scope of the flood risk assessments to be undertaken. EDF Energy prepared draft flood risk assessments in support of its Stage 2 consultation, which the EA duly provided comments on. An iterative process followed whereby EDF Energy took account of the comments and issued further versions of the draft documents for comment. Table 4.1 below outlines the principal issues raised in relation to each of the proposed off-site developments.




Table 4.1: Summary of Environment Agency comments on flood risk for AD sites

Off-Site Associated Development Site

Matter Raised by Environment Agency

Response of EDF Energy

All off-site associated developments (excluding highway improvements)

The EA provided feedback on the options presented at Stage 1 consultation on the suitability of each site for development, with regard to the flood zone classification for the site.

The EA sought additional details to demonstrate that the development could proceed without impact to others.

Comments from the EA, as well as those from other stakeholders, were considered as part of EDF Energy’s site selection process and as part of the detailed design stage.

EDF Energy has continued to refine the masterplans. This has included rationalisation of the amount of land required for each of the proposed developments as much as possible for a number of reasons including to minimise flood risk impacts.

Bridgwater A Accommodation Campus site

No specific comments received.

Bridgwater C site The EA requested an evacuation strategy be developed.

The flood evacuation strategy is detailed in the Bridgwater C Flood Risk Assessment.

Cannington bypass site The EA sought demonstration that there would be no impact to third parties.

The Cannington Bypass Flood Risk Assessment demonstrates that there is no impact to third parties as a result of the proposed development.

Cannington park and ride site

The EA sought clarity over the layout of the site, particularly in respect of culverts.

The proposed development has been sited so that it would not result in a loss of the existing flood alleviation channel. Changes to the siting of the park and ride to the west of the existing flood alleviation channel rather than on both sides has minimised the amount of culverting required. Culverting is now only required where the access road enters the site. See Cannington Park and Ride Flood Risk Assessment for further information.

Combwich site The EA sought demonstration that there would be no impact to third parties and that compensatory flood storage would be incorporated, where required.

The freight laydown facility would be removed following cessation of the construction phase of the HPC power station, in part because the land is in the floodplain and the site is only identified as being suitable for development which is ancillary to waterborne activities. See Combwich Flood Risk Assessment for further information.







Junction 23 site The EA sought demonstration that there would be no impact to third parties; and compensatory flood storage would be incorporated and safe access and egress was provided.

Works to increase the level along part of the bank are proposed to ensure that any future flooding of the Parrett would not have a greater impact to third parties with the proposed development in place.

Compensatory storage is not required as a result of the proposed development.

The site levels have been set, in part, to ensure that safe access and egress would be available at all times to the proposed development. See Junction 23 Flood Risk Assessment for further information.

Junction 24 site The EA sought additional details to demonstrate that the development could proceed without impact to others.

The Junction 24 Flood Risk Assessment demonstrates that there is no impact to third parties as a result of the proposed development.

Williton park and ride site


4.5.33 As with the HPC Development Site, draft flood risk assessments and associated flood models were submitted to the EA prior to submission of the DCO application.

ii. Surface Water


4.5.34 In response to EDF Energy’s Stage 1 consultation, the EA provided comments on the HPC flood risk assessment and the culverting of Holford Stream as detailed above, and also pollution prevention during the construction and operation of HPC. With respect to pollution prevention the EA highlighted key guidance that should be taken into consideration and their expectations with regards to management procedures on site to minimise the potential for pollution occurring and the protection of controlled waters.

4.5.35 For the HPC Development Site, the EA requested further details on the drainage strategy and clarification on the nature of surface water discharges including the volumes, outfall arrangements, duration and nature of all discharges during construction together with any overlap with discharges arising from the commissioning and operation of HPC. EDF Energy has provided details, through ongoing dialogue with the EA on both planning and environmental permitting requirements. This is considered in detail in the Environmental Statement.

Off-site Associated Development Sites

4.5.36 The EA commented on the merits of each of the proposed off-site associated development options presented as part of EDF Energy’s Stage 1 consultation; and gave guidance on the scope of the surface water assessments. EDF Energy prepared an Environmental Appraisal in support of its Stage 2 consultation, on which the EA duly provided comments. An iterative process followed whereby EDF Energy took account of the comments and issued further versions of the draft documents for




comment. Table 4.2 below outlines the principal issues raised in relation to each of the proposed developments.

Table 4.2: Summary of Environment Agency comments on surface water for AD sites




All off-site associated developments

The EA sought the inclusion of a sustainable drainage strategy and mitigation within each of the proposed developments.

The EA sought the inclusion of pollution prevention measures, where relevant, to ensure water quality would not be compromised as a result of the proposed developments.

Drainage strategies have been developed with the EA. Site specific details are set out below.

Pollution prevention measures have been included within the proposed developments, as appropriate. Management plans have been prepared detailing the procedures and controls that will be in place during the construction, operational and post-operational (as appropriate) phases for each of the proposed developments.

Bridgwater A site The EA stated that the proposed drainage design acceptable provided that a future connection to the North East Bridgwater rhyne system could be made.

The EA stated that they would also wish to see the removal of the pumped drainage element for any future development.

A connection to the North East Bridgwater rhyne system is EDF Energy’s preferred option for the site and will be undertaken providing it is technically feasible (subject to detailed design.)

The removal of the pumped drainage element would be dependent on the post-operational development.

Bridgwater C site The proposed drainage design is acceptable to the EA subject to confirmation with Wessex Water that the proposed out-flow from the site includes both surface water and foul water flows.

This element has been confirmed with Wessex Water.

Cannington bypass site The EA stated that the overall drainage strategy was acceptable in principle; albeit some design modifications were suggested.

A detailed design strategy is included within the Cannington Bypass Flood Risk Assessment, on which the EA was consulted.








The EA stated that the overall drainage strategy was acceptable in principle; albeit some design modifications were suggested.

The EA stated that a Flood Defence Consent is required in connection with the new access crossing over the ditch between the A39 and the site entrance.

The EA sought more information concerning the upgrade to the Flood Alleviation Scheme in the Cannington area.

The EA stated that foul sewage/septic tank arrangements would only be acceptable subject to ground investigations, including soakaway testing.

A detailed design strategy is included within the Cannington Park and Ride Flood Risk Assessment, on which the EA was consulted.

An application for consent would be submitted prior to commencement of any relevant works.

Refer to the draft Section 106 Agreement (draft Heads of Terms) for details.

Details of the ground investigations have been submitted to the EA; and the conclusions have informed the proposals.

Combwich site The EA stated that a Flood Defence Consent is required in connection with the proposed flood bund and alterations to the existing Parrett flood defence embankment.

The EA sought confirmation of the surface water drainage arrangements.

An application for consent would be submitted prior to commencement of any relevant works.

A detailed strategy is included within the Combwich Flood Risk Assessment, on which the EA was consulted.







Junction 23 site The EA accepted the proposed pumped drainage solution, subject to the caveat that the northern car park area is only temporary and that the pumped drainage system would be removed following cessation of use of the site by EDF Energy.

The EA queried whether Detention Basin 2 should be dry rather than wet, having regard to the post-operational use of the site and the characteristics of the site.

The northern part of the site would be removed following cessation of use by EDF Energy as part of any post-operational scheme.

The detention pond is designed to be dry most of the time and would only store water for a relatively short period after severe storms and when the river is at high tide. A wet pond is not considered suitable as this would result in the creation of a possible ecological habitat on the site, which would be difficult to remove if the site were returned to agricultural use during the post-operational phase.

Williton site The EA stated that more certainty was required regarding the route and condition of the receiving water course for the surface water drainage from the site.

The EA requested that the viability of infiltration drainage was fully investigated

A close circuit television (CCTV) survey was undertaken to inform the proposed drainage strategy which was issued to the EA.

Infiltration testing was undertaken as part of the site investigations and this data was included within the proposed drainage strategy.

iii. Land Contamination and Groundwater


4.5.37 In response to EDF Energy’s Stage 1 and 2 consultation, the EA provided comments on the HPC monitoring results to date and early assessment work and provided feedback specifically on potential contamination in Built Development Area East given its historical land uses, and the dewatering strategy for the deep excavations, particularly concerning the potential for contaminant transport from the existing Hinkley Point A site, which is currently being decommissioned but has known levels of radiological and non-radiological contaminants. The EA advised on the need to develop dewatering plans to mitigate the risk of drawing potential contamination upwards and discharging at the surface at concentrations that may be unacceptably high. Further detailed modelling work was undertaken on the potential contaminant transport. The results of this modelling were presented to the EA at a meeting in April 2011 for discussion, which was followed up with consultation on the Environmental Statement chapters.




4.5.38 The results of the groundwater modelling associated with the dewatering of the excavations concluded that there is no known contamination on the Hinkley Point A site which would present a significant risk during the dewatering activities at HPC. However construction best practice measure would be implemented ensuring compliance to legislative requirements and appropriate monitoring as agreed with the EA.

4.5.39 At Stage 2, the EA also queried the potential for the dewatering activities to affect Wick Moor, emphasising its importance as a Site of Special Scientific Interest (SSSI). This has subsequently been given further consideration in the impact assessment, the details of which have been discussed with the EA with a general consensus on the conclusions, subject to monitoring in the Wick Moor area throughout the construction phase.


4.5.40 In response to EDF Energy’s Stage 1 consultation, the EA provided comments on the merits of each of the proposed off-site associated development options presented and gave guidance on the scope of the contaminated land and groundwater assessments. EDF Energy prepared an Environmental Appraisal in support of its Stage 2 consultation on which feedback from the EA was produced. An iterative process followed whereby EDF Energy took account of the comments and issued further versions of the draft documents for comment. Table 4.3 below outlines the principal issues raised in relation to each of the off-site associated developments.

Table 4.3: Summary of Environment Agency comments on land contamination and groundwater for AD sites




All off-site associated developments

The EA provided guidance on the scope of the assessments required, having regard to their knowledge of each of the sites.

The EA sought contaminated land investigations to be carried out as part of any pre-development activities.

The EA provided their knowledge of sensitive receptors close to the sites.

The assessments detailed in the Environmental Statement submitted in support of this application for Development Consent have regard to the guidance provided.

On the majority of the sites investigations have now been completed, although on some of the sites work is still ongoing. The scope of these investigations was agreed with the EA and the conclusion issued to them for their records.

This information helped inform the scope of the assessment, and the masterplanning and detailed design of the proposed development (see site-specific comments for details).







Bridgwater A site The EA stated that the Phase 1 Desk Study was acceptable but noted that a site walkover should be completed as soon as access to the site was granted and prior to any site investigations being carried out. The EA also noted that a number of standard conditions would be recommended.

A site walkover was undertaken at the site prior to the scope for the ground investigations being submitted to the EA for comment.

Bridgwater C site The EA stated that the Phase 1 desk study was acceptable but noted that a number of standard conditions (i.e. requirements) would be recommended.

The scope for the ground investigation was submitted to the EA for comment prior to the works commencing and they raised no objections to the proposals.

Cannington bypass site

The EA stated that the Phase 1 desk study was acceptable.


The EA stated that the Phase 1 desk study was acceptable.

The EA stated that they had no comments regarding the ground investigation report.

Combwich site The EA stated that the Phase 1 desk study indentified that there are unlikely to be any issues with respect to contaminated land, given its previous uses. However, given that the wharf area has been used in the past for industrial activity, an environmental site investigation to comply with PPS23 was sought.

The standard condition with respect to contaminated land should apply.

The site investigation and contaminated land risk assessment has now been undertaken. No remedial works were indentified as needing to be undertaken.

Junction 23 site The EA stated that the Phase 1 desk study was acceptable.

Junction 24 site No subject specific comments were received.

Williton Site No subject specific comments were received.

iv. Ecology

Off-Site Associated Developments

4.5.41 The scope of the ecology assessments was agreed with the EA in consultation with Natural England, SCC, WSC and SDC in 2009. Only a few additional comments were received from the EA formal consultations, the focus of which was on proposed




mitigation. The proposed mitigation measures are details in the Terrestrial Ecology and Ornithology chapters of the Environmental Statement. Table 4.4 below outlines the principal issues in relation to each of the off-site associated developments

Table 4.4: Summary of Environment Agency comments on ecology for AD sites




Bridgwater A site No subject specific comments were received

Bridgwater C site No subject specific comments were received

Cannington bypass site

The EA sought demonstration that the proposed developments would be multi-functional.

An oversized culvert, with ledges on both sides for otters, has been designed into the scheme to allow continued passage for otters along the watercourse crossed by the proposed Cannington bypass. Underpasses for other wildlife (including, badgers, amphibians and bats) have also been designed into the scheme.

A substantial programme of habitat creation has also been designed into the scheme. These proposals include a balancing pond in the northern part of the route to provide a new high quality wildlife pond.

Furthermore, in addition to all the measures that have been designed into the scheme to prevent impacts on ecological receptors, an outline ecological mitigation and habitat management plan has also been produced. This plan sets out a range of measures to deliver biodiversity benefits and mitigate unavoidable impacts.


The EA sought demonstration that potential impacts have been minimised.


The proposed development has been designed and located to minimise the potential for any impacts on Cannington Brook County Wildlife Site (and other ecological receptors such as otter and water vole).

A programme of habitat enhancement is also proposed. In addition to all the measures that have been designed into the scheme to prevent impacts on ecological receptors, an ecological mitigation and habitat management plan has been prepared. This plan sets out a range of measures to deliver biodiversity benefits and mitigate unavoidable impacts.

Combwich site The EA provided feedback on the scope of the assessment.

The EA specifically sought an assessment to identify bird species using the area close to the site. This was completed and details are provided in the Environmental Statement,







The EA sought demonstration that potential impacts have been minimised.

which the EA has been consulted on.

The wharf and laydown facility at Combwich have been designed to minimise the potential for impacts on nearby designated sites (including the Severn Estuary Special Protection Area (SPA)/Special Area of Conservation (SAC)/Ramsar Site, Bridgwater Bay SSSI and Combwich Brick Pits CWS) and the protected and notable species populations present within these sites (and other ecological receptors). For example, six culverts designed with reference to the Design Manual for Roads and Bridges (DMRB) has been included in the scheme design to facilitate otter movement through the site, even in flood conditions.

A programme of habitat enhancement is also proposed. In addition to all the measures that have been designed into the scheme to prevent impacts on ecological receptors, an ecological mitigation and habitat management plan has been produced for the site. This plan sets out a range of measures to deliver biodiversity benefits and mitigate unavoidable impacts.

Junction 23 park and ride, freight management, courier consolidation and induction centre site


The proposed development has been sited and designed to minimise the potential for impacts on ecological receptors. An example is the retention of the field pond that has been found to support notable aquatic invertebrate species.

A programme of habitat creation and enhancement (including the creation of new wetland habitats) is also proposed. In addition to all the measures that have been designed into the scheme to prevent impacts on ecological receptors, an ecological mitigation and habitat management plan has been produced for the site. This plan sets out a range of measures to deliver biodiversity benefits and mitigate unavoidable impacts.

Junction 24 site The EA sought demonstration that the proposed developments would be multi-functional.

The proposed development has been designed and located to minimise the potential for any impacts on Stockmoor County Wildlife Site (and other ecological receptors).

A programme of habitat enhancement is also proposed. In addition to all the measures that have been designed into the scheme to prevent impacts on ecological receptors, an ecological mitigation and habitat management plan has been produced for the site. This plan sets out a range of measures to deliver biodiversity benefits and mitigate unavoidable impacts.







Williton park and ride site


v. Marine Environment


4.5.42 EDF Energy has had ongoing consultation with the EA on the marine environment associated with the HPC proposals, namely impacts associated with the construction and presence of the sea wall, construction, operation and subsequent removal of the temporary jetty, construction and operation of the intake and outfall structures; the fish return system and also discharges associated with the construction outfall. The scope of the assessment work for the HPC assessment covers the following topic areas which are presented in three separate chapters:

coastal hydrodynamics and geomorphology;

marine water and sediment quality; and

marine ecology.

4.5.43 Comments received from the EA throughout the consultation period, both formal and informal, have focussed on potential impacts associated with the discharge of the thermal plume together with the discharge of chemicals via the cooling water outfall, and similarly discharges via the construction outfall as described above. These comments are particularly significant as the marine environment, which HPC has the potential to impact is a European designated feature and includes a Special Protected Area (SPA), a Special Area of Conservation (SAC) and a Ramsar site. There has been ongoing consultation on the potential impacts on the marine environment with the EA, and other statutory consultees including Natural England and the Countryside Council for Wales (CCW) as part of the Habitats Regulations Assessment (HRA). Further details of EDF Energy’s informal engagement on the HRA are provided in this chapter.


4.5.44 EDF Energy’s proposals for the freight laydown facility to support Combwich Wharf during the construction phase (when there will be a greater intensity of use) has changed at each stage of the Project’s evolution in response to feedback from consultees, as well as development of the nature and scope of this facility. Further details were provided to the EA, which enabled them to understand the need for the facility and any impacts on the environment, including flood defences along the river. Similarly, additional details of the proposed refurbishment of Combwich Wharf enabled the EA to understand the impacts on the cross section of the river and the tidal prism.




vi. Environmental Management and Monitoring Plans

4.5.45 EDF Energy consulted the EA on its draft Environmental Management and Monitoring Plan (EMMP) and subject-specific management plans for the HPC Project.

vii. Waste

4.5.46 The EA sought clarity on the waste management strategy, seeking conformity with the Contaminated Land: Application in Real Environment (CL:AIRE) code of practice. In response, EDF Energy consulted on its draft Waste Management Strategy as part of its Stage 2 Update consultation.

4.5.47 A subject-specific management plan has been prepared in respect of soil management, which forms part of the application for development consent. A Materials Management Plan and Soils Management Plan is provided in support of the DCO application, which provides the details sought by the EA.

4.5.48 The Waste Management Implementation Strategy, which has evolved from the draft Waste Management Strategy consulted on as part of the Stage 2 Update Consultation, forms part of this application and reflects all aspects of the Hinkley HPC Project, including the jetty. This responds to comments received from the EA. The draft of this document was submitted to the EA prior to submission of the application to the IPC. The EA provided comments and EDF Energy has taken on board this feedback when preparing the final document. Specific details on the nature of the comments are documented within the document itself.

4.5.49 The draft was also submitted to Somerset County Council at the same time as being submitted to the EA.

c) English Heritage

4.5.50 EDF Energy’s engagement with the relevant technical experts at English Heritage started in November 2009. However, there was contact with English Heritage via the Marine Liaison Action Group (MALG) from April 2009 and intermittent telephone contact on specific issues, either directly or via SCC Historic Environment Service (SCC HES), from July 2008.

4.5.51 English Heritage is the Government's lead advisory body for the historic environment and has a statutory role in the planning system. It has assisted EDF Energy in identifying potential impacts to the settings of designated heritage assets beyond the HPC site boundary and submerged archaeological deposits offshore.

4.5.52 A variety of topics were discussed at meetings between EDF Energy and English Heritage, including assessment requirements, results of baseline assessments and proposals for mitigation. English Heritage provided significant input into the palaeo-environmental investigation strategy carried out by EDF Energy across the HPC Development Site and associated development sites.

4.5.53 In addition to the meetings with EDF Energy, English Heritage attended main site walk-overs to look at the historic buildings and discuss Pixie’s Mound, as well as off-site visits to discuss heritage assets and s106 mitigation proposals.




4.5.54 English Heritage reiterating SCC HES’s view that the historic east-west track way, “Green Lane”, is a significant historic landscape feature that should therefore be retained as part of the development (further details of EDF Energy’s engagement with SCC HES are provided in this chapter). EDF Energy modified the plot plan in order to retain as much of the trackway as possible. A method statement will be provided detailing how the track way will be preserved and protected during the construction period.

4.5.55 English Heritage also concurred with SCC HES that historic buildings merited recording. English Heritage asked whether a building could be rebuilt, or material from the barns incorporated into any of the ancillary buildings. It has been agreed that the stone from the barns will be used for the rebuilding of the great plantation wall. A Written Scheme of Investigation (WSI) has also been agreed with SCC HES for historic building recording for the on-site barns.

4.5.56 EDF Energy commissioned a Historic Landscape Assessment (HLA) to investigate the landscape development of the site and its setting. EDF Energy’s final landscape restoration plan was subsequently reworked, taking into account English Heritage’s comments and is now more reflective of the findings of the HLA and the historic landscape character of the area.

4.5.57 EDF Energy has agreed to incorporate screen planting on Pixies field and move the vehicle search area further south opposite the mound. At meetings with English Heritage and SCC HES, EDF Energy agreed clearing of vegetation and limited excavation of the mound.

4.5.58 English Heritage also provided comments on a number of associated development sites. In response to concerns, the design of and landscaping has focused on minimising any impact on Brymore Ride, and also maintaining the connections between Brymore School and Cannington itself. In addition, as part of the Site Preparation Works s106 agreement, a series of public realm heritage enhancements have been suggested for Cannington.

4.5.59 EDF Energy also engaged with English Heritage on a number of marine issues to discuss all aspects on the offshore and intertidal archaeology assessment, including offshore geotechnical boreholes and vibrocores, baseline assessment and mitigation. Further information on the marine surveys carried out by EDF Energy can be found in the Environmental Statement Volume 2, Chapter 24 Offshore and Intertidal Archaeology.

4.5.60 EDF Energy undertook site investigations and found no remains. Aerial photographs of the construction of the original wharf were also examined and these suggest that any deposits that may have been present would have been destroyed by the construction techniques used at the time. No mitigation is therefore required.

4.5.61 In response to English Heritage’s queries as to whether any heritage assets (ship wrecks) posed a potential navigational hazard, therefore risking destruction or removal, EDF Energy commissioned a report which indicated that there would be no detrimental wash impacts that would affect wrecks, nor have any been identified as navigational hazards.

4.5.62 EDF Energy, throughout this continued engagement, has sought to take account of English Heritage’s comments, responding to requests for further surveys and




investigative work as much as possible. Engagement with English Heritage is expected to continue beyond 2011. The Inspector of Monuments for Somerset will monitor restoration works and landscape enhancements associated with Pixies’ Mound. The Regional Scientific Advisor will monitor and review the programme of analysis and publication of material recovered from the offshore boreholes.

d) Marine Authority Liaison Group (MALG)

4.5.63 EDF Energy established the Marine Authority Liaison Group (MALG) as a forum to undertake the pre-application consultation in relation to marine proposals and impacts of the HPC development.

4.5.64 The first meeting of the MALG took place in March 2009. The aim of the MALG was to focus on informing the design development of the proposed temporary jetty, sea wall, cooling water tunnels, site drainage and Combwich Wharf refurbishment.

4.5.65 The MALG included officials from West Somerset Council, Sedgemoor District Council, Somerset County Council, Environment Agency, Natural England, Countryside Council for Wales, English Heritage, MMO (formally Marine and Fisheries Agency), CEFAS, Port Authorities, Crown Estates, the Royal Society for the Protection of Birds (RSPB) and Somerset Drainage Board.

4.5.66 The MALG met monthly until Stage 2 consultation, after which a couple of meetings took place. However, more detailed specialised meetings were taking place by this point. A number of marine-related issues were raised during these meetings, including discussion on flood risk and other assessments, design concerns and the temporary jetty, amongst others. MALG meetings concluded in November 2010.

4.5.67 The consultees commented on the sea wall design proposals in terms of flood risk, climate change assessments, impact on the foreshore and the most effective way to merge with the existing Hinkley Point stations’ sea wall; points that EDF Energy took into account when developing the sea wall design.

4.5.68 The sea wall was initially going to be part of the Site Preparation Works application, however, as a result of discussions held during the MALG, it was decided that it should form part of the main HPC application.

4.5.69 Discussions were held with regards to studies being undertaken to inform the Environmental Impact Assessment (EIA) such as thermal plume, marine archaeology, hydraulic and off-shore investigations.

4.5.70 Refurbishment of Combwich Wharf and impacts on the River Pill, including studies and consents required, were discussed.

4.5.71 Consultees requested that offshore geophysical studies were reviewed by a qualified marine archaeologist, and that additional scouring studies were carried out. A two-stage approach to building the temporary jetty was also developed during discussion at MALG meetings. The Temporary Jetty Application was submitted to the MMO in December 2010.

4.5.72 As part of its engagement with MALG, EDF Energy presented cooling water tunnel designs to the group, which raised concerns with regards to fish recovery. It was agreed that a Fish Recovery and Returns system would be required for HPC and




discussions on the subject continued between EDF Energy and the Environment Agency via a separate forum.

4.5.73 Drainage design concerns with regards to the developments’ impact on Wick Moor Drove and the foreshore were also raised and discussed at MALG. Initial drainage designs were developed based on the discussions around impact on the foreshore and a requirement to keep water levels consistent with existing levels that feed into Wick Moor Drove. A permanent culvert proposal was developed during MALG meetings but was developed further in specific EA and Drainage Board meetings.

e) Ministry of Defence

4.5.74 A meeting between EDF Energy and the Ministry of Defence (MoD) was held in November 2010 to discuss the communications protocol for vessels moving through the firing range. The meeting took place following Stage 1 and Stage 2 DCO consultation but prior to the submission of the jetty consent applications (Harbour Empowerment Order application, Transport and Works Act Order application and two marine licences). After the jetty applications were submitted, EDF Energy continued to engage with the MoD, providing updates on the status of the Project and responding to representations the MoD submitted.

4.5.75 EDF Energy’s engagement with the MoD took place through a variety of methods, including face-to-face meetings, telephone conversations and letters to update the MoD on the progress of the applications.

4.5.76 One of the key issues raised was that the proposed temporary jetty would be partly located within the MoD’s Lilstock Firing Range (D119), which is used for military training (including helicopter gunnery training). The MoD raised concerns that the presence of the temporary jetty could compromise use of the Lilstock Firing Range.

4.5.77 EDF Energy is working with the MoD to establish a workable solution which would allow dual use of the area for the temporary jetty and Lilstock Firing Range and is confident that this can be achieved. A management plan will be prepared which will set out the protocols for communication. This will include details of how and when EDF Energy would inform the MoD of activities taking place at the jetty, such as vessel movements, well in advance of those activities taking place. Likewise, the MoD would inform EDF Energy as to when it intends to use Lilstock Firing Range. It is anticipated that agreement of the management plan will be a condition of bringing the jetty into operation.

4.5.78 As an alternative option to the management plan, EDF Energy and the MoD have discussed the possibility of temporarily relocating the marking buoys elsewhere within the Firing Range, away from the harbour limits of the jetty. Both EDF Energy and the MoD consider that an appropriate management plan can be agreed and, therefore, it is likely that it will not be necessary to relocate the buoys.

4.5.79 The MoD also raised concerns that the jetty could be used for other amenities if it remains in place following construction. However, EDF Energy confirmed to the MoD that the sole use of the temporary jetty is to assist in the construction of HPC. When it is no longer required the jetty will be dismantled and removed and EDF Energy would seek to obtain all necessary consents for this.




4.5.80 EDF Energy and the MoD will maintain an ongoing dialogue throughout the operation, construction and decommissioning of the jetty and will work together to ensure that dual use of the site can be achieved.

f) Marine Management Organisation (MMO)

4.5.81 Consultation with the Marine and Fisheries Agency (MFA), the government body previously responsible for UK marine waters, began in 2009. The Marine Management Organisation (MMO) was formed in 2010 and replaced the MFA; consultation continued with the MMO and is currently ongoing.

4.5.82 EDF Energy consulted with the MFA/MMO throughout the pre-application process for the HPC Project on a number of topics, as discussed below.

i. Strategic HPC Meetings

4.5.83 The MMO was invited to various high-level Project presentations. These meetings were held at irregular intervals, providing a forum for key stakeholders and regulators to provide feedback on EDF Energy’s approach, programme and handling of information.

ii. Marine Authorities Liaison Group (MALG)/Habitats Regulations Assessment (HRA) Workshops

4.5.84 Initially, the MFA attended the Marine Authorities Liaison Group (MALG), which was a technical forum attended by representatives from regulators and advisory agencies. This was initially established to discuss development associated with the HPC proposals in the marine environment. These meetings were replaced by Habitats Regulations Assessment (HRA) workshops in December 2010 (further information on EDF Energy’s informal engagement regarding MALG and HRA can be found in this chapter) and the MMO continued to attend these meetings.

4.5.85 In total, eleven HRA workshops were held, as well as twelve fortnightly meetings, which either took the form of face-to-face discussions or teleconferences between December 2010 and June 2011. This culminated in the provision of a final draft HRA (initial drafts had also been circulated) to the regulators and MMO for review prior to submission in support of the Development Consent Order (DCO) application.

4.5.86 The MMO provided comments on technical aspects of initial drafts of the HRA to EDF Energy, which considered the feedback in preparing subsequent drafts of the HRA.

iii. Temporary Jetty Development

4.5.87 EDF Energy submitted applications for a Harbour Empowerment Order (HEO) and two Marine Licences to the MMO in December 2010, to construct a temporary jetty. EDF Energy consulted the MMO prior to submission of the applications and discussions continued as the applications have progressed. The applications will be considered at a public inquiry, which is scheduled to open in November 2011.

4.5.88 EDF Energy consulted the MMO following submission of the applications, to discuss various aspects of the proposals. These included the preparation of an addendum to the Environmental Statement (ES); responses to queries raised by stakeholders during statutory consultation; responses to queries raised by the MMO; arrangements for the inquiry and how the HEO relates to the DCO.




4.5.89 The draft HEO originally sought powers to close the harbour under Article 29, however, the MMO advised that legally it would not be possible to include such a provision. Following discussions with the MMO, and in the interest of progressing the application, powers to close the harbour are being sought by other means, for example by including a provision in the DCO application or by an Act of Parliament.

iv. Deemed Marine Licence Requirements

4.5.90 Prior to submission of the DCO application, discussions were held with the MMO regarding the deemed marine licences, including a face-to-face meeting and teleconferences. Areas of discussion included the drafting of the marine licences and the various potential conditions attached to each, and the ability to change licences following the submission of the DCO application.

4.5.91 Following further discussions and legal advice, it was understood that it would not be possible to include deemed marine licences which sought to dispose of dredged material at Cardiff Grounds within the DCO application as this area is in Welsh, not English, waters. It was decided that deemed marine licences will be separated from the DCO application and applied for separately to the Welsh Government and MMO.

g) National Grid

4.5.92 In order to connect the new HPC power station into the National Grid, high voltage electricity transmission network modifications to the overhead lines in the vicinity of the power station site will be required. These works will include the re-routing of existing overhead lines and the construction of a number of new transmission towers (pylons).

4.5.93 National Grid also requires a new 400kV connection of approximately 60km between Bridgwater and Seabank near Avonmouth. These works will comprise a Nationally Significant Infrastructure Project in their own right and will be subject to a separate DCO application by National Grid to the IPC.

4.5.94 In order to allow the HPC Project construction and commissioning schedule to be met, the National Grid works need to be completed. As a result it was viewed as imperative that regular planning interface meetings were held with appropriate representatives of National Grid to discuss progress towards key milestones and delivery of their programme.

4.5.95 From February 2009, working level monthly planning/technical interface meetings have been held between EDF Energy and National Grid. All resulting actions were followed through and reported at subsequent meetings. In addition, ad-hoc senior management meetings have been held during this period between the two organisations, where discussions of a more strategic nature have taken place.

4.5.96 The initial discussions at the planning/technical interface meetings centred on the timing of the DCO applications by EDF Energy and National Grid. The timing of the applications was discussed and it was agreed between the two companies that it was not imperative for the two applications to be made at the same time as the lead-in and construction times are very different.

4.5.97 EDF Energy and National Grid exchanged details of their respective consultants and project documents when they became available, particularly where there was an




overlap in the survey area. Furthermore, in the various consultations that both companies have undertaken since 2009, the documentation has been checked for accuracy and signed off by the non-consulting party.

4.5.98 The interface meetings also discussed matters of a more technical nature, including where the new 400kV substation should be located in the vicinity of the proposed HPC site.

4.5.99 The technical information required for inclusion in the EDF Energy and National Grid DCO applications was discussed and agreed at a high level. The specifics of the platform level were provided to National Grid to allow them to work up the design and the orientation of the substation, which was agreed between the parties.

4.5.100 Initially it was agreed that the EDF Energy DCO application would include National Grid’s 400kV substation, three end (terminal) towers and connecting wires (downleads) from the terminal towers into the substation. This proposal was consulted on at both the Stage 1 and Stage 2 consultations. However, it was later decided and agreed between the parties that to ensure that EDF Energy’s consultation and subsequent DCO application does not pre-judge National Grid’s own DCO consultation, EDF Energy’s proposals would only include the 400kV substation. This change was consulted on at the Stage 2 Update.

4.5.101 Since the beginning of 2010 a number of joint meetings have been held between EDF Energy and National Grid with statutory consultees, including Natural England (NE) and English Heritage (EH).

4.5.102 Regular meetings have also taken place since early 2010 between National Grid and EDF Energy’s Landscape and Visual Impact consultants with respect to the cumulative impact assessment that would need to be included in the various consultations and ultimately in the final DCO submission. In addition, National Grid has provided EDF Energy with models of the tower types that it is proposing to erect, to allow them to be modelled correctly and visually represented in the cumulative photomontages for the DCO submission.

4.5.103 National Grid regularly updated each interface meeting on the progress it was making on its consultation programme on the Route Corridor Study. EDF Energy provided similar updates on its schedule for public consultation and the target DCO submission date. Joint public exhibitions were held in December 2009 and subsequently in July 2010.

4.5.104 Discussions have been held in order to progress the necessary land documentation that will need to be put in place between the two companies. At the point of the DCO submission this has not been concluded, however, there are no perceived issues that would prevent this coming to a successful conclusion.

4.5.105 National Grid is still in the process of developing and consulting on its proposals for the overhead line entries in the vicinity of HPC and therefore it has been agreed between National Grid and EDF Energy that, for the purposes of the cumulative impact assessment, two potential route options should be considered. This proposal was discussed and agreed at a meeting with representatives of, English Heritage, Natural England, Quantock Hills AONB service and Somerset County Council.




4.5.106 The monthly interface meetings between the two companies will continue, in order for EDF Energy to keep National Grid up to date on the progress of its DCO application and construction and commissioning schedule.

h) Natural England

i. Biodiversity

4.5.107 EDF Energy has undertaken extensive formal and informal engagement with Natural England during the consultation process for HPC. Engagement on issues relating to biodiversity began with Natural England (NE) in June 2009.

4.5.108 Informal engagement with NE on the current site and emerging HPC proposals began in 2009, although earlier engagement had taken place with British Energy. EDF Energy will continue to consult NE throughout the construction and operational phases of the development, should the application receive consent. EDF Energy intends to invite NE to be part of the Hinkley Point Land Management Working Group during the construction site restoration and post-construction management.

4.5.109 Informal engagement on matters relating specifically to biodiversity has taken place at key Project milestones. A total of 20 meetings with NE have taken place, with the key periods being prior to the start, and after the completion, of the ecology surveys. Further meetings took place during the design process to discuss potential mitigation measures to minimise potential adverse impacts.

4.5.110 Other key periods for meetings took place at various times during the consultation period and focused on specific topics such as badger licensing, bats (barbastelle in particular) and site restoration.

4.5.111 Natural England’s primary concerns about the potential impact on biodiversity focused on the loss of habitat during construction and the importance of considering designated sites. On the latter point, NE highlighted the maintenance of water supply to Bridgwater Bay Site of Special Scientific Interest (SSSI) and the possible chemical and thermal impacts on birds that are part of the Special Protection Area (SPA)/Ramsar site/SSSI designations.

4.5.112 The requirement for obtaining protected species mitigation licences to allow the development to proceed was highlighted, particularly in relation to badgers (HPC Development Site), bats (HPC Development Site) and great crested newts (Cannington bypass and Junction 23) and the mitigation measures that may be required to support these (e.g. a new ‘bat barn’).

4.5.113 In response, EDF Energy has reduced the construction area footprint on the HPC Development Site in the southern area. This area would be re-profiled at the beginning of the construction phase and permanently planted with a woodland and grassland mosaic, which reflects the final restoration plan. The remainder of the site has also been reviewed in relation to minimising short-term habitat loss through temporary habitat creation on landscape screening bunds (e.g. along the north west boundary) and on embankments and soil storage mounds. As originally discussed, Benhole Lane, Bum Brook and the majority of the Green Lane, are retained and protected during construction. In addition, an area of approximately 25ha of arable/improved grassland would be seeded with a wildflower grassland mix prior to the start of construction.




4.5.114 As described in Chapter 16 and 20 of Volume 2 of the Environmental Statement, the design of the development will ensure that water input into the SSSI is kept consistent with the current baseline through the implementation of Water Management Zones Licences have been granted by NE in relation to badgers and bats on the HPC Development Site.

4.5.115 EDF Energy is also in the process of agreeing the main principles of mitigation within draft licence applications in relation to great crested newts at the Cannington bypass and Junction 23 associated development sites.

ii. Engagement on Landscape and Visual Impact Assessment (LVIA)

4.5.116 Informal consultation with Natural England on landscape and visual impact began in January 2009, with the aim of establishing a landscape and visual baseline, confirming the landscape and visual impact assessment methodology and discussing the potential impacts and their mitigation.

4.5.117 Natural England has contributed to every stage of formal consultation since January 2009. Several consultation meetings in 2010 and 2011 were held to discuss landscape design of the proposed scheme and landscape and visual mitigation measures. Consultation with Natural England concluded in 2011.

4.5.118 The majority of informal consultation with Natural England was undertaken by email and supplemented by phone calls to clarify the material sent electronically. From early 2010 meetings were also organised at irregular intervals to discuss landscape design of the proposed scheme and landscape and visual mitigation measures.

4.5.119 A site visit with Natural England was carried out in April 2010 when representatives of Natural England advised on the location of additional Areas of Outstanding Natural Beauty (AONB) and other viewpoints along the coastline.

4.5.120 Further meetings were held and correspondence exchanged in the following year, however, regular meetings were not required due to the Stage 2 consultation which took place within this period. The majority of feedback from Natural England was provided as part of the formal consultation process.

4.5.121 A key meeting related to LVIA issues was held in April 2011, when agreement was reached on the following key issues:

selection and presentation of representative viewpoints including final location of viewpoints to be included in the assessment;

presentation of montages (Visually Verifiable Images - VVIs) of the development in the Environmental Statement and scaling of images according to the new advice note published in March 2011 (Landscape Institute Advice Note 01/11 (2011) Photography and photomontage in landscape and visual impact assessment Landscape Institute: London);

VVI methodology;

illustration of cumulative impacts with National Grid proposals; and

presentation of night time views and selection of views to be retaken at dusk for the production of VVIs including lighting proposals.




4.5.122 Several meetings relating to issues of landscape and ecology were held with Natural England between March 2010 and August 2011, when agreement was reached on the following key issues:

the extent and balance of valuable habitats proposed within the restoration proposals;

the pattern of hedgerows and shape of woodlands proposed to follow 17-18th century planned landscape including size of fields;

reduction in the amount and location of areas of scrub;

modification to the bund and woodland planting adjacent to the north-west boundary of the permanent development site to maximise screening benefit; and

mitigation proposals during construction.

4.5.123 While the majority of issues relating to the application for development consent have now been discussed and resolved, EDF Energy will continue to engage with Natural England on an informal basis on LVIA issues throughout the construction of HPC and into the landscape restoration phase, should consent be granted.

i) Royal Mail Group

4.5.124 EDF Energy Bridgwater staff and the Company’s transport consultants have been engaging with the Royal Mail Group and its consultants since October 2010 with regards to the HPC Project. Consultation has been via meetings, telephone conversations, emails and formal correspondence and is ongoing as of September 2011.

4.5.125 The Royal Mail Group wanted to understand what impact any additional traffic movements generated by the construction of Hinkley Point C (HPC) would have on its daily delivery and collection of mail.

4.5.126 The Royal Mail Group’s representation to the Stage 2 consultation, dated 4 October 2010, pointed out that until such time as it can be shown by EDF Energy that Royal Mail operations in the area will not be adversely affected or the impact of the development can be fully mitigated, then Royal Mail will maintain an objection to the proposed development.

4.5.127 EDF Energy has written to the Royal Mail Group to provide updates on the modelling work that will inform the impact of the construction proposals on the local highway network. EDF Energy has also described the potential highway mitigation measures that will be proposed as part of the DCO application. These are focussed principally on Bridgwater and the intention is that the improvements will ensure that the local road network will not be worse off as a result of the HPC traffic.

4.5.128 EDF Energy has confirmed to the Royal Mail Group that these highway schemes will remain in place after the HPC construction phase is completed, providing Bridgwater with longer-term improvements.




j) SCC Historic Environment Services

4.5.129 EDF Energy engaged with the SCC Historic Environment Service (SCC HES), to identify significant heritage assets associated with Hinkley Point C and associated development sites. The engagement started in July 2008 and has continued throughout the pre-application process.

4.5.130 SCC HES provides information and advice on the historic environment of Somerset, including archaeology, built heritage and historic landscapes. EDF Energy will continue to engage with SCC HES throughout the process. This will include on-site archaeological investigation in advance of Site Preparation Works, construction and the subsequent post-excavation assessment, analysis and publication of the results of the archaeological investigation.

4.5.131 Rather than having meetings at set intervals, EDF Energy and SCC HES held meetings when required, with the frequency depending on the Project requirements at the time. Weekly monitoring meetings were held also on site to review the results of the field evaluations (geophysical survey and trial trenching) across the HPC Development Site and associated developments during 2009 and 2010.

4.5.132 A variety of topics were discussed at these meetings, including assessment requirements, results of completed surveys and proposals for mitigation. SCC HES provided significant input into the investigative work strategy carried out by EDF Energy across the development site and associated development sites, and the comments received were taken account of wherever possible.

4.5.133 Through the meetings with SCC HES, locations for the geophysical surveys were discussed and agreed. EDF Energy carried out surveys for the HPC Development Site, Cannington park and ride, Cannington bypass, Combwich and Junction 24, and provided results reports to SCC HES upon completion. Similarly, the areas where surveys were not deemed necessary were also agreed.

4.5.134 As a result of the geophysical surveys, trial trenching was considered necessary to investigate features identified by the surveys. In all cases, trench plans were discussed with SCC HES and modified where appropriate to incorporate the comments received.

4.5.135 Where buried archaeology was identified in the assessment phase (at the HPC Development Site, J24 and Cannington bypass) it was agreed with SCC HES that suitable mitigation would comprise Preservation by Record. This would entail a programme of archaeological excavation, recording and post-excavation analysis, with results published in academic journals.

4.5.136 During the field work, weekly monitoring meetings took place on-site with SCC HES and trial trenching reports provided, detailing the findings (December 2009 – January 2011).

4.5.137 SCC HES has requested that the objectives of the excavation and recording reflect relevant research aims included in the South West Archaeological Research Framework (SWARF). These objectives are described in the Written Scheme of Investigation (WSI) for archaeological recording, submitted to SCC HES. Following completion of on-site investigation and recording, the objectives will be reviewed as




part of the post-excavation assessment. An updated Project design will outline proposals for analysis and publication of the results, to be agreed with SCC HES.

4.5.138 EDF Energy hosted site visits, to allow SCC HES to see and discuss topics relating specifically to the development site. At the initial site walk-over a number of issues were discussed, including the need for historic building surveys for derelict barns and the identification of historically important hedgerows on site. It was agreed that suitable mitigation for both would be Preservation by Record.

4.5.139 The east-west trackway, Green Lane, was also identified as a potentially significant historic landscape feature as a result of the site walk-overs. SCC HES requested that this should be retained and not removed as part of the development. As a result, EDF Energy modified the plot plan for the development site to retain as much of the trackway was possible. This is now a key feature of the scheme in terms of landscaping and ecology, as well as historic environment.

4.5.140 Site Preparation Works were considered by WSC in July 2011. The Council resolved to grant planning permission subject to resolving conditions and entering into legal agreement. Work on-site is likely to commence in October 2011. This will include set-piece excavation of five of the seven archaeological areas on the HPC Development Site, recording of the historic buildings as they are demolished and recording of the sections of Green Lane and historic hedgerows that are to be lost. SCC HES will be kept fully informed during the course of these works.

4.5.141 Once the works are complete, the results will be reported to SCC HES and a strategy for public distribution of the information agreed. This will be by EDF Energy (through academic publication) and by SCC HES (through public outreach paid for by s106 contributions).

k) SCC Rights of Way Team

4.5.142 EDF Energy has engaged with the SCC Rights of Way Team (SCC ROW) since July 2008 and will continue to do so throughout the construction phase and into the operation phase of HPC, should consent be granted.

4.5.143 SCC ROW serves to protect and record the Public Rights of Way PRoW) in Somerset and has worked closely with EDF Energy in identifying the extent, status, and importance of the PRoW network. This collaboration has been particularly focused on areas in and adjacent to the HPC sites, including that of the range of PRoW users (dog walkers, equestrians, anglers).

4.5.144 Rather than having meetings at set intervals, EDF Energy and SCC ROW held meetings when required. Meetings typically took place at County Hall and were occasionally attended by other interested parties, local parish councils or ramblers associations. Several meetings were held on-site with the area Rights of Way Officer to discuss specific issues or to confirm specific actions where required.

4.5.145 The meetings held between EDF Energy and SCC ROW covered a number of topics, including works on-site and the impact on PRoW requirements for closure and diversion of paths, assessment requirements and mitigation.




4.5.146 In addition to the meetings, a number of HPC site visits took place, attended by local residents and the Stogursey Parish Council Rights of Way representative to discuss EDF Energy’s proposals and offer feedback.

4.5.147 The need to close on-site footpaths for the duration of the construction period for health and safety reasons was raised at the start of the consultation process. As EDF Energy would be using the entire site throughout the build period, with extensive north-to-south vehicle movements, retention of any on-site footpaths, this was discounted as an option. The SCC ROW team stipulated that a diversion around the outside of the works would be required to retain east-west and north-south access. Some of the key discussions in terms of the diversion route are set out below.

i. Link between Hinkley Point A and Hinkley Point C Site

4.5.148 Originally it was agreed that the diversion would run between the Hinkley Point A and Hinkley Point C sites, but this later proved unworkable for health and safety and security reasons. It was therefore agreed that the diversion would start from the east of Hinkley Point B and run to the south of the existing Hinkley Point Power Station Complex, before linking into the HPC site to the north of the Common Land and west of Wick Moor Drove.

4.5.149 The stretch of coastal path that runs in front of the existing Hinkley Point B and A stations will remain open but this will result in a dead end (though with access remaining present onto the foreshore) while the Coastal Path in front of HPC site is closed.

ii. West Somerset Coast Path

4.5.150 At Stage 2 consultation EDF Energy, in discussion with SCC ROW, assessed the Coast Path (part of the West Somerset Coast Path) as regionally important. However, SCC ROW advised that it should be afforded nationally important status as it will ultimately become part of the England Coast Path. SCC ROW alerted EDF Energy to the fact that Somerset has been chosen as one of the pilot counties for implementation of the Marine and Coastal Access Act provisions, and advised that EDF Energy should also liaise with Natural England on this point. In light of the above, the requirement to keep the Coast Path open for as much of the build period as possible was noted. It was accepted by SCC ROW that a period of closure (estimated as three years) would be required during construction of the temporary jetty and seawall.

iii. Open Access Land

4.5.151 It was discussed at the joint meeting with the Stogursey Parish Council rights of way representative that a circular route around the HPC Development Site should be provided. It was not possible to action this request (see above regarding link between Hinkley Point A and Hinkley Point C), but it was agreed that EDF Energy would allow permissive access to the southern area to allow local residents to go on short circular walks if desired. It was noted that access may be restricted to certain areas at certain times, due to archaeological excavations, screen planting, construction of the emergency access road but a designated diversion route would always remain open.




iv. Benhole Lane

4.5.152 The southern end of Benhole Lane floods frequently and as a result, the public right of way is diverted into a resident’s field at one point. The resident had raised concerns about this and asked that the route be diverted back out of their land. EDF Energy engineers were unable to identify measures to avoid this. Wider consultation with the community revealed a split in opinion (Stogursey Parish Council’s Stage 2 response acknowledges this division in local opinion). Furthermore the owner of Benhole Lane could not be identified by EDF Energy or SCC ROW. Therefore it was agreed that EDF Energy would provide an alternative access from Shurton into the site to the east of Benhole Lane and that this would link into the east-west diversion which runs into Benhole Lane above the area prone to flooding.

v. Other General Requirements

4.5.153 EDF Energy ensured that all path specifications and requirements were discussed and agreed with SCC ROW, incorporating any feedback where appropriate.

4.5.154 Post construction, the HPC Development Site will be restored as set out in the Landscape Restoration Plan and the SCC ROW team’s aspirations for this were discussed. These comprised a rationalisation of existing routes to provide a clearer north-south/east-west grid and the addition of new bridleways in recognition of the limited bridleway provision within Stogursey Parish. Cyclists may also use bridleways, providing more leisure opportunities.

4.5.155 EDF Energy had originally proposed only the on-site diversion route, followed by on-site restoration proposals, in terms of mitigation for public rights of way. A series of wider enhancements, to be funded by EDF Energy but implemented by SCC ROW (with support from EDF Energy), were agreed as part of the Site Preparation Works s106 agreement and is likely to be supplemented by some additional enhancements in the DCO s106 for the main site and associated development sites (particularly those which affect the River Parrett Trail).

4.5.156 EDF Energy’s engagement with SCC ROW will continue as the mitigation measures are implemented and into the operational phase of HPC in relation to public rights of way maintenance should permission be granted. SCC ROW will monitor the public rights of way diversions and EDF Energy’s implementation of the off-site enhancement proposals.

l) South West Regional Development Agency

4.5.157 Engagement with the South West Regional Development Agency (SWRDA) began in May 2010 and has been ongoing throughout the period leading up to the submission of the DCO application.

4.5.158 Three meetings took place between EDF Energy and SWRDA in 2010 to understand SWRDA’s strategic role and identify ways in which EDF Energy could work with them. SWRDA was positive about the employment and skills plans set out in the Stage 2 consultation documentation and were keen to ensure that skills activity maximised the use of the existing infrastructure. It was particularly supportive of the apprenticeship strategy, now detailed in the Construction Workforce Development Strategy.




4.5.159 Engagement with SWRDA in 2011 has focused on the development of a cluster of nuclear related businesses, service functions, educational institutions and public bodies to support the nuclear industry in Somerset and nationally. A partnership approach was adopted to define the scope of the nuclear cluster, outlining activities and establishing a business model. Discussions are ongoing to finalise the model and business plans part of the work that EDF Energy is doing in collaboration with the authorities to support the development of a low-carbon delivery strategy.

4.5.160 In February 2011 a low-carbon delivery team (LCDT) was established as a direct response to a number of joint visions that were agreed between the Somerset local authorities and EDF Energy, which included the concept of the nuclear cluster. The LCDT’s role is to establish a strategic framework to support the rebalancing of the Somerset economy and the transition to a low-carbon economy.

4.5.161 LCDT meetings were held on a monthly basis, which SWRDA attended. Further ad-hoc meetings were held with SWRDA in relation to the development of the nuclear business cluster element of the LCDT activity.

4.5.162 EDF Energy has worked collaboratively with SWRDA and other key stakeholders to develop the strategic framework for a low-carbon economy, to maximise the catalytic impact of HPC on the wider economy. The approach is linked to activity undertaken through the Construction Workforce Development and Procurement teams. Equally, discussions about a nuclear business cluster have been based on a joint goal between EDF Energy and Somerset local authorities of creating a positive economic impact in Somerset as a result of the HPC Project.

4.5.163 However, the overall engagement with SWRDA has been limited by the Government’s decision in 2010 to abolish the Regional Development Agencies. The governance of the low-carbon delivery team remains unresolved in the light of changes to regional government, although it is anticipated that the role of the recently established Heart of the South West Local Enterprise Partnership (LEP) will develop over time.

m) Supplementary Engagement which Invited Comment – Red-line Boundary Changes – M5 Junction 23 and Combwich

4.5.164 Following the formal stages of consultation, there was a requirement to make minor changes to two development (red-line) boundaries – one near M25 Junction 23, the other at Combwich Wharf. EDF Energy therefore undertook a very limited and targeted supplementary informal engagement which invited comment. Separate letters, with a map showing the proposed red-line change, were issued to statutory consultees on 2 September 2011 inviting them to respond by email or freepost by 19 September 2011.

4.5.165 A red-line boundary was extended along the southern boundary of the Junction 23 associated development site to include an area required to improve the River Parrett flood defence.

4.5.166 At Combwich, the red-line boundary was extended slightly around the two locations on the Combwich Wharf access road where EDF Energy is proposing to create otter culverts. It has also been extended to include all the works proposed at Combwich Wharf including dolphins (a mooring point in the river) and other structures required for the navigation of vessels.




4.5.167 The red-line was also reduced:

along the northern-most boundary of the site at the Wharf in the Combwich Pill area;

on the south-eastern most boundary of the site so that this now aligns with the centre-point of the existing ditch in this location;

to exclude land comprising the River Parrett Trail Public Right of Way (PRoW) along part of the north-eastern boundary of the site where it adjoins the River Parrett;

to exclude land comprising the layby off the C182 at the junction with Combwich Wharf access road; and

to allow for 10m around Tuckett’s Clyce.

4.5.168 This land was excluded from the red-line as EDF Energy no longer requires these areas to accommodate its proposals.

4.5.169 Otterhampton Parish Council responded to the Combwich consultation stating that its initial appraisal did not raise any concerns on the boundary reductions and that it welcomed the creation of otter culverts, but they reserved judgment on the impact on Combwich Pill, where there were potential concerns.




4.6 Emergency Services and Local Authorities Group

4.6.1 Discussions with Avon and Somerset Constabulary, Devon and Somerset Fire and Rescue Service, the South Western Ambulance Service Trust and Her Majesty’s Coastguard, together with Sedgemoor District, Somerset County and West Somerset Councils, began in September 2010 with the establishment of the Emergency Services and Local Authorities Group (ES and LA Group). Sedgemoor District Council also represented the interests of the Harbourmaster.

4.6.2 The group was set up as a result of the formal consultation process and provides an interface between EDF Energy and public service providers with responsibility for community safety, incident planning and emergency response.

4.6.3 The ES and LA Group also takes guidance from district and county community safety officers and the Somerset Local Authorities Civil Contingencies Unit (SLACCU). Its focus centres on incidents both on and off the HPC site, on the strategic road network and on community safety issues.

4.6.4 The group’s first task has been to devise a mechanism to inform mitigation methods for the potential impacts of the construction of HPC and its associated developments on public services and the safety of local people, whether real or perceived. All the issues were collated and analysed to produce two overarching documents written by EDF Energy in consultation with public service providers.

4.6.5 The Outline Contingency Response Arrangements (OCRA) document addresses any potential incident scenarios during the construction phase of the HPC Project, identifies the mitigation measures required to deal with these incidents. The OCRA was also informed by existing plans at Hinkley Point A or B station. Security contingency arrangements, the Traffic Incident Management Plan and construction phase Health and Safety Plans have also been taken into account.

4.6.6 The second overarching document, written by EDF Energy in collaboration with members of the ES and LA Group, was the Community Safety Management Plan (CSMP) (Annex b of the Environmental Statement). The document outlines the current approach to community safety in Somerset and considers the potential impact that the building of HPC may have. It sets a strategy for mitigating any negative impacts through monitoring and management.

4.6.7 The OCRA and CSMP have consequently informed Strategic Relationship Protocols (SRPs) with each emergency service provider and local authority. Although SRPs are not legally binding documents they confirm how parties will co-operate to achieve stated objectives, and apply to preliminary and main construction. From the outline arrangements contained within the SRPs, detailed undertakings were agreed and are set out within the Section 106 agreement for Site Preparation Works and within the Requirements and Obligations attached to the DCO application.

4.6.8 EDF Energy has engaged with the emergency service providers listed below, in bi-lateral meetings, specialist workshops and as part of the ES and LA Group. Regular monthly meetings of the ES and LA Group informed the establishment of strategic emergency response processes, risk analysis and the mitigation proposals now contained within both the OCRA and CSMP documents. Some of the key issues raised by each provider through informal consultation are summarised below.




a) Avon and Somerset Constabulary (ASC)

4.6.9 EDF Energy has engaged with the Avon and Somerset Constabulary (ASC) in regular meetings, specialist workshops and as part of the ES and LA Group. These working relationships resulted in strategic emergency response processes, risk analysis and mitigation proposals, which are now contained within both the OCRA and CSMP documents. Furthermore, engagement with ASC occurred on at least a weekly basis since their issues and concerns were of a greater challenge and have a wider cross-county impact.

4.6.10 In addition to requirements for regular liaison and information exchange, ‘routine policing’ matters were discussed, such as the procedures for handling incidents involving the workforce and the local community, enforcing highway regulations along key travel routes, and dealing with minor protests on-site or at an associated development site. The major elements of these discussions, informed by the OCRA and CSMP, were agreed as follows and assisted in formulating the EDF Energy and ASC SRP agreement.

4.6.11 The SRP established that additional police officers would be funded by EDF Energy in proportion to the rise and fall in the size of the workforce based on a sophisticated algorithm, developed with ASC, that relates the likely number of incidents associated with an increase in population to the police resources required to handle such an increased workload.

4.6.12 A series of key principles were established within the SRP that will govern the various roles and responsibilities of the parties engaged in handling serious public order incidents. These were also reflected in identical agreements with the existing Hinkley Point B and the Magnox-operated Hinkley Point A stations.

4.6.13 Following consultation with both ASC and all other emergency service providers, and informed by the OCRA and CSMP, EDF Energy also undertook to fund a set number of awareness and education campaigns in support of wider community safety strategies.

4.6.14 Consultation with ASC revealed two larger, nationally significant issues that required resolution. The first of these related to the provision of radio coverage at the HPC site and neighbouring vicinity, which at present is limited. Whether this requirement can be accommodated within the site communications plan is currently being investigated. The second related to the costs for the handling of a major protest event as a result of the HPC development. This issue proved particularly difficult to resolve, not least because of the precedent which it set for police forces and future major developments across the country. Mitigation measures to address the risk of protestor activity are considered within the OCRA with reference made to the role of ASC and EDF Energy’s own site security arrangements. Home Office advice has been sought on how costs for policing any such protests should be covered.

4.6.15 Following these discussions with ASC, the agreed resourcing and associated remuneration commitments provided by EDF Energy are shown in detail within both the Section 106 agreement for Site Preparation Works and the Requirements and Obligations section of the DCO application.




b) Devon and Somerset Fire and Rescue Service (DSFRS)

4.6.16 The requirements of Devon and Somerset Fire and Rescue Service (DSFRS) mirrored the other emergency services in terms of routine information sharing and strategic planning. Furthermore it provided greater detail on how DSFRS would assist during any potential HPC-related incidents, either on-site or at associated development sites, such as the accommodation campuses.

4.6.17 The OCRA established the necessary principles of incident management process with DSFRS and concluded that the potential for significant calls to site could be mitigated adequately by the provision of a specialist vehicle to deal with the most common minor incidents. It was also established that the contractor appointed to lead in each specific area should be responsible for providing the equipment and trained personnel, to respond to incidents that might arise in its work area.

4.6.18 A specific concern was raised by DSFRS about the ability of emergency service vehicles to access an incident resulting from blockages of the strategic road network surrounding the HPC Development Site. Possible mitigation measures for these concerns were assessed by the Traffic Incident Management Plan in consultation with the emergency services and local authorities. Analysis and potential mitigation provision was again informed by accident statistics from both the construction of Sizewell B power station and the London 2012 Olympic Park construction.

4.6.19 The Community Safety Management Plan (CSMP) established the requirement to initiate a regime of fire safety visits by qualified DSFRS inspectors of private rented accommodation, and a rolling programme of awareness campaigns on such subjects as the fire risks of multiple occupancy accommodation.

4.6.20 The OCRA and CSMP assisted in informing the formulation of the EDF Energy and DSFRS SRP which confirms how both parties will co-operate to achieve stated objectives for both preliminary works and main construction.

4.6.21 The agreed resourcing and associated remuneration commitments provided by EDF Energy following consultation with DSFRS are shown in detail within both the Section 106 agreement for Site Preparation Works and the Requirements and Obligations section of the DCO application.

c) Her Majesty’s Coastguard (HMCG)

4.6.22 Key issues for HMCG centred on the requirement to establish effective liaison and systems for passage of emergency information. These have been covered within the relevant EDF Energy and HMCG Strategic Relationship Protocol (SRP) (overview available as an appendix to the CSMP (Annex b of the Environmental Statement)). This details regular liaison, site visits and communication arrangements, as well as outlining procedures to be adopted in the event of a maritime incident. Any resourcing and commitments provided by EDF Energy, is shown within both the Section 106 agreement for Site Preparation Works and the Requirements and Obligations section of the DCO application.

d) South Western Ambulance Service Trust (SWAST)

4.6.23 In addition to liaison and information sharing, engagement with SWAST has devised a mechanism by which information on Project progress and site arrangements could




be shared. The EDF Energy and SWAST SRP covered the outline routine and emergency procedures. Using comparable data from the construction of Sizewell B power station and London 2012 Olympic facilities, the likely number of call outs during the HPC construction period was identified.

4.6.24 Any necessary resourcing and associated remuneration commitments provided by EDF Energy following consultation with SWAST is shown within both the Section 106 agreement for Site Preparation Works and the Requirements and Obligations section of the DCO application.

4.6.25 Separate to the ES and LA Group, EDF Energy engaged SWAST on Health Impact Assessment (HIA) issues from early 2011. It also continued to do so alongside consultation with the Somerset Primary Care Trust. Further information on EDF Energy’s informal engagement on HIA issues can be found in this chapter.

e) Local Authorities

4.6.26 Consultation with local authorities also included dialogue with the Somerset Local Authorities Civil Contingencies Unit and Local Resilience Forum to inform detailed aspects of emergency planning and wider impacts in the event of a major incident, such as an off-site incident at Hinkley Point A or B station. Through this engagement EDF Energy assisted the Local Resilience Forum in updating the Community Risk Register to take account of the HPC development.

4.6.27 The specific concerns of the local authorities centred on the issues of community safety, including community tensions and the maintenance of community cohesion following the influx of non-home-based workers. The risks, concerns and associated potential mitigations were outlined in both the OCRA and CSMP, which assessed impacts on the role of current Community Safety Officers and the role of the EDF Energy Community Liaison Officer proposed by the local authorities.

4.6.28 The CSMP outlines the working protocols involved in community safety and a range of mitigation measures have been developed with the public service providers. These include a Worker Code of Conduct, initiatives and awareness campaigns, a welcome pack to promote community cohesion, a construction hotline to raise grievances and subscription to a telephone based translation service to reduce difficulties associated with the families of non-English speaking workers. The agreed resourcing and associated remuneration commitments provided by EDF Energy are shown in detail within both the Section 106 agreement for Site Preparation Works and the Requirements and Obligations section of the DCO application.




4.7 Health Impact Assessment and Associated Engagement

a) Health Impact Assessment

4.7.1 In keeping with best practice, EDF Energy has commissioned a Health Impact Assessment (HIA) to further investigate and address local community health concerns, and to support the development of mitigation and community support initiatives.

4.7.2 In line with IPC guidance, the scope and focus of the assessment was primarily defined with key health stakeholders at Somerset Primary Care Trust (PCT). However, in order to further investigate strategic health issues and needs, informal consultation with the South West Strategic Health Authority (SWSHA) and the South West Public Health Observatory (SWPHO) also took place.

4.7.3 Informal consultation provided a means to supplement the HIA with independent epidemiological studies conducted to address perceived risks of cancer prevalence in the region. It also enabled the refinement of the scope of the HIA to address concerns of road safety and supported the development of a health action plan to support strategic health initiatives.

4.7.4 The SWPHO’s key health concerns reflect those of the PCT and have therefore been addressed through the final HIA and health action plan. During consultation, the SWPHO indicated that its key concern was the potential increase in construction vehicles on local roads and the subsequent risk of collision.

4.7.5 EDF Energy also discussed radiological issues, to which SWPHO provided crucial insight into previous and ongoing local radiological studies, which demonstrate no increase in cancer prevalence in proximity to Hinkley Point, and also investigated and addressed the perceived risk of breast cancer prevalence in Burnham-on-Sea.

4.7.6 SWPHO’s involvement in the scoping exercise helped to refine the approach, scope and focus of the HIA. The SWPHO will continue to be a key partner in the independent monitoring of local health.

4.7.7 The South West Strategic Health Authority (SWSHA) was not included within the initial HIA scoping stage, as it typically provides a more regional coverage. However, the SWSHA was engaged during Stage 2 consultation, providing positive responses on the comprehensive scope and focus of the HIA, the use of Public Health Observatory studies and the key objective of addressing local concerns.

4.7.8 The SWSHA focused on key health pathways (reiterating the PCT’s key points) and the need to further address perceived risks and share transferable knowledge. The SWSHA responses mirror and reinforce those of the PCT and are therefore addressed within both the final HIA and the dedicated health action plan.

4.7.9 Consultation on the HIA also took place with the South West Ambulance Service (SWAS) from early 2011. The engagement centred on informing the health care and service provision of EDF Energy’s appointed health care provider. Prior to this, EDF Energy had engaged the PCT, which also represents the interests of the SWAS.

4.7.10 The main issues raised by SWAS during this informal engagement included the potential impact of the construction workforce on local emergency response capacity,




coverage and response time during both site preparation works and the main construction phase.

4.7.11 In response to these concerns, EDF Energy issued both a briefing note and health technical note outlining the approach to on-site ambulance provision, the management of potential risk and mitigation of residual impacts with the PCT Ambulance Commissioner. To fully address its concerns, the SWAS has been included within the Health and Task Finish Group (HTFG) alongside the PCT and has taken an active roll in the development of appropriate mitigation measures.

b) Health and Task Finish Group (HTFG)

4.7.12 Informal consultation between EDF Energy, the local authorities and Somerset Primary Care Trust (PCT) started in 2010 to discuss health matters related to the HPC Project. Following a number of meetings and at the request of the PCT, the Health Task and Finish Group (HTFG) was established in late 2010.

4.7.13 The group, chaired by EDF Energy, was formed to further assist the delivery and development of the HIA and a health action plan. The membership included representatives from the Bridgwater GP Federation, Sedgemoor District Council, Somerset County Council, Somerset Primary Care Trust and West Somerset Council.

4.7.14 Importantly, given the restructuring of the UK public health system, the group constituted a change management function. The body was set up in preparation for the abolition of the PCT by 2013 and in order to define responsibility for the implementation and delivery of a health action plan, should development consent be granted.

4.7.15 A health action plan has been developed to expand upon the standard recommendations section within HIA guidance (see Chapter 7 of the HIA document for more information). It establishes recommended protocols and monitoring regimes that will be implemented to reduce and remove potential adverse health outcomes and disruption, whilst maximising opportunities to increase the uptake of local health benefits. The HIA also identifies specific information that should be supplied to local communities in order to address and alleviate specific health concerns and perceived risks.

4.7.16 On this basis, the HTFG played an active part in the development and refinement of additional mitigation to address local community concerns, but also in the development of community support initiatives to improve local health and wellbeing.

c) Somerset Primary Care Trust

4.7.17 In keeping with IPC guidance, an optional Health Impact Assessment (HIA) was commissioned and the remit discussed and refined with key health stakeholders, including Somerset PCT in March 2010.

4.7.18 The PCT represents the local public health stakeholder and is responsible for health protection, promotion and care throughout Somerset. On this basis, the PCT has been an active partner during the entire HIA process and has proved essential in sourcing local health and hospital admission statistics, in sharing tacit knowledge on local circumstance and relative sensitivity, and has played a key role in the




development of appropriate mitigation and support initiatives through the health action plan (see the HIA for further information).

4.7.19 EDF Energy met with the PCT approximately every two months through the Health Task and Finish Group, supplemented with meetings on an ad-hoc basis when necessary and general correspondence to support the development of the HIA and a health action plan.

4.7.20 The key issues raised by the PCT during this engagement focused on the need for adequate assessment of health impacts and health care capacity in the county, as well as the potential impacts of the HPC Project on the physical and mental health of communities within close proximity of the HPC Development Site for prolonged periods.

4.7.21 The PCT was also concerned about non-home-based construction workers’ families coming to the area and on local health care capacity and requested a planning contribution be considered, should consent be granted.

4.7.22 EDF Energy has also carried out a number of additional assessments and investigative work at the request of the PCT, such as investigating the actual and perceived physical health impacts as a result of changes to air quality, noise and transport, as well as the more intangible impacts on wellbeing.




4.8 Habitats Regulations Assessment

a) Introduction

4.8.1 The Infrastructure Planning Commission (IPC) Advice Note 10 relates to the Habitat Regulations Assessment (HRA) of nationally significant infrastructure projects. Within this advice is a recommendation that:

“dialogue takes place between the developer and the nature conservation bodies about HRA issues throughout the pre-application stage and as early as possible. Informal discussions with the developer may include advising on likely significant effects and mitigation proposals.”

4.8.2 In accordance with the 2010 Habitats Regulations and the IPC guidance, the following consultees were included in the informal HRA consultation process:

Natural England (NE);

Countryside Council for Wales (CCW);

Environment Agency (EA);

Marine Management Organisation (MMO);

Sedgemoor District Council (SDC);

Somerset County Council (SCC); and

West Somerset District Council (WSC).

4.8.3 This informal consultation process followed meetings of the initial Marine Authorities Liaison Group (MALG), which formed the basis for early pre-application discussions. A report on the informal engagement undertaken with MALG is included in this chapter.

4.8.4 The Royal Society for the Protection of Birds (RSPB) was brought into the consultation process in March 2011. The RSPB is a non-statutory organisation, but it was agreed with regulators that the involvement of the organisation would be beneficial. They were invited to key meetings and given access to the information available to the regulators.

4.8.5 The pre-submission consultation period on the HRA was initially based on the establishment and discussion of the baseline data. A total of 12 workshops were held, as well as 16 fortnightly meetings that either took the form of face-to-face or dial-in discussions between December 2010 and September 2011. The initial discussions involved the establishment of a programme to agree the baseline material and discuss key issues as they developed. The main issues discussed at these meetings, how they were progressed and concluded is outlined below. The HRA Report includes an appendix, which summarises the main discussions at the meetings and workshops held, along with how EDF Energy responded.

4.8.6 This approach ensured that the regulators were given sufficient time to review and fully understand baseline data reports and topic papers, ahead of reviewing the drafts of the HRA Report itself.




4.8.7 In response to comments from the consultees regarding the length of time taken to produce the full HRA, a number of subject specific topic papers were produced using the initial baseline reports. The main aim of the papers was to ensure that any potential effects were identified at a stage early enough in the assessment process to allow for any potential issues to be flagged up by the regulators.

4.8.8 The initial consultation on the baseline data reports, the topic papers, the initial draft HRA Report and the draft HRA Report (v2) was followed by a five-day intensive consultation week in June 2011, where all of the consultees, except the MMO who was unable to attend, were brought together to discuss the data and predicted effects.

4.8.9 Following the consultation week, the regulators submitted written comments on the draft HRA Report (v2). The areas of response were: thermal effects and thresholds used in the assessment; chemical water quality standards and operational procedures; fish entrainment and impingement and the effectiveness and functionality of proposed mitigation; and disturbance to birds. Written comments are documented in the HRA Report appendices.

4.8.10 A supplementary workshop to focus on issues specifically related to birds was arranged in July 2011 as a response to some of the issues raised during the consultation week. The workshop was attended by the RSPB, NE, the EA, WSC, SDC and SCC. The key issues discussed are included in detail in the appendices to the HRA Report.

4.8.11 Further reports were also released to the regulators to provide further detail about the designs of the Acoustic Fish Deterrent and Fish Recovery and Return system, as well as updated marine ecology and water quality assessment reports following the HRA consultation week. These provided detailed baseline information and impact assessments to help the regulators understand the process by which the HRA had been undertaken.

4.8.12 A Final Draft HRA Report was released to the consultees for comment in July 2011. Comments arising from this consultation were integrated into the HRA Report for the DCO submission and are documented in the HRA Report appendices.

b) HRA Report

4.8.13 The following approach to the HRA was discussed and agreed with regulators:

EDF Energy’s survey and analysis work has taken a conservative approach, with a focus on Bridgwater Bay as the main study area as part of a wider area. This is reflected in the HRA.

It has been assumed that if no adverse affect is predicted for migratory fish species in the Severn, it follows that the HPC Project will not affect those sites linked to the Severn that are also designated for the same species populations.

Aspects that were agreed to be incorporated into the HRA Report, following consultation on initial drafts and the HRA consultation week, included:

Climate change and the existing vs. future baseline;

The potential need for dredging arising from vessels using the jetty;




The potential benefits of nearby compensation schemes in the future; and

The use of mitigation and design to avoid likely significant effects and avoiding the potential need for compensation.

The use of models for predictions and the modelling approach was also agreed.

c) Mechanisms to Ensure Predicted Effects are Accurate

4.8.14 A key issue arising from some of the discussions surrounded the need to include mechanisms to ensure changes in design, development and/or changes in construction methods post any IPC consent did not have an adverse impact on the EU sites. Notable aspects from the discussions are included in the summary below and in the HRA Report and appendices.

d) Key Issues Arising from the Consultation Process

i. Relationship with Other Schemes/Potential for Compensation

4.8.15 Discussions regarding compensatory habitat (if this were required) took place early on in the process, before any potential effects had been identified. The initial focus of attention was the potential impact that the cooling water discharge, and the increase in water temperature associated with this, could have on intertidal mudflat invertebrate communities and, indirectly, the bird populations in Bridgwater Bay that feed on these invertebrates. Natural England (NE) concluded, in relation to the potential for compensation, that it would not be possible to provide like for like replacement habitat (i.e. lower-mid intertidal mudflat) in proximity to Bridgwater Bay or within the wider Severn Estuary. It was also agreed that the creation of mudflat habitat (in Bridgwater Bay), which could provide additional food resources should this be depleted by the effect of the thermal plume, is not viable.

4.8.16 However, a potential reduction in the biomass of the Macoma population of Steart Flat (i.e. the Special Area of Conservation (SAC) interest) could potentially be compensated for through the creation of suitable habitat anywhere inside or outside of the estuary. NE agreed that compensation to replace any functional loss could be considered. Increased functionality/biomass in the area would be carefully considered as potential mitigation for any effect (i.e. as distinct from specific habitat creation). Meetings were held with both the EA Steart Peninsula project team and the Bristol Ports Company with regards to potential effects of their managed realignment schemes on the Steart Peninsula.

4.8.17 Although the focus in the HRA is on the mitigation of effects ahead of any compensatory measures, EDF Energy will also consider potential compensation schemes should an adverse effect on the integrity of the Severn Estuary SAC and the Severn Estuary Special Protection Area (SPA) be concluded by the IPC in undertaking its Appropriate Assessment.

ii. Bats

4.8.18 The methodology of the research and conclusions drawn in relation to bats was raised during the HRA consultation. The local authorities (represented by SCC and Arup) suggested that Greater Horseshoe bats might travel further than assumed for foraging. References of these studies were provided by the local authorities to EDF




Energy. SCC suggested that there is evidence of barbastelle roosting in the Quantocks, although agreed that a lot of survey work had already been completed.

4.8.19 Specific mitigation measures to retain key habitat corridors have been built into the site design and layouts. Green Lane and Benhole Lane (both important corridors), which connect to Bum Brook at the bottom of the site, will be kept open and are considered in the lighting strategy. Other measures for the mitigation of potential effects on the capacity of the development site to support foraging habitat for barbastelle bats include tree planting in existing arable fields early on in the development process. Taking into account the mitigation and measures outlined, EDF Energy’s initial conclusion is that there would be no likely significant effect; although EDF Energy would give further consideration to the discussions and the need for any additional mitigation measures.

4.8.20 Following consultation the need for an additional 15ha of land for foraging, to form additional mitigation to that already proposed, was identified. Further details are included in the Environmental Impact Assessment.

iii. Cooling Water Intake/Outfall

4.8.21 The HRA consultation week included discussions on the design and operation of the cooling water intake/outfall process and the effectiveness of proposed mitigation measures.

4.8.22 During consultation the EA endorsed the approach taken by EDF Energy to the Fish Recovery and Return system (FRR). The EA requested monitoring of the impingement of fish on the drum screens. It is hoped that specific tests of the drum screens will be performed before implementation. The importance of the design of the screens and FRR to protect eels was highlighted.

4.8.23 The design of the FRR and the in-combination effects with Hinkley Point B (HPB) were raised. EDF Energy confirmed that the design brief had been developed to prevent discharged fish becoming entrained in the HPB cooling water system.

4.8.24 The consultation also investigated the most appropriate position for the FRR discharge. NE wanted to understand if there was any evidence relating to the disorientation of fish when they come out through the FRR discharge area. EDF Energy confirmed that this would be closely monitored and the outfall location for the FRR has since been designed to take these issues into account. A report documenting the position of the FRR discharge was issued to regulators in July 2011.

4.8.25 Following comments on the Final Draft HRA Report from the regulators, it was agreed that further information would be provided on entrainment effects, especially on plankton and important crustacea.

iv. Water Quality

4.8.26 Natural England raised concerns that the water quality impacts (i.e. chemical), added to the thermal effects, could be significant and that the potential impact area might extend. It was agreed by EDF Energy that this would be considered and included in the HRA Report.




Chlorination

4.8.27 From the EA’s perspective, with the adoption of suitable management, chlorination would have minimal impact on the SAC and SPA designations. NE agreed with this, as long as the permitting requirements are agreed.

4.8.28 EDF Energy’s proposed management measures are listed in the HRA Report. The EA consider this at the permitting stage, as will the Countryside Council for Wales (CCW).

Hydrazine Discharge

4.8.29 It was agreed that hydrazine discharge will be considered further through permitting. A technical report on hydrazine toxicology was issued to the regulators in July 2011.

Accuracy of Modelling

4.8.30 The EA expressed the view that the modelling of HPC was overly conservative, due to the assumption that the discharge mixed at the outfalls. This was supported by a sensitivity analysis produced by Cefas (Centre for Environment, Fisheries and Aquacultural Science). It was subsequently agreed that without full validation, the existing results would be used and accepted as precautionary. Cefas outlined the results of sensitivity analyses that had been performed since that workshop at the HRA consultation week.

4.8.31 The RSPB suggested that the bird food model (MORPH) might not adequately address some of the components. The RSPB was provided with extensive datasets and analysis and the models used for the prediction of effects were discussed at the RSPB workshop on birds in July 2011. Discussions related to data validation; tidal behaviour on the flats and key simulation parameters; water temperatures; hydrodynamics; combined effects with other schemes; day and night time feeding rates; and assumptions relating to the input bird data and food supply.

4.8.32 Outcomes and conclusions relating to the predictions from the modelling are discussed below. The models adopted were agreed to be conservative so further validation work was subsequently undertaken. The MORPH model will be used as a supplementary document that verifies the conclusions.

Thermal Plume

4.8.33 Although discussions continued throughout the consultation process regarding the potential extent and effects of the thermal plume associated with the cooling water discharge, both for HPC alone and in combination with HPB, detailed discussions were largely concluded at the HRA consultation week. Discussions mainly surrounded the availability of a food source for birds, particularly Shelduck.

4.8.34 Discussion took place on the predicted effect of a reduction in the biomass of Macoma within the plume area. However, modelling has demonstrated that the Shelduck population will be unaffected by the conservative, predicted reduction in Macoma biomass from HPB and HPC plumes.

4.8.35 Prey availability for Shelduck was raised by the RSPB. The RSPB requested a range of data and stated that understanding the net effect of the thermal plume (with respect to biomass change, both for HPC alone and in combination with HPB) and




where the overlaps occur is required. NE confirmed that it could agree a worst-case scenario and this analysis was subsequently provided to the RSPB. The RSPB stated that it accepted the work to date that can be used to produce the calculations and confirmed that it accepted the assessment of impact to the mudflats.

4.8.36 Following regulator comments (September 2011) relating to how the Macoma populations relate to other populations in the Severn Estuary, detailed analysis is ongoing. Further analysis is also continuing in relation to Macoma within and outside of the plume, based upon 2010 survey data. This information has informed the HRA Report.

Uplift Standards

4.8.37 Countryside Council for Wales specifically questioned the use of a 3 degree uplift as the temperature standard being used in assessment, rather than the 2 degree threshold that forms the standard used under the Habitats Regulations.

4.8.38 Cefas confirmed that, for the ecological assessment of potential HPC impacts, the Project had only used the existing regulatory limits as indicative screening levels. Impacts on any potentially sensitive features had been assessed at appropriate temperatures or chemical concentrations, which, in several cases, were below the existing regulatory guidelines. CCW stated that the agreed standards at present remain (WGTAG 160) – any deviations from this need to be proven and adopted by the regulatory authorities. It was agreed that consent would be applied for based on existing standards.

v. Bird Disturbance

Displacement

4.8.39 The potential for HPC to cause a displacement effect and any in-combination effects that could arise with other projects (e.g. wind farms or the planned Bridgwater-Seabank electricity transmission line) was raised by NE. EDF Energy’s response showed that from a disturbance perspective, any displacement effects, if they occurred, would be localised and temporary.

Vessel Movements

4.8.40 The local authorities asked about bird disturbance in relation to the movement of vessels to Combwich Wharf and the combined effect with the construction works for the realignment projects on the Steart Peninsula. EDF Energy confirmed that vessel movements would be unlikely to lead to disturbance and displacement, as they would be at high tide, so birds would not be feeding on mudflats and vessel speeds would be low. Further detailed commentary on these discussions can be found in the appendices of the HRA Report.

Shelduck

4.8.41 The behavioural responses of moulting Shelduck to disturbance were raised at consultation. The RSPB was of the view that rafting Shelduck were not being properly considered and argued that there may be a logical reason to look at additional precautionary mitigation.




4.8.42 Mitigation and best practice measures that will be implemented as part of the jetty proposals are included in the summary notes provided in the HRA Report appendices. These also include a record of the discussion of key issues. A formal response has subsequently been issued to the RSPB and regulators addressing this issue.

4.8.43 In terms of mitigating any potential for bird disturbance from lighting, the jetty has been designed to be shrouded to avoid spill towards the surrounding areas. EDF Energy will minimise lighting where practicable.

4.8.44 EDF Energy confirmed that best practice measures during construction, including a working corridor, will be used. It was agreed that these measures will be included in the HRA. NE added that the reduction of in-combination effects by diverting the footpath during construction should be noted, as it will reduce the disturbance effects of the public walking on the foreshore.




4.9 Engagement with Landowners

4.9.1 As part of its ongoing engagement on proposals for HPC and its associated development, EDF Energy has consulted, at length, with landowners, tenants and those with in an interest in land who would be affected by the development proposals. As statutory consultees in the planning process, EDF Energy has engaged a range of landowners, both formally and informally, taking account of comments when and wherever possible. As the Project proposals have been amended and refined, the number of affected parties has varied, as have the issues and identities of the affected parties.

4.9.2 In addition to consultation with the landowners, EDF Energy has also engaged a number of the parties on a commercial basis to secure the necessary rights (either freehold or leasehold) over the land to allow for the construction of facilities should the IPC grant DCO permission for the Project. This engagement will continue past the submission of the DCO application up until the land interest is secured, or the DCO is granted.

4.9.3 The majority of EDF Energy’s informal engagement with landowners took place via meetings and telephone conversations, with site visits organised where relevant. A number of these were initiated by EDF Energy and tended to involve small meetings between the landowner, their agent and the EDF Energy design team. A number of the discussions were held in response to concerns raised directly with EDF Energy by the landowners themselves.

4.9.4 A wide range of issues were raised on the likely impact of the HPC development on individual landowners throughout the period of engagement. Some of these issues reflect comments made in response to the formal consultations. A summary of the key points discussed informally with landowners is provided below on a site by site basis and for those who may be eligible for compensation from EDF Energy (known as Part 1 Claimants).

a) Bridgwater

4.9.5 EDF Energy’s engagement with Bridgwater landowners began with the Stage 1 consultation in November 2009. Following the completion of this stage of consultation, further dialogue took place regarding the preliminary designs of the sites and the limitations and strengths that were still being established through the early design and environmental impact assessments.

4.9.6 At all four of the Bridgwater sites, proposed at Stage 1 consultation, access and egress points were an important consideration and a number of meetings were held with both the designers and landowners to agree the best way forward. As a result of some of these discussions, EDF Energy undertook further technical work, such as traffic modelling and swept path analysis.

4.9.7 A significant amount of informal consultation took place on the Bridgwater A site. However, the majority of this was about commercial discussions and was not related to design.

4.9.8 EDF Energy engaged landowners on the proposals and potential design aspects of the Bridgwater B site on several occasions, until the decision was taken, prior to Stage 2 consultation, to no longer proceed with the site. The main areas of




discussion, prior to this decision, centred on the potential access points and physical capacity of the site. At this point, a number of these decisions remained unresolved. However, due to the decision to discount the site for development no further action was taken.

4.9.9 The layout of the site at Bridgwater C was discussed on several occasions with the surrounding landowners to assess the potential operational impacts, and continued until the finalisation of the site design prior to the DCO application submission. A number of design changes were implemented as a result of the feedback received, both formally and informally, including building alignment and boundary treatment to reduce the potential operational impacts on the surrounding owners and for possible legacy uses to be factored in.

4.9.10 Limited informal consultation occurred with landowners in relation to Bridgwater D, and the possibilities surrounding this site, until the decision was taken, prior to Stage 2 consultation, to no longer proceed with the site. Discussions surrounded the legacy potential of the site and aspirations for the wider area.

b) Cannington

4.9.11 EDF Energy began engagement with landowners in Cannington in 2009 regarding the four sites that had been identified for potential associated development use in and around the village. A number of discussions were held with the landowners, with the majority initiated by individuals post-Stage 1 consultation in order to continue the discussions started during the formal consultation period.

4.9.12 The main issues related to the proposed uses and their scale, as well as the potential impacts on the surrounding area. These discussions continued until just before the Stage 2 consultation when, as a result of the informal engagement with landowners, the formal consultation responses to Stage 1 and further technical information, the number of sites proposed for the Cannington area was reduced to one site, Cannington A, for a park and ride for 360 vehicles.

4.9.13 During and after Stage 2 consultation further engagement was held with the landowners of Cannington A (the preferred site for the park and ride facility) through one-to-one meetings and dialogue with the design team to refine the proposals, particularly in relation to the boundary treatments to balance the concerns of the landowners and ecological requirements.

c) Cannington Bypass

4.9.14 EDF Energy began engagement with the relevant landowners through the formal consultation process in November 2009. At the end of the Stage 1 consultation process, further dialogue was entered into about the preliminary designs of the two possible routes of the bypass (west and east of the village), discussing the limitations and strengths of each, which were still being established through the early design and environmental impact assessments.

4.9.15 The landowners along both route options where consulted both formally and informally until the finalisation of the preferred route prior to Stage 2 consultation, after which point, only those landowners on the western route were engaged with.




4.9.16 During the Stage 2 consultation, landowners on the western route were engaged in more detail. The design, in particular, was covered in a series of specific meetings held with the landowners and their agents. A number of meetings and conversations covered issues of detailed design, such as position of gateways, fence lines and crossing provisions. Informal discussions continued up to the submission of the DCO application.

4.9.17 Detailed discussions were held regarding the crossing points at the southern end of the western route, in order to reach the safest and most practical way of crossing the proposed bypass for both people and animals, particularly with respect to the local school and farmers. Concerns from existing users around the safety of the proposed route and crossing were raised. The bypass design was adjusted and altered as the proposals were progressed to reflect the ongoing discussions with the landowners in this area. This included the location and type of cattle crossing, as well as the location of the signalised pedestrian crossing and corals (holding areas for cattle).

4.9.18 Field access points were also discussed and agreed with the respective landowners over the course of the design phase, with a number of discussions being held post-Stage 2 Update consultation as more information became available.

d) Combwich

4.9.19 Engagement began with landowners in 2009, when the site was identified for a laydown area, as well as improvements to the existing wharf. EDF Energy has had a number of discussions about the design and operation of the proposed facilities, holding meetings both at the request of the landowners and at the invitation of EDF Energy.

4.9.20 A number of the issues raised were in relation to the layout of the wharf area and the ability for existing users to continue to operate from it. Post-Stage 2 consultation, a number of design changes were implemented in relation to the access arrangements to the wharf to allow the safe continued use by other parties. These continued to be refined through the following stages of consultation.

4.9.21 Throughout the various stages of engagement – both formal and informal – with landowners, a number of issues were raised surrounding the proposed uses of the facilities, particularly in relation at the laydown area and fabrication facilities. In response to the issues raised through formal channels, the land use was altered to remove uses such as fabrication in this location. Access to the surrounding fields was seen as an important consideration by the landowner here and design changes were made to facilitate this.

e) Junction 23, M5

4.9.22 Engagement began with the publishing of the Stage 1 documentation, which included two potential sites, J23-A and J23-B. Landowners within the vicinity of both sites where contacted via the formal consultation process, with discussions continuing beyond the completion of this phase. These discussions allowed landowners the opportunity to better understand the proposals for the site, leading to valuable input for the EDF Energy project team.

4.9.23 Discussions focused on understanding the landowners’ aspirations for the site, as well as furthering EDF Energy’s understanding of the sites’ limitations and




opportunities from the landowners’ perspectives. This included the usage of areas such as the Drove, and factors such as the drainage conditions of the fields.

4.9.24 EDF Energy continued to engage with the landowners on options and proposed changes to the site design up until the Stage 2 consultation when, as a result of the informal engagement with landowners, the formal consultation responses to Stage 1 and further technical information, EDF Energy decided to focus on the J23-A site.

4.9.25 Following Stage 2 consultation issues such as design, legacy, need and timing of the J23-A site were addressed through continued discussion.

4.9.26 At Stage 2 Update, following engagement with landowners over an outstanding planning issue with the site boundary, the design was altered to exclude this particular area to allow the landowner’s potential development to come forward. A number of discussions were also held surrounding access and egress to the site, resulting in a design review to ensure the proposals were as economical as possible with the land requirements. EDF Energy also explored the development potential of the area nearest the main road, as a result of informal engagement, and looked to reduce the land take at the frontage area as much as possible to allow the landowner to bring forward potential development in the future. Some of these issues were still being resolved at the point of submission.

f) Junction 24, M5

4.9.27 Engagement began with the publishing of the Stage 1 documentation which included three potential sites for development at J24. A number of meetings were held to discuss the potential development through the pre-application consultation process with the identified landowners. Upon the publication of the Stage 2 consultation, engagement continued on the preferred site, J24-A, primarily with the option holder of part of the land. This covered the issues of type, scale and siting of the development. A number of these discussions resulted in changes to the design and facilitated further engagement with other stakeholders, such as the Highway Authority and the developers of an adjoining housing estate.

4.9.28 At the Junction 24 and Highways Improvements consultation, an additional site was proposed at Junction 24 of the M5 for the proposed park and ride and freight management site. Informal consultation occurred with the landowner of the new site, prior to it being presented at consultation, to discuss the future of the site, timescales and availability, as well as the operational characteristics of the current usage.

4.9.29 Informal consultation also continued with those landowners whose sites were affected by original proposal at the J24-A site. The landowners of the J24-A site have been informed of EDF Energy’s decision to no longer pursue development proposals for this site. Informal discussions continued as part of the ongoing need to understand the proposed developments in the surrounding area.

g) HPC Development Site

4.9.30 Consultation on a formal and informal level has occurred with landowners in relation to the proposed HPC Development Site, since before Stage 1 consultation, on a commercial and practical basis. A large number of issues have been raised by a wide range of parties in relation to the impacts of the proposals for this site.




4.9.31 In response to comments made through formal and informal channels by landowners and those in close proximity to the site, a number of changes have been made including the creation of early planting on the southern land and the establishment of the southern construction limit at gridline 144750mN.

4.9.32 Informal engagement has also occurred regularly with Stogursey Parish Council and further information can be found in this chapter.

4.9.33 In response to a number of concerns raised during the engagement, EDF Energy introduced its Main Site Neighbourhood Support Scheme, which looks to offer assistance should local residents wish to sell their property or make noise insulation improvements to their windows. EDF Energy is continuing to engage with all parties, including landowners surrounding the site, and these relationships will continue.

h) Williton

4.9.34 EDF Energy began engagement with landowners through the formal Stage 1 consultation process, which included two potential sites for accommodation and a park and ride site in the area. The main areas of discussion with the landowners focused on the scale of development and the potential opportunities it created. A number of conversations also focused on the exact siting of the developments and the limitations of the site, such as the tumuli to the north of the Williton A site and flood risk issues on both. A number of these issues remained unresolved ahead of the decision not to pursue the Williton B site at the publication the Stage 2 consultation.

4.9.35 During and after Stage 2 consultation further informal engagement occurred with the landowner of Williton A regarding a number of issues, including the precise siting of the facility and the access arrangements for the proposed park and ride. As a result of formal responses to consultation, together with further technical information and studies, EDF Energy sought to engage landowners on the proposals for Williton and informal discussions began with the landowner of an alternative site to the west of Williton (the Smithyard Terminal).

4.9.36 A number of conversations and meetings were held between the landowners, EDF Energy and their respective advisors, prior to the Stage 2 Update consultation. This engagement sought to explore the landowners’ aspirations for the site, as well as gaining a greater understanding of the operational impacts on both parties, including land-take and access arrangements. These discussions reached a successful conclusion.

i) Highway Improvement Schemes

4.9.37 Highway improvement works were proposed at Stage 2 Update that affected a number of landowners. These landowners were engaged with through the formal consultation process, which looked to address a number of their concerns and points of clarification over the full extent of the works that would be undertaken. Due to the nature of this engagement the majority of issues were addressed in the formal consultation period.

4.9.38 Informal discussion continued at Washford Cross, following the Stage 2 Update consultation, about the nature of the proposals for road improvements in the area. It came to EDF Energy’s attention that the design would have a significant impact on a




local business, which lead to the proposed junction design being reviewed and altered to avoid this particular area. Field gate positions were also discussed with the affected landowners, and altered where necessary, to continue to allow the surrounding fields to be farmed.

4.9.39 At the Junction 24 and Highways Improvements consultation, a number of new highway schemes were introduced following further technical studies and discussion with the local councils. The affected landowners were engaged through this formal consultation process. Since the close of consultation, further informal engagement has been undertaken via a series of phone calls and letters relaying EDF Energy’s decisions on the schemes as the proposals became more refined. Through more detailed traffic modelling on the impacts and requirements of the proposed highway improvements, EDF Energy has reduced the impact and extent of a number of the proposals. Those landowners that continue to be affected by the proposals have been engaged with on both the commercial and practical issues associated with schemes. Through these discussions with those landowners who remained affected by the highway proposals, a greater understanding of the potential impacts was gained by EDF Energy and the additional refinement of the redline boundaries was undertaken to reduce the impact wherever possible.

j) Part 1 Claimants

4.9.40 In addition to the landowners and those with a direct interest in land, EDF Energy also engaged, from Stage 2 consultation onwards, with those individuals that it felt had the potential to make a Part 1 claim under the Land Compensation Act 1973.

4.9.41 In addition to the formal consultation, a number of home visits were undertaken to those potentially affected by the development to help explain the proposals in more detail and the basis for any potential claim. These discussions looked to address and explain the background and rationale for the proposals that were felt to have a potential impact, as well as allowing EDF Energy to gain an understanding of their concerns in relation to the proposals.

4.9.42 A number of the schemes, particularly the main HPC site, Cannington and J24, have been adjusted and adapted, as detailed above, in response to the areas discussed with the potential Part 1 claimants.




4.10 Non-statutory Consultees/Stakeholders

a) Area Of Outstanding Natural Beauty Partnership Offices

4.10.1 An Area of Outstanding Natural Beauty is, an area of countryside considered to have significant landscape value in England, Wales or Northern Ireland that has been specially designated by now Natural England.

4.10.2 Informal consultation on issues relating to Areas of Outstanding Natural Beauty (AONB) began in December 2008, with discussions aiming to:

establish a landscape and visual baseline;

confirm the landscape and visual impact assessment (LVIA) methodology; and

discuss the potential impacts on the Quantock Hills AONB and Mendip Hills AONB.

4.10.3 The Quantock Hills AONB Service and Somerset County Council have contributed to every stage of consultation since December 2008. The Mendip Hills AONB Service provided the majority of comments during the early stages of informal consultation, and consultation with both stakeholders concluded in 2011 in advance of the DCO submission. Informal consultation was also undertaken with Exmoor National Park, the majority of which was undertaken by email.

4.10.4 The majority of informal consultation on AONB issues was undertaken by email and supplemented by phone calls to clarify the material sent electronically. From early 2010 meetings were also organised at irregular intervals. The first meeting on AONB issues took place in April 2010 during a site visit with statutory consultees. Representatives from Natural England provided advice on the location of additional AONB viewpoints along the coastline, having confirmed those with the AONB Service prior to the meeting.

4.10.5 Further meetings were held and correspondence exchanged over the next year, however regular meetings were not required due to the launch of Stage 2 consultation. The majority of feedback from the Quantock Hills AONB Service was provided during formal consultation.

4.10.6 A key meeting with stakeholders including Quantock Hills AONB Service and Somerset County Council was held in April 2011, when agreement was reached on the following issues related to AONB:

Selection and presentation of representative viewpoints, including final location of all AONB viewpoints to be included in the assessment.

Presentation of montages (Visually Verifiable Images - VVIs) of the development in the Environmental Statement (ES) and scaling of images according to the new advice note published in March 2011 (Landscape Institute Advice Note 01/11 (2011) Photography and photomontage in landscape and visual impact assessment Landscape Institute: London).

VVI methodology.

Illustration of cumulative impacts with National Grid Proposals.




Presentation of night time views and selection of views to be retaken at dusk for the production of VVIs including lighting proposals.

4.10.7 No further meetings were held, however further correspondence was exchanged in late 2011. While the majority of issues relating to the application for development consent have now been discussed and resolved, EDF Energy will continue to engage with the AONB offices and Natural England on an informal basis on LVIA issues throughout the construction of HPC and into the landscape restoration phase, should consent be granted

b) Bridgwater Challenge

4.10.8 EDF Energy has had a seat on the Bridgwater Challenge Board and has attended its quarterly meetings since mid 2009. The Challenge’s aim is to co-ordinate the delivery of economic, commercial and regenerative initiatives for the town, of which HPC is but one project.

4.10.9 EDF Energy has provided the Board with updates on the HPC proposals, contributing to debate and helping to identify potential local business opportunities. EDF Energy agreed to provide some of the Bridgwater office staff to support the Challenge from summer 2011. Insights gained at these meetings have helped inform the approach taken within the HPC procurement strategies.

c) Bridgwater College

4.10.10 EDF Energy published a draft Construction Workforce Development Strategy for review and consultation at Stage 2. At this time, EDF Energy proposed to create a partnership with a local training provider to establish a construction skills training centre in Sedgemoor.

4.10.11 After an initial scoping exercise Bridgwater College was selected as the preferred delivery partner for this planned facility, known as the Construction Skills Centre (CSC). The CSC would provide training to people in the West Somerset and Sedgemoor districts and the wider Somerset administrative area, to prepare them for future job opportunities that will result from the HPC Project.

4.10.12 Since June 2011, regular meetings were held between a core staff team from Bridgwater College and EDF Energy, to jointly deliver the Construction Skills Centre. Meetings typically took place once or twice a month. The relationship with Bridgwater College developed into a more formal partnership in August 2010, with proposals for the CSC being presented and signed off by the Employment and Skills Operations Group in September 2010.

4.10.13 Both EDF Energy and Bridgwater College have appointed senior managers to oversee this key project and joint areas of interest, including managing issues and risks, and ensuring that key skills based projects and initiatives remain on track.

4.10.14 The CSC project team developed a detailed project scoping document, which evolved over time into a detailed business plan to ensure that the CSC would be sustainable and support the skills needs of HPC workers. Discussions between EDF Energy and Bridgwater College focussed on the centre training local people for employment on the HPC Project.




4.10.15 Bridgwater College successfully obtained consent under the Town and Country Planning Act application process on 12 April 2011 for the CSC to be located at the College’s site in Cannington.

4.10.16 There are currently no facilities or sites within Somerset that meet, or are suitable to meet, the exacting criteria of a construction skills centre for HPC. For the project to succeed, issues of funding, land acquisition, planning and the development of a robust business case had to be overcome.

4.10.17 EDF Energy worked closely with Bridgwater College to help build its capability and business plans, assuring that the key objectives of the Construction Skills Centre could be met. A key feature of the proposal was the added value that the College brought to the scheme, in particular its extensive local knowledge. A strong working partnership has achieved many significant milestones, including the development of a skills curriculum specifically focusing on the needs of the HPC Project.

4.10.18 In developing specific proposals for the Construction Skills Centre, the aim of the project team was to maximise the value of the College’s existing facilities such as training being delivered at Riverside. Whilst the Centre at Cannington is being built, training is being delivered from existing college sites.

4.10.19 EDF Energy is also committed to investing in future operational and management skills in Somerset that will be required beyond the construction phase of HPC. Finding suitable facilities and the development of a robust business model with Bridgwater College raised significant issues that both parties were committed to resolve.

4.10.20 The development of Bridgwater College Energy Skills Centre will allow large numbers of people to benefit from the HPC proposals and for Somerset to be a leader in the low-carbon energy industry.

d) Bristol Ports Company

4.10.21 In 2011, EDF Energy began engagement with the Bristol Ports Company on their proposals for a new container terminal in Avonmouth. Constructing this new container terminal will involve some reclamation of the foreshore on which birds currently feed and roost. To compensate for that loss, the Bristol Ports Company will be creating new compensatory habitat for wetland birds and other wildlife. This new habitat will be provided on the Steart Peninsula and is programmed to be delivered in advance of any damage to designated habitats during the construction of the new container terminal. It is intended the planning application for the Steart Habitat Creation Scheme will be submitted in 2011 to Sedgemoor District Council.

4.10.22 The objective of the engagement with the Bristol Ports Company was to identify opportunities to provide joint enhancements in the area, and identify where our respective proposals interact to understand the potential for cumulative impacts.




4.10.23 Meetings were held with the Bristol Ports Company in March and July 2011. Throughout the period of engagement information has been shared on project proposals and outputs from the Environmental Impact Assessment (EIA) and Habitats Regulations Assessment (HRA). Key environmental topics discussed included:

flood risk;

coastal and marine processes;

terrestrial and marine ecology;

transport (including visitors);

amenity and recreation; and

visitor numbers and proposals.

4.10.24 In parallel to the Bristol Ports Company’s proposals, the Environment Agency is also proposing to create additional intertidal habitat on the Steart Peninsula with an aim to manage flood risk while taking the opportunity to create new natural habitat. The Bristol Ports Company has been working in close cooperation with the Environment Agency on the overall vision for the Steart Peninsula and to promote consistency and integration on their proposed schemes. Similarly, EDF Energy has jointly engaged with the Environment Agency on their scheme proposals.

4.10.25 EDF Energy has also engaged with the Severn Estuary Partnership (SEP), the membership of which includes Bristol Ports Company. The partnership brings together academic researchers, estuary users and businesses as well as government agencies. Updates on the HPC Project have been given to the annual meetings of the Severn Estuary Forum in September 2009, October 2010 and September 2011, and contributions made to the SEP's newsletter "Severn Tidings".

e) Brymore School

4.10.26 A number of meetings were held with Brymore School in the months following Stage 2 consultation to discuss the training and employment opportunities that the Hinkley Point C development might generate for pupils and the impact that the construction of the Cannington bypass may have on the school’s day-to-day activities.

4.10.27 Adjustments to the design of the pedestrian and animal crossings of the bypass were strongly influenced by the requirements of the school; the toucan crossing has been moved south in order to tie in with the main pedestrian and cycle route for students travelling into Cannington and a cattle crossing with corrals and warning lights has been introduced to assist students and the farm manager with moving the school herd of cattle to their summer grazing field.

4.10.28 The proposals at Stage 2 originally had an underpass by Brymore School’s main drive to allow pupils to cross the bypass and to herd cattle to the school's summer grazing field. EDF Energy met with the headmaster of the school in October 2010, who stated that Brymore’s preference was to have a bridge going over the bypass, rather than an underpass. It was noted, however, that an underpass would be acceptable in the absence of other suitable options. The school’s opinion at that time was that an at-grade toucan crossing would not be a safe option as some of the




pupils have learning difficulties and no road sense, as such, the concern was that they may not use the toucan crossing properly.

4.10.29 A further meeting between EDF Energy, the school’s headmaster and farm manager was held in November 2011, where it was stated that whilst the school’s preference was still for a bridge, it had been concluded that an underpass for pupils and cattle would not be suitable. The concern was that it would be impractical in terms of maintenance and there was a fear that it could be a hazard for pupils if cattle stampeded in the enclosed space of the underpass.

4.10.30 The farm manager also suggested that an at-grade cattle crossing with corrals and warning lights would, in fact, be acceptable providing that the pupils had adult assistance. The school was concerned that the mix of farm traffic, school traffic and cattle on the back access (where the toucan crossing had previously been suggested) could be a hazard and confirmed that the main route for pupils walking from the school into Cannington was actually along the route of the main access.

4.10.31 As a consequence of these discussions, the underpass was omitted from the proposals; the toucan crossing was moved to be close to the Brymore School’s main access, close to the main desire line of pedestrian traffic between Cannington and Brymore School; a cattle crossing with warning lights and corrals was included and a new section of road was added for farm and school traffic to segregate these from the cattle that will continue to use the route of the existing back access.

4.10.32 Engagement with the school will continue throughout the duration of the Hinkley Point C Project and will continue to be one of EDF Energy’s key stakeholders.

f) Jobcentre Plus

4.10.33 Consultation with Jobcentre Plus (JCP) began in September 2010, with a view to creating a partnership that would optimise the organisation’s input to generating employment opportunities for Somerset people during the construction and operation of HPC. The relationship is ongoing, with consultation continuing beyond the submission of the DCO application and through the construction phase of the Project.

4.10.34 EDF Energy first met with the senior management team from the Somerset and Dorset District of JCP in September 2010. This followed on from the preparation of an options paper within EDF Energy, which highlighted JCP as a potential key partner in future employment and skills initiatives to support HPC.

4.10.35 Meetings between the two parties continued once or twice a month until JCP was affected by the implementation of the UK Government’s Comprehensive Spending Review (CSR). Consultation with JCP became less frequent during this time, as JCP went through significant organisational change. The Somerset and Dorset district was replaced with a larger district called ‘Wessex District’, with a new senior management team appointed.

4.10.36 Consultation resumed with the Director of JCP’s new Wessex region in February 2011. Since April 2011 regular meetings have taken place with a core team of staff from Wessex District JCP and EDF Energy. The frequency of these meetings is fortnightly, however it has been agreed that at key points within the programme this may need to change, to reflect the demands of the Project and impending vacancies.




4.10.37 To formalise the relationship a draft Memorandum of Understanding (MoU), has been developed jointly between the two parties. The draft MoU outlines the methods of working together and ascertains each partner’s responsibilities regarding the brokerage in this formalised partnership. The structure of the employment brokerage team was jointly agreed post Stage 2 Update consultation.

4.10.38 As outlined in the MoU, EDF Energy will provide an employment manager as well as employment and skills managers as the Project develops. JCP will provide a dedicated account manager, job advisor manager, HPC champions in each JCP location and further staff to support the growing requirements of the phased construction development.

4.10.39 To maximise the opportunity to Somerset residents via the employment brokerage, a primacy rule has been established. Primacy will provide people living in Somerset the opportunity to access any HPC vacancy before the vacancy goes ‘live’ on the JCP national vacancy register. JCP, as a part of the vacancy creation process, has produced a dedicated HPC mnemonic so that the agreed primacy option can be tracked and monitored.

4.10.40 Agreement has been reached between EDF Energy and JCP on the location of the central employment brokerage team; this will reside within the Bridgwater JCP Office in North Gate, Bridgwater.

4.10.41 Consultation will continue following the DCO application in a collaborative manner for the duration of the construction of HPC, and should consent be granted into its operational phase from its location within the JCP Bridgwater office. Scheduled meetings will continue and will be reviewed in line with the construction phase and requirements for additional resource at HPC.

g) Save Cannington Action Group

4.10.42 Consultation began with the Save Cannington Action Group (SCAG) in early 2010, prior to the end of Stage 1 consultation. SCAG was formed in response to the proposals for HPC. SCAG is specifically concerned about the potential traffic impacts on Cannington.

4.10.43 Two official meetings between EDF Energy and SCAG took place in January 2010 and, prior to Stage 2 consultation in May 2010. SCAG has also engaged in the formal stages of consultation, as well as attending public meetings arranged for residents of Cannington, North Petherton and those living closest to the HPC Development Site.

4.10.44 SCAG has consistently argued the case for a Bridgwater bypass to transport workers and materials to and from the construction site, and believe that this would leave a lasting legacy for the area. During Stage 1 consultation the group also raised concerns about proposals for worker accommodation for 320 people, the park and ride facility for up to 900 cars and the freight facility in Cannington.

4.10.45 Following careful consideration and updates to the transport and accommodation plans EDF Energy was able to remove the proposals for accommodation for up to 320 people and a freight facility in Cannington. The reduction in the size of the Cannington park and ride from 900 down to 373 vehicles was seen as an improvement, although SCAG would prefer not to have had any facilities in




Cannington at all. SCAG’s significant input contributed to these changes being made.

4.10.46 SCAG disagrees with EDF Energy’s conclusion that a Bridgwater bypass is not justified on the basis of need and continues to push for a Bridgwater bypass to be included in EDF Energy’s proposals.

4.10.47 General engagement with the residents of Cannington, including SCAG members, will take place following the submission of the DCO application through the Community Forum, Transport Forum, ad-hoc public meetings, newsletters and informative letters. Subject to achieving consent to build and operate HPC, it is envisaged that these meetings will continue to take place and the distribution of information will be ongoing throughout the construction and eventual operation of the power station.

h) Somerset Otter Group

4.10.48 EDF Energy’s informal engagement with environmental and wildlife groups in Somerset has been open and flexible throughout the pre-application consultation period for Hinkley Point C. Engagement with the Somerset Otter Group began in August 2010, in response to an enquiry from the Chair of the Group.

4.10.49 A single site meeting was held in October 2010 at the proposed Williton park and ride (P&R) site identified at Stage 2 consultation. There was also regular email correspondence with a volunteer who managed the organisation’s engagement with EDF Energy.

4.10.50 The Somerset Otter Group raised two main concerns about the proposals for HPC at Stage 2 consultation. The first focused on the need for a balancing pond at the proposed Williton park and ride site, which it was feared could encourage otters from the security of the ditch into the site and therefore put them at risk from traffic collision (the culvert underneath the A39 was successfully altered to reduce otter road traffic collisions).

4.10.51 The change of location of the proposed Williton park and ride site removes an area of concern highlighted by the Somerset Otter Group, as otters are not present on the current site and the change of location therefore avoids the potential for any impact.

4.10.52 The second concern was the increase in traffic on the internal access road at the Combwich laydown area, which could also result in otter traffic collision, particularly as otters cross the road at grade, as the existing culverts are too small.

4.10.53 To minimise this potential risk, the site design has been altered to include two otter culverts underneath the access road, which are at a level to ensure they will be available to otters in flood conditions. Culverts on another watercourse have also been designed to be ‘otter friendly’ with ledges to provide continued access during high water levels. These measures would be implemented with wildlife fencing to encourage otters through the culverts and inhibit access onto the internal road network.




i) Somerset Wildlife Trust (SWT)

4.10.54 The Somerset Wildlife Trust (SWT) is a member-led organisation focused on wildlife and wild places in the county. EDF Energy began informal engagement with the SWT in April 2009, providing the SWT with an early opportunity to discuss the HPC proposals.

4.10.55 EDF Energy’s informal engagement with the SWT continued throughout the consultation period and will extend into the construction and operational phases of the development, should development consent be granted. EDF Energy’s long-term objective is to include the SWT in the management of the retained and created habitats.

4.10.56 EDF Energy and the SWT held a total of six meetings from April 2009 to September 2011. The engagement was conducted primarily through face-to-face meetings that took place at and around key Project milestones during the consultation period.

4.10.57 The informal engagement included a meeting prior to the start of the ecology surveys to discuss the scope of the work and a follow up session after the completion of the surveys to discuss the results. Further meetings were also held to discuss the potential mitigation measures that could be employed to reduce any adverse impacts.

4.10.58 The main areas of discussion focused on the potential short-term loss of habitat during construction (i.e. between site clearance and site restoration), which could be a period of 7-10 years. The SWT believed that off-site mitigation or a review of the works schedule would be required to reduce the time between clearance and restoration. The SWT also highlighted the need for EDF Energy to consider Biodiversity Action Plan (BAP) habitats and species, as well as legally protected species and designated sites.

4.10.59 In response to consultation feedback from SWT and other consultees, EDF Energy has reduced the construction area footprint on the development site in the southern area. As a result, this area will be re-profiled at the beginning of the construction phase and permanently planted with a woodland and grassland mosaic, which reflects the final restoration plan. The remainder of the site has also been reviewed in relation to minimising short-term habitat loss through temporary habitat creation on landscape screening bunds (e.g. along the north-west boundary) and on embankments and soil storage mounds.

4.10.60 As intended, Benhole Lane, Bum Brook and the majority of the Green Lane, will be retained and protected during construction. In addition, an area of approximately 25ha of arable/improved grassland will be seeded with a wildflower grassland mix prior to the start of construction. In response to the SWT highlighting the issues of potential impacts on UK BAP and notable species are considered within the Environmental Statement, which is submitted as part of this DCO application.

j) West Hinkley Action Group

4.10.61 Consultation with West Hinkley Action Group (WHAG) began in early 2009. The group is made up of residents who live close to the proposed site for HPC and was originally created to oppose plans for a proposed wind farm close to Hinkley Point.




4.10.62 Official meetings between EDF Energy and WHAG took place in June 2009 and August 2010 to discuss the proposals for Hinkley Point. Engagement with WHAG members continues via other means, such as the Main Site Neighbourhood Forum, with WHAG also represented at the HPC Community Forum.

4.10.63 WHAG members have participated in the numerous drop-in sessions and public meetings that have been held for the residents living closest to the HPC Development Site, having also contributed to the formal stages of consultation.

4.10.64 The meeting between EDF Energy and WHAG in June 2009 focused on the application for the wind farm. Questions were asked about the proposed HPC plans, but as this was very early in the process, limited detail was available. The August 2010 meeting focused on the size and location of the proposed on-site campus, as residents were concerned about the size and proximity to the nearby homes. They were also concerned about the lack of detail on improvements to the local roads, and they required confirmation of what circumstances would lead to the use of the proposed emergency road.

4.10.65 As the wind farm application did not progress there was no need for further engagement on this proposal.

4.10.66 Following careful consideration of comments received and modifications to the accommodation and transport plans for HPC, it was possible to reduce the size of the proposed campus. The campus site area has been reduced in size, car parking has been moved to reduce noise impacts and there has been a reduction in the visual impact of the campus from the surrounding hamlets. EDF Energy also plans to facilitate access to campus sports facilities for local residents.

4.10.67 Road improvements have been developed, including a horse crossing, parking controls on the C182 and improvements at Clayland Corner. These specific improvements were consulted on during the Stage 2 Update consultation. The use of the emergency road was also clarified in the Stage 2 Update consultation - it will be used only in cases of emergency and locked gates will ensure no unauthorised access for vehicles at any other time.

4.10.68 Despite the changes to the on-site accommodation campus proposals, WHAG would have preferred for the facility to have been removed or relocated to another part of the site. These suggestions were investigated thoroughly, but when balancing the engineering and land constraints and the need to minimise vehicle movements, EDF Energy concluded that an on-site campus is an essential component of the proposals for the successful build of HPC.

4.10.69 Members of WHAG neighbour the proposed site, so if consent is granted to build the power station, they will continue to be informed via the multiple channels of engagement. These include the Main Site Neighbourhood Forum and informative letters that are sent to residents living close to the proposed site. Individual meetings between representatives and staff from EDF Energy’s Bridgwater office are planned to continue.

k) West Somerset Community College

4.10.70 West Somerset Community College (WSCC) was identified as an important learning and training hub by WSC. Based on this and with the support of WSC Senior




Officers, EDF Energy met with the Principal and Deputy Principals of the College to explore opportunities to support the training needs of the HPC Project.

4.10.71 EDF Energy commenced detailed discussions with the senior management team of the College following the publication of the draft Construction Workforce Development Strategy at Stage 2 consultation. This included a proposal to invest in a training provider in the West Somerset District.

4.10.72 West Somerset Community College’s existing construction curriculum provided a platform on which to build, particularly to the provision of training for the types of skills required for HPC. This provided the rationale for the selection of WSCC as the preferred delivery partner for this Project.

4.10.73 EDF Energy will be providing assistance to WSCC to achieve the alignment of the College’s vocational offer through the construction of a new mechanical and electrical workshop and updating of other existing facilities; known as the Hinkley Ready Skills Project.

4.10.74 The Hinkley Ready Skills Project (HSRP) will see West Somerset Community College bring its current provision in line with the present and future requirements of the wider construction industry in West Somerset. The project is based upon a robust business case that has been produced in partnership with the College and approved by EDF Energy and West Somerset Community College’s senior management and governors.

4.10.75 The Stage 2 consultation proposals included provision for an apprenticeship hub to be located in West Somerset and resulted in a change to the skills approach and the proposal to develop a broader skills offer. It was agreed that this would centre on the provision of sustainable opportunities and the Hinkley Enterprise Centre Project was conceived.

4.10.76 EDF Energy has proposed to invest in the establishment of the Centre on the agreement of a robust business case with the delivery partner.

4.10.77 EDF Energy, West Somerset Council and West Somerset Community College are working in a collaborative manner to progress proposals and the study will be scrutinised by the Employment and Skills Operations Group on completion.

4.10.78 The Hinkley Enterprise Centre Project will look to serve the construction and future workforces at HPC with products and services, which are delivered by WSCC trainees and its staff in a realistic working environment.

4.10.79 A scoping workshop, which was also attended by members of WSC, was completed and the outputs led to agreed objectives and visions for the Centre. Consultations have taken place with Williton Parish and Stogursey Parish Council with regards to the planned project and to seek their feedback on its location, to inform the feasibility study.

4.10.80 The challenge for the project team is primarily around the location of the centre. The feasibility study will test the potential sites and provide a robust case for the chosen location based upon market research and demand for the Centre’s offer.




4.10.81 The consultation and engagement with West Somerset Community College will continue up to and beyond the submission of the DCO application.




4.11 Engagement with the Local Community, Parish Councils and Other Local Representatives

a) Stakeholder Forums

4.11.1 As part of its ongoing engagement with stakeholders and the local community, and to facilitate engagement with EDF Energy, a number of subject-specific forums have been established to discuss Hinkley Point C proposals and related topics.

i. Community Forum

4.11.2 The Community Forum was the first of the local forums to be established and provided a focal point of contact between EDF Energy, representatives of the local community and stakeholder bodies during the pre-application process for HPC.

4.11.3 The Community Forum met regularly from its inaugural meeting in September 2009 up to submission of the DCO application, during both formal and informal stages of consultation. The meetings held during the informal consultation period took place in February, May, September and December 2010, May and September 2011.

4.11.4 The first Community Forum took place on 30 September 2009 and was attended by 35 representatives. During that time, the Forum has evolved and now has a membership of approximately 80 organisations. Many of these have attended the Community Forum, but some prefer to receive minutes and agendas for information only.

4.11.5 Members of the Community Forum discuss the key issues affecting the local community and work with EDF Energy to address the impacts and consider the benefits of new nuclear build to those living in the area.

4.11.6 Further details of the Community Forum and the agenda items discussed at all Community Forum meetings can be found in Chapter 2. Agendas and minutes of each Community Forum meeting are available to view on the HPC Project website www.edfenergyconsultation.info.

4.11.7 Subject to agreement with the Community Forum members, EDF Energy anticipates that this forum will continue to meet throughout the IPC process and, subject to consent, into the construction and operational phases of HPC.

ii. Transport Forum

4.11.8 Due to the significant demand for more detailed engagement on transport issues, specifically from the parish councils along the proposed construction transport routes for HPC, a Transport Forum was set up by EDF Energy in early 2011.

4.11.9 The Transport Forum provides a mechanism for regular discussion between EDF Energy and representatives of the local community on the transport plans for the construction of HPC. The Transport Forum members discuss and advise EDF Energy on key issues affecting the local road network, working to address the impacts and potential benefits to those living in the area.

4.11.10 A wide range of questions and issues are raised at the Transport Forum, ranging from where yellow lines should be positioned, speed limits and traffic calming as well




as additional transport modelling to assess the perceived need for a northern Bridgwater bypass.

4.11.11 In additional to Transport Forum meetings held during the formal stages of consultation, the Transport Forum met regularly from its inaugural meeting in February 2011 up to submission of the DCO application. The meetings held during the informal consultation period took place in March, April, May, June, and September 2011.

4.11.12 Further details of the Transport Forum and the agenda items discussed at all meetings can be found in Chapter 2. Agendas and minutes of each Transport Forum meeting are available to view on the HPC Project website.

iii. Main Site Neighbourhood Forum

4.11.13 The Main Site Neighbourhood Forum was established in April 2011 at the request of residents living closest to the HPC Development Site to allow key issues to be discussed with those likely to be most affected.

4.11.14 Membership of the Forum includes representatives from the hamlets of Shurton, Burton, Knighton, Wick and Stolford, together with key stakeholders from the area. The invite to attend the Main Site Neighbourhood Forum was extended to Avon and Somerset constabulary following the Forum meeting in July 2011. Meetings have taken place outside the formal consultation periods in April, May, June, August and September 2011.

4.11.15 EDF Energy expects the Main Site Neighbourhood Forum to run for the duration of the construction of HPC, should consent be granted, and anticipates the need for the Main Site Neighbourhood Forum to be flexible, ensuring that it is fit for purpose for the communities neighbouring the HPC Development Site.

4.11.16 The above forums provide both EDF Energy and the local community with a clear method of communication on the key issues relating to the HPC Project. The forums have grown over time and are likely to continue to evolve as HPC progresses.

b) HPC Development Site Neighbourhood Engagement

i. Main Site Neighbourhood Support Scheme

4.11.17 The Main Site Neighbourhood Support Scheme was developed in early 2011 and published in May 2011 to address the concerns raised by residents and Stogursey Parish Council relating to the potential impact of the Hinkley Point C development on those living closest to the construction site.

4.11.18 The Main Site Neighbourhood Support Scheme includes a Property Price Support Scheme and a Noise Insulation Scheme. These respective schemes offer homeowners assistance should they wish to either sell their property or make noise insulation improvements to windows. There has been a significant level of interest from homeowners in the Main Site Neighbourhood Support Scheme with approximately 40 households (at September 2011) applying for window replacement noise insulation and over 30 registering to participate in the Property Price Support Scheme (at September 2011).




4.11.19 The concept for a Main Site Neighbourhood Support Scheme evolved from engagement with residents living closest to the HPC Development Site. The idea for developing a scheme was first shared with residents in June 2010 as part of the pre-application consultation for Site Preparation Works. The proposed schemes have been designed for those residents living nearest to the construction site. The final scheme was published and sent to residents in May 2011.

4.11.20 EDF Energy carried out a 28-day consultation on the scheme, aimed at those living within the four hamlets closest to the HPC site; Shurton, Burton, Knighton and Wick. The consultation document ‘Consultation on Local Mitigation Scheme and Property Price Support Scheme’ was sent directly to residents and parish, district and county councillors, together with a questionnaire inviting contributions and comments on the scheme’s proposals.

4.11.21 The consultation ran from 21 November to 21 December 2010 but was extended until 10 January 2011 at the request of residents, due to heavy snowfall, which affected the entire country. This consultation was carried out by EDF Energy on a voluntary basis and did not constitute part of the programme as detailed under the Statement of Community Consultation (SoCC). It is therefore not considered as ‘formal consultation’.

4.11.22 A public drop-in session was held, as part of the consultation, to allow residents to speak to EDF Energy staff about the scheme and to discuss their individual situations.

4.11.23 More than 100 residents were consulted and 250 questions and suggestions were received in response to the consultation. These comments were analysed and assessed by the EDF Energy project team and, where possible, changes were made as a result. A wide range of issues were raised and the main points are summarised below.

4.11.24 The hamlet of Stolford was not initially included in the proposed scheme due to its distance from the HPC site. Having received a number of comments stating that Stolford’s proximity to the site should make it eligible for the inclusion during the engagement, EDF Energy decided to expand the proposed boundary of the scheme to incorporate most of the hamlet.

4.11.25 Residents also commented that the need to “demonstrate hardship” to be eligible for the scheme was unfair. As a result, EDF Energy removed this criterion from the proposals.

4.11.26 A number of comments were received relating to EDF Energy’s involvement and responsibility to those who wished to sell their homes as a result of the HPC Project. For those wishing to move away, it was felt that EDF Energy should pay all costs incurred by the homeowner wishing to sell, and in the event that the house could not be sold, EDF Energy should buy it instead.

4.11.27 In response to the first point, EDF Energy has committed to pay a lump sum of £5,000 to residents wishing to move to help with the costs incurred. EDF Energy also explained to residents that it would consider the purchasing of houses that are unable to sell on a case-by-case basis.




4.11.28 Window cleaning was suggested in the initial consultation material as a measure to mitigate any dust generated from the site. However, it is considered that the on-site control mechanisms, e.g. dust suppression, would be sufficient and therefore window cleaning was not included in the final scheme. A commitment to promptly take action was given should unanticipated circumstances arise.

4.11.29 The local mitigation manager, who reports monthly to the Main Site Neighbourhood Forum, is the main liaison point for residents about the scheme and is available to discuss issues on a one-to-one basis at the request of local residents.

4.11.30 The Main Site Neighbourhood Support Scheme was published in May 2011 and would be activated on agreement of the conditions attached to the Site Preparation consent, as approved by WSC on 28 July 2011. The scheme, which is entirely voluntary, is separate to any entitlements property owners may have under the Land Compensation Act 1973 and will be reviewed within five years.

ii. HPC Development Site Resident Engagement

4.11.31 Early engagement with those residents living closest to the HPC Development Site (referred to as residents) began in summer 2009, ahead of Stage 1 consultation. EDF Energy sought to engage these residents early in the process and to continue an open dialogue throughout.

4.11.32 In addition to the formal stages of consultation, which many residents took an active role in contributing to, ongoing informal engagement also took place and will continue throughout the construction and operation of HPC, should permission be granted.

4.11.33 Meetings took place on an ad-hoc basis, largely led by the Project activities at the time and included public meetings, drop-in sessions, site visits and private meetings with individual residents on request.

4.11.34 Many of the issues raised by the residents reflect the formal comments received at the various stages of consultation and often centre on the impacts of the construction phase on those living in the vicinity of the development site. Site Preparation Works, the on-site accommodation campus and landscaping were also important issues to local residents.

4.11.35 Part of EDF Energy’s early engagement with the local residents involved a site walk-over, organised at the residents’ request, as a means for EDF Energy to gain an insight into local issues. One of the key areas raised during the walk-over involved the position of the southern construction boundary and its proximity to the hamlet of Shurton. This point was raised on a number of occasions, both formally and informally, and was of key concern to those living closest to the site.

4.11.36 A number of meetings were held with the main site residents to discuss this issue and the potential to move the boundary further north, away from the homes of local residents. As a result, EDF Energy significantly changed the construction boundary for both the site preparation works and the main construction phase, by permanently moving it north to gridline 144750mN.

4.11.37 Direct impacts of the construction phase on those living closest to the development site, namely the potential noise, dust and light impacts from the construction site and




on-site campus and the need to mitigate them, were frequently raised by local residents.

4.11.38 A significant amount of detailed work has been carried out by EDF Energy to assess the potential noise, dust and light impacts that could arise from the construction site. These impacts are addressed in the Environmental Statement submitted as part of this application, which details how EDF Energy plans to reduce and control these potential impacts.

4.11.39 Some residents remain concerned about these potential impacts, however, the Main Site Neighbourhood Support Scheme’s Noise Insulation Scheme responds directly to those concerns about increased noise levels from the construction site. The scheme, which also includes a Property Price Mitigation Scheme, was developed with input from residents of the four hamlets closest to the main site.

4.11.40 The rationale for, location and size of the proposed on-site campus was another key concern, with residents feeling that it should be removed completely from the proposals. This issue was raised both in formal consultation responses and in follow-up informal engagement meetings.

4.11.41 Whilst the on-site campus could not be removed completely from the proposals, EDF Energy has made significant amendments to both the transport and accommodation strategies for the Project in order to reduce the size of the on-site accommodation campus. Efforts were also made to site buildings in the most sensitive way possible so as to minimise the potential impact on local residents.

4.11.42 Local residents would still like to see the accommodation campus removed or relocated to another part of the site. EDF Energy has investigated all options thoroughly and when local views were balanced against engineering and land constraints, together with the need to reduce vehicle movements, it was concluded that the on-site accommodation campus is an essential component of the proposals.

4.11.43 EDF Energy has also worked closely with the residents on the screen planting proposals, which would provide visual mitigation for residents from both the on-site accommodation campus and the construction site activities. Early planting was an important issue for the residents as they felt that the maximum amount of growing time should be allowed prior to work starting to afford the most mature screening possible.

4.11.44 This issue was discussed in detail in early 2011 when EDF Energy met with development site residents and Stogursey Parish Council for input into the planting strategy. The residents felt strongly that early planting should take place in advance of the Site Preparation Works decision by WSC and that they should have an active roll in the planting strategy.

4.11.45 EDF Energy agreed to reprioritise its planting to ensure that it was brought forward as early in the programme as possible and organised a followed up site walk-over later in the year to get further input from residents. As a direct result of this engagement, the screen planting was extended to include the hamlet of Burton and requests for specific vegetation by residents were included where possible in to the plans. Stogursey Primary School was also involved in the planting, at the request of the residents who felt that it would be beneficial to the students, by relocating plants from Bishop’s Wood – an area that would be cleared should construction begin.




4.11.46 Weekly site visits were made available for local residents during the planting activity to enable further input and interaction between EDF Energy and neighbouring residents; approximately ten residents attended these sessions.

4.11.47 At many of the above meetings, residents commented that the EDF Energy public office in Bridgwater was too far away from the development site to be helpful. In response to this feedback, EDF Energy has arranged a weekly two-hour drop-in session (from 5 August 2011) in Stogursey, the nearest village to the site. This drop-in allows residents to speak face-to-face with EDF Energy staff on a regular basis in a forum that is dedicated to the issues most pertinent to them.

4.11.48 Residents closest to the HPC Development Site will continue to be engaged via the Main Site Neighbourhood Forum, the Community Forum and receive letters and newsletters providing site updates at relevant points in the Project. Should DCO be granted, public meetings and drop-ins are expected to continue throughout the construction phase, with individuals likely to continue their close working relationships with EDF Energy community engagement staff.

c) Parish Councils

4.11.49 As part of its ongoing engagement with local community representatives, EDF Energy met with local parish councils outside the formal consultation period on request. Cannington and Stogursey Parish Councils were engaged with most frequently, however, EDF Energy also met with representatives from other parish councils including Kilve, Otterhampton, Wembdon and Stockland Bristol Parish Councils.

4.11.50 Due to the significant input provided by Cannington and Stogursey Parish Councils during the pre-application process, further information on EDF Energy’s informal engagement with both is provided below.

i. Cannington Parish Council

4.11.51 Engagement with Cannington Parish Council began in 2009 to discuss the proposals for Hinkley Point C and its associated development. There has been significant formal public consultation since then and the Parish Council has contributed at each stage. In between the formal stages of consultation, EDF Energy’s engagement with Cannington Parish Council has been ongoing and will continue throughout the construction and operational phases of HPC, should permission be granted.

4.11.52 Initially, EDF Energy attended routine meetings in order to answer questions and provide updates when possible to attendees. However, as the proposals developed, it was agreed that EDF Energy would attend specific meetings, where HPC would be discussed, so as to allow sufficient time to discuss the subject and so the project would not overshadow other important Parish Council business.

4.11.53 In addition to EDF Energy attending these meetings, Cannington Parish Council is invited to attend both the Community and Transport Forums to discuss specific topics relating to the HPC proposals. To supplement this ongoing engagement, site visits were organised by EDF Energy to facilitate further contributions from the Parish Council members.




4.11.54 The initial proposals published at Stage 1 included a park and ride, freight management facility, worker accommodation campus and a bypass, to be developed in and around the village of Cannington. As such, EDF Energy’s engagement with Cannington Parish Council has been extensive and has covered a number of areas.

4.11.55 In response to the proposals published at Stage 1, Cannington Parish Council raised concerns about the proposals for worker accommodation for up to 320 people to be located in the village. This was lead by a number of issues, including the concern of over-stretched local facilities, such as the school. Worker behaviour was another issue, with the Parish Council concerned that an influx of HPC workers would result in increased anti-social behaviour.

4.11.56 The Stage 1 proposals also included a park and ride site for 900 vehicles and freight management facility in Cannington. The Parish Council had a number of concerns about these proposals, including the potential noise and light impacts on local residents and the impact that building on agricultural land would have on the village.

4.11.57 Following careful consideration of the responses received at Stage 1 and through informal engagement, EDF Energy removed proposals for all accommodation and freight management in Cannington. Whilst the park and ride could not be removed completely, its size was significantly reduced to 320 vehicle spaces to reduce the impact to the village. These decisions involved significant amendments to both the transport and accommodation strategies for the Project and were implemented due to the overwhelming feedback received from consultees.

4.11.58 The long-term focus of Cannington Parish Council’s concerns related to traffic and the proposed bypass. For example, the Parish Council was concerned that the Cannington bypass would not be successful in removing traffic from the village and that road users travelling to and from HPC would use Cannington as a ‘rat run’, cutting through the shorter route of the village, rather than using the bypass. To address these concerns, EDF Energy is proposing a number of improvements in Cannington, such as traffic calming measures, including a proposed speed restriction and pedestrian improvements through the village. Further information can be found in the Transport Assessment.

4.11.59 Two options for the Cannington bypass were proposed at Stage 1 as part of the ‘Initial Proposals and Options’ consultation; an eastern route and a western route. Partly as a result of the responses received to the consultation, EDF Energy elected to progress the western route of the bypass. However, at Stage 2, the Parish Council raised concerns about this proposed route, primarily due to the proximity of the route to residential dwellings and the perceived adverse noise, air quality and visual impacts that the bypass would create.

4.11.60 To help address the concerns of the Parish Council and local residents relating to the construction of the western bypass, EDF Energy held a Cannington bypass workshop in September 2010 to receive and consider feedback on detailed design issues. The input received was fed back to the project team and changes made where possible.

4.11.61 In response to the noise, air quality and visual impact concerns, EDF Energy carried out a number of impact assessments in the area and has proposed mitigation measures where appropriate. For example, stripped topsoil from the bypass corridor




would be used to form two-metre-high earth bunds, which will provide acoustic screening of vehicle movements on the bypass.

4.11.62 The Parish Council has, on a number of occasions, requested that the Cannington bypass be built in advance of any significant construction work starting on site to minimise the impacts to the village. EDF Energy is aware of the need to reduce, where possible, the potential impact to local people and is looking to minimise the time required to construct the bypass. Construction work at the main HPC Development Site, however, cannot wait until the bypass is complete, as it would significantly impact on the delivery of the Government’s target of increasing low-carbon energy generation by 2025.

4.11.63 In addition to commenting on the Cannington bypass, Cannington Parish Council has also requested that EDF Energy build a Bridgwater bypass from Junction 23 of the M5, which would bypass the village of Cannington completely, to avoid an increase in traffic on the C182 (the principal road to Hinkley Point and on which Cannington is situated). The Parish Council and many local residents are concerned that more traffic will increase the potential for accidents in the village.

4.11.64 The need for a Bridgwater bypass has been assessed in detail and EDF Energy’s reasons for not including it in the HPC proposals were provided at Stage 2 consultation. This was subsequently reviewed and confirmed at the Stage 2 Update consultation.

4.11.65 Whilst the issues set out above were discussed during EDF Energy’s informal engagement, they are also reflective of the Parish Council’s formal responses to each stage of formal consultation.

ii. Stogursey Parish Council

4.11.66 Engagement with Stogursey Parish Council began in 2009 to discuss the proposals for Hinkley Point C and its associated development. As the parish within which the HPC Development Site is situated, Stogursey Parish Council has engaged significantly with EDF Energy at all stages of formal consultation and has been forthcoming with input during the informal engagement on proposals.

4.11.67 As with Cannington Parish Council, EDF Energy initially attended routine Parish Council meetings in order to answer questions and provide updates to attendees. However, as the proposals developed, it was agreed that EDF Energy would attend specific meetings, where proposals for HPC were the main agenda item.

4.11.68 Since the Main Site Neighbourhood Forum was established in April 2011, at the request of Stogursey Parish Council and residents, much of EDF Energy’s engagement with the Parish Council on HPC-related issues has been conducted via this Forum, which members attend on a regular basis. The Parish Council is also represented at the Transport Forum and quarterly Community Forum. The information below provides a summary of the engagement carried out in advance of these forums being established.

4.11.69 To facilitate constructive dialogue with the Parish Council and local residents, EDF Energy organised a number of public drop-ins and site visits, allowing the opportunity for questions to be answered directly by members of the EDF Energy project team.




Parish Council members were also engaged via telephone, written correspondence and one-to-one meetings.

4.11.70 The key issues raised in relation to the likely impacts on the Parish of Stogursey related principally to the position of the construction boundary, the on-site accommodation campus and potential impacts of construction on residents in the vicinity of the site. Many of the issues described below reiterate the points raised through the local resident engagement (see HPC Development Site Resident Engagement in this chapter) or were included in the Parish Council’s formal consultation responses.

4.11.71 In 2009, early in the engagement process, Stogursey Parish Council highlighted that the proximity of the southern construction boundary was a significant concern for the residents of Shurton, the hamlet neighbouring the southern boundary of the proposed site. This point was raised on a number of different occasions, both informally and in response to the Stage 1 consultation proposals by the Parish Council and local residents.

4.11.72 Having taken account of the feedback received on the subject, EDF Energy agreed to significantly alter the construction boundary by permanently moving it north to gridline 144750mN for the duration of the construction period, including the Site Preparation Works. The construction site, as a result, has been distanced from homes, thus reducing the likely impacts to local residents. EDF Energy informed the Parish Council and residents of the change by letter, sent June 2010.

4.11.73 Proximity of the on-site accommodation campus was also a concern for the Parish Council which, from early 2010, questioned the rationale, size and location of the facility. The Parish Council, and its parishioners, suggested that the accommodation campus be removed completely from the HPC proposals, or relocated elsewhere on the site.

4.11.74 A number of meetings were held by EDF Energy post-Stage 1 to discuss local concerns about the on-site accommodation campus and the potential solutions. EDF Energy investigated the options thoroughly but when engineering and land constraints were balanced against the need to decrease vehicle movements, it was concluded that the on-site accommodation campus was an essential component of the proposals. Significant work was, however, undertaken to decrease the size of the facility by amending both the transport and accommodation strategies for the whole Project.

4.11.75 In advance of Stage 2 consultation, on-site investigative works were undertaken to understand the ground conditions along the southern boundary of the proposed construction site. The Parish Council raised concerns about the level and duration of noise being generated whilst drilling work was undertaken and the inconvenience this noise was causing the residents of Shurton.

4.11.76 On receiving this feedback, EDF Energy erected acoustic barriers around the machinery to reduce the noise impacts of the work. A site visit was subsequently organised for Parish Council members and residents, to demonstrate the actions being taken to reduce the noise impacts from the investigative work. Drop-in sessions and written correspondence were also implemented in advance of and during the investigatory works to provide updates to those living in the vicinity.




4.11.77 Direct impacts of the construction site, such as dust, light and noise, on local residents’ quality of life is an ongoing concern of the Parish Council, as is the issue of property prices and the need for adequate mitigation against potential loss in value. In response to these concerns, EDF Energy developed the Main Site Neighbourhood Support Scheme, which includes a Property Price Support Scheme and a Noise Insulation Scheme. Stogursey Parish Council was consulted on the scheme prior to it being published in May 2011. More information on the Main Site Neighbourhood Support Scheme, which was published in May 2011, can be found in this chapter.

4.11.78 Stogursey Parish Council will continue to be engaged via the Main Site Neighbourhood Forum and the Community Forum, as well as receiving letters and newsletters. There are also likely to be more meetings and drop-ins to engage with parish councillors and local residents when construction begins, subject to consent being granted.

d) Elected Representatives Engagement

4.11.79 The head of EDF Energy’s Bridgwater office has had a central role in the engagement with local councillors and Members of Parliament on the proposals for Hinkley Point C. Engagement began in 2009 and continued throughout the formal stages of consultation. EDF Energy expects engagement to be ongoing throughout the construction of the HPC development and beyond, should consent be granted.

4.11.80 The frequency of meetings was largely dependent on the maturity and development of the proposals. When the proposals were in the early stages there was less detailed information to share, but as the plans evolved and more information became available, wider engagement with councillors and MPs took place.

4.11.81 Frequent engagement with individual district and county councillors, particularly those representing Sedgemoor District, Somerset County and West Somerset Councils also took place outside the formal consultation periods. MPs were generally keen to stay abreast of all major developments and wanted to understand the progress of the proposals and to maximise opportunities for, and minimise potential impacts on, their constituents. Meetings were typically held on an informal, one-to-one basis in EDF Energy’s Bridgwater office. It is important to note that the majority of topics raised informally were reflected in formal consultation responses.

4.11.82 A number of meetings and briefings took place, both formally and informally, with specific party political groups, whilst others were held with all the major political parties present. In addition to the formal briefings and meetings with EDF Energy, site tours were also offered to councillors and MPs ensuring they were able to walk the areas potentially affected by EDF Energy’s proposals.

4.11.83 EDF Energy also hosted an information gathering visit to Flamanville 3, the nuclear power station currently under construction in Normandy, France, for members and officers of SCC, WSC and SDC in April 2010.

4.11.84 EDF Energy endeavoured to give MPs advanced warning of Project developments in order to help them in answering their constituents’ questions and to direct them to the relevant information provided during the consultation stages.

4.11.85 EDF Energy was flexible in its approach to councillor engagement as different authorities had different mechanisms for keeping their members informed. EDF




Energy worked with council officers to tailor the engagement to individual organisations’ needs and always endeavoured to keep councillors fully informed about the progress of the proposals.

4.11.86 Following the General Election in 2010, Government Ministers, including the Secretary of State and Minister of State at the Department for Energy and Climate Change; the Secretary of State for Business, Innovation and Skills; the Secretary of State for Communities and Local Government; and Ministers in HM Treasury were kept abreast of the HPC developments, with Project updates provided where appropriate. The Secretary of State for Energy and Climate Change also visited the HPC site for an in-depth explanation of the plans and the stages of development.

4.11.87 Similar briefings were also extended to MPs and Peers interested in the energy sector, MPs with an EDF Energy site in their constituency, and the Labour Shadow Energy and Climate Change team, Shadow DCLG team, Shadow BIS team and Shadow Treasury team.

4.11.88 Councillors and MPs are the elected representatives for the local communities surrounding HPC, so effective engagement was essential to ensure EDF Energy accurately understands the communities’ concerns and aspirations and to ensure that elected representatives have access to relevant information on the Project. EDF Energy will continue to actively engage councillors and MPs as the Project progresses.

e) Consultation by the Young Advisors

4.11.89 EDF Energy met with the West Somerset Young Advisors on 16 February 2011. Recruited and trained by the Young Advisors national charity, the group based in Minehead consists of eight young people, aged between 15 and 21, who help community leaders and decision-makers to engage with young people.

4.11.90 As part of its commitment to engage with ‘hard to reach’ groups, EDF Energy decided to commission the West Somerset Young Advisors to undertake a programme of consultation with young people in the area to find out their views on the Project. Full details of EDF Energy’s overall consultation with ‘hard to reach’ groups is shown in Chapter 2.

4.11.91 The Young Advisors undertook two separate consultations. The first at West Somerset Community College in Minehead took place in March 2011. The Young Advisors participated in college assemblies, held an open day and ran a series of focus groups with all year groups. A final ‘wash up’ session was also held at the end of the consultation process, attended by two representatives from EDF Energy. Their key findings were:

young people had a basic knowledge that the development was proposed;

there was a low level of interest which increased with more information;

transport was the biggest and most obvious concern;

employment opportunities had the greatest positive interest;

interest in housing issues increased as more information was provided; and

young people were keen on potential benefits, particularly in relation to leisure.




4.11.92 A similar consultation exercise was undertaken by the Young Advisors at East Bridgwater Community, situated in Sydenham ward in Bridgwater, during June 2011. The consultation was undertaken intensively during a single day incorporating eight separate consultations with approximately 25 students in each session. Their key findings are briefly summarised below:

a very low level of knowledge about Hinkley Point and the proposed development;

practical issues predominated, rather than the principle of nuclear power;

housing was a topical issue with suggestions that empty homes should be used and concern about the strain on existing infrastructure;

while bypass options were dismissed, there were particular concerns about the Cross Rifles roundabout in Bridgwater and road safety;

little understanding of the type of employment opportunities that might be available during construction and how these might be accessed;

social integration issues centred around perceived capacity and overcrowding in Bridgwater; and

strong feeling that the community wanted a new swimming pool, improved parks and leisure facilities with ‘somewhere to go and something to do’ for teenagers.

4.11.93 The full reports and recommendations from the Young Advisors, together with EDF Energy’s response, are shown in Appendix F.

4.11.94 As detailed in Chapter 2 of this report, EDF Energy engaged with students of local schools and colleges. These events were organised through tutors at Bridgwater College (October 2009 and June 2010), West Somerset College (March 2010) and Robert Blake Science School (November 2010). The issues raised in these student workshops largely echo those made by other consultees during the consultation process and EDF Energy’s response is set out in the topic responses in this report (Appendix H).




4.12 Business and Supply Chain Stakeholders

4.12.1 EDF Energy has built relationships with the local business community in Somerset to help communicate the requirements of nuclear new build, and to explain how to access the supply chain opportunities that the construction and operation of Hinkley Point C would present.

4.12.2 This section addresses EDF Energy’s engagement with stakeholders involved in the business community, such as the Somerset local authorities and business support agencies. The main focus is on EDF Energy’s work and engagement with the Local Business Engagement Forum, the Somerset Chamber of Commerce and Somerset local authorities.

a) Local Business Engagement Forum

4.12.3 Early in 2010 meetings were held with local business stakeholders, the Somerset local authorities and the South West Regional Development Agency (SWRDA) with the aim of practically supporting and implementing the proposed procurement strategy outlined in Stage 1 consultation on ‘Initial Proposals and Options’ (November 2009). It was agreed during these early meetings to constitute a formal forum of business stakeholders to ensure that Somerset companies would have the best opportunity to gain access to the HPC supply chain.

4.12.4 Details on the activities of the Business Engagement Forum were given in the Stage 2 Update consultation in February 2011. The work of the Forum included overseeing the development of a local supplier register, developing programmes for business support and communicating the progress of Project procurement activities. A programme of visits to Somerset businesses was also developed, as well as an events programme to communicate the opportunities likely to arise for Somerset businesses.

4.12.5 The membership of the Forum is made up of representatives from EDF Energy (chair), Sedgemoor District, Somerset County and West Somerset Councils, “Into Somerset” Somerset Chamber of Commerce, SWRDA, Bridgwater Industrialists, Business Link and the Southwest Manufacturing Advisory Service. The terms of reference were agreed by the Forum and its core purpose is “to work with SCC, WSC and SDC, the local business community and agencies to promote the engagement of companies local to the proposed HPC development.”

4.12.6 Recently Taunton Deane Borough Council and Construction Skills have been invited to become members of the Forum. It is also expected that the main site contractors will be invited to attend the Local Business Engagement Forum on appointment.

4.12.7 Originally the scope of the Forum covered employment, education and skills development. The different membership and additional time required to consult effectively on skills development has resulted in this subject being covered by a separate meeting, held on the same day after the Local Business Engagement Forum. All key actions are documented and followed up at subsequent meetings by permanent members.

4.12.8 The Local Business Engagement Forum has provided valuable insight and advice to local suppliers and has promoted the engagement activities led by EDF Energy and the Somerset Chamber of Commerce. In addition, members have supported events




and direct supplier engagement, and have helped to ensure that the benefits of the Project and the routes to becoming involved are communicated to their network of Somerset businesses.

4.12.9 With respect to the issues and concerns raised at the Local Business Engagement Forum, EDF Energy (working with members of the Forum) has undertaken the following activities:

4.12.10 Business Opportunities: The nature of the work that might be available to local businesses has been communicated to them at a number of EDF Energy-sponsored events, via one-to-one visits and via regular newsletters to local suppliers. This approach is likely to be continued throughout the construction phase.

4.12.11 Communication Channels: The nature and scope of information shared with local businesses has been driven by the Project programme. Initially information on registering an interest in participating in the supply chain and general Project timescales were provided via the Somerset Chamber of Commerce website on behalf of EDF Energy. As the Project procurement requirements have been released these details have become more specific. Future communication of procurement needs will be aligned with the requirements of prime (Tier 1) contractors and EDF Energy will use the contacts registered through the Somerset Chamber of Commerce website to put Somerset suppliers in touch with the Tier 1 contractors quickly and easily.

4.12.12 Business Risks: The forum has expressed concern that the Project may cause a boom and bust economy and that local businesses may lose skilled staff to the Project, thus weakening the existing local economy. EDF Energy has been working with local education providers to support training and skills in the local community and has developed a Construction Workforce Development Strategy to create a sustainable job pipeline. The development of long-term knowledge-based industries that can support HPC during the operational phase is seen as a way of avoiding an economic downturn after the construction phase.

4.12.13 Availability of business premises: A database of commercial premises has been developed by the Somerset local authorities, with the support of EDF Energy, and this will be accessible via the Somerset Chamber of Commerce web site and, potentially, other channels.

4.12.14 Development of Tier 1 Supply Chain: EDF Energy has already invited Tier 1 contractors to present at the Local Business Engagement Forum. This provided an opportunity to local stakeholders to discuss work content and allow the Tier 1 contractors to explain their approach to local business community support. It is expected that this will continue as further Tier 1 contracts are confirmed.

4.12.15 Business Support: The business support organisations, such as the Somerset Chamber of Commerce and the Manufacturing Advisory Service (MAS), are members on the Local Business Engagement Forum and hence have been able to support EDF Energy-sponsored events and EDF Energy visits to local suppliers. This has provided those businesses, wishing to improve, with direct access to support and in some instances gain access to funding. Following EDF Energy supplier visits, a number of Somerset companies have embarked on business improvement programmes leading toward ISO certification.




4.12.16 The Local Business Engagement Forum will continue to support the Somerset business community and will evolve as the Project develops. The long-term aim is to support sustainable business growth within the region.

b) Somerset Chamber of Commerce

4.12.17 Early in 2010 meetings were held with Somerset business stakeholders, the Somerset local authorities and the SWRDA with the aim of practically supporting and implementing the proposed procurement strategy outlined in Stage 1 consultation on ‘Initial Proposals and Options’ (November 2009). As well as agreeing to establish the Local Business Engagement Forum, these meetings resulted in the decision by EDF Energy to work with the Somerset Chamber of Commerce to deliver a strong Somerset supply chain solution to support HPC construction.

4.12.18 Since mid-2010, fortnightly meetings have been held between the Somerset Chamber of Commerce project team and EDF Energy. Meetings have been supplemented by regular correspondence in the form of telephone calls and emails.

4.12.19 It is important to note that the operators of the nuclear power stations at Hinkley Point have worked closely with the Somerset Chamber of Commerce for many years. EDF Energy has developed a strong working partnership with the Chamber that has resulted in effective communication with Somerset businesses and the organisation of several local business support events.

4.12.20 An agreement between EDF Energy and the Somerset Chamber of Commerce places the Chamber as the focus for Somerset businesses enquiring about the HPC Project, with those enquiries handled in the most appropriate and effective way for all stakeholders. Through EDF Energy’s continued engagement with the Chamber of Commerce, a number of key issues have emerged that have helped to shape the procurement strategy outlined in consultation and to achieve the objectives set by the Local Business Engagement Forum.

4.12.21 A key issue for the Chamber of Commerce was the identification of suppliers and how EDF Energy would facilitate this. A supplier database was developed (www.hinkleysupplychain.co.uk) by the Chamber, as requested by EDF Energy and discussed by the Local Business Engagement Forum. This information has been and will continue to be used as a shop window to the Tier 1 contractors appointed to undertake the major works. It is also intended to support the Tier 1 contractors in developing their supply chains and provide Somerset businesses with the visibility of up-coming work opportunities so that they are in a position to bid for work.

4.12.22 As of October 2011, a total of 734 Somerset company registrations were held on the system, with details of a further 176 South West companies and 89 UK companies also held.

4.12.23 Assessment of local businesses by the Somerset Chamber of Commerce has been limited to verifying company details recorded on the registration portal. The Somerset Chamber of Commerce team also offer a service to Tier 1 bidders, to search the database to identify Somerset businesses that have specific skills to undertake the work they may require. Other supplier assessments of capability and capacity are carried out by the Tier 1 contractors in line with standard vendor pre-qualification processes. The Somerset Chamber of Commerce is not involved in this activity.




4.12.24 The question of what is ‘local’ in the context of the Local Business Engagement Strategy has been raised during all stages of the consultation. Since Stage 2 consultation, following feedback from a range of stakeholders and in discussion with the members of the Local Business Engagement Forum, the local engagement boundary has been extended to include the North Somerset region (excluding Bristol and Bath). This extends the engagement boundary to cover Weston-Super-Mare, which was outside original Somerset administrative boundary zone but less than 10 miles from the site.

4.12.25 Supporting local business has been a key topic for the Somerset Chamber of Commerce who, in conjunction with EDF Energy, organised a number of events to support the engagement and development of Somerset suppliers. The scope of future events will be adjusted according to the Project needs. All post-event participant feedback has been very positive and it is anticipated that similar events will be organised following the DCO application and throughout the construction of HPC.

4.12.26 Communications with local businesses is also an important issue and the HPC supply chain website www.hinkleysupplychain.co.uk has been used to communicate relevant Project updates and procurement details. As the Project develops EDF Energy and the Somerset Chamber of Commerce will continue to regularly communicate with the Somerset group of companies. Currently this is occurring bi-monthly however the frequency will be adjusted in line with Project demands.

c) Local Authority Engagement on Supply Chain Issues

4.12.27 Sedgemoor District, Somerset County and West Somerset Councils are all represented on the Local Business Engagement Forum.

4.12.28 Since September 2010 EDF Energy has participated in a number of council-led groups, or held meetings with council business development teams separately from the Forum, as and when requested. It is anticipated that these activities will continue throughout the period of the Project.

4.12.29 The council-led meetings have typically taken place on a quarterly basis or as one-off conferences. The events have had synergy with the activities of the Local Business Engagement Forum.

4.12.30 The following council led meetings were held:

Sedgemoor Business Forum – Two meetings in Sedgemoor in September and December 2010;

Bridgwater Challenge Partnership Board – Meetings in Bridgwater every quarter from November 2010;

West Somerset Economic Conference at Danesfield School, Williton in November 2010;

Sedgemoor Economic Conference at The Exchange, Bridgwater in November 2010; and

Sedgemoor Food and Drink Conference at Canalside, Bridgwater in March 2011.




4.12.31 In all of the above EDF Energy has been a participant, and has usually provided a briefing on the status of the Project and procurement activities.

4.12.32 Meetings also took place with West Somerset Council and Taunton Deane Borough Council business development teams. These have taken place to ensure access to information on the opportunities in the supply chain to companies within these areas.

4.12.33 During the council-led meetings, issues relating to other work streams, such as accommodation and transport were raised. The EDF Energy strategy for local business engagement was generally well received. EDF Energy noted concerns that it was too early to determine whether these activities would create the business opportunities it described. It was able to illustrate the local benefits arising from the work on the HPC site. EDF Energy will continue to brief and inform local stakeholder groups on the benefits of the Project and the route to market for smaller companies.

4.12.34 It is anticipated that EDF Energy will continue to support these local authority-led groups following the submission of the DCO application and throughout the construction phase of the HPC Project and beyond.

d) Other Business Representative Groups

4.12.35 Since the launch of Stage 1 consultation on ‘Initial Proposals and Options’ in November 2009, requests have been received by EDF Energy from a variety of business representative groups for information on the HPC Project and the opportunities that might arise for local and regional businesses. After the detailed proposals were published in the Stage 2 and Stage 2 Update consultation the frequency of these requests has increased.

4.12.36 Approximately two presentations each month are now being given to Somerset stakeholder groups on the Project timescales, and how local businesses can become involved in the HPC Project.

4.12.37 The presentations have been generally well received and generated many questions from the audience. The most frequently asked questions relate to the Project planning timescales, the opportunities available to Somerset businesses and additional clarification on the actual work content. In most cases these were addressed, however some could not be answered at this stage in the Project.




4.13 Telephone Surveys

4.13.1 Two telephone surveys were commissioned and undertaken during the pre-application consultation period to assess local attitudes towards the nuclear industry and the Hinkley Point C Project in particular.

4.13.2 The surveys were undertaken, on behalf of EDF Energy, by independent research company ICM, a member of the Market Research Society. On each occasion ICM interviewed a representative sample of more than 1,000 adults, aged 18+ and living in the districts of Sedgemoor, Taunton Deane and West Somerset. The data was weighted to the profile of the local population.

a) First Survey

4.13.3 The first poll was carried out by telephone between 24 and 28 September 2010 during, but separate from, the Stage 2 consultation. The results were published on 15 October 2010 in a press release on the full research findings. This was available to download from the Project website www.edfenergyconsultation.info

4.13.4 The survey showed that 85% of respondents living within about 25 miles of Hinkley Point thought that the Project was important for local jobs and nearly two thirds (63%) said it is important for the future of businesses in the area.

4.13.5 A total of 63%, within 25 miles of Hinkley Point, supported the development of the new power station and support became stronger amongst people living closer to the station, with levels rising to 66% support within 10 miles. Only 17% said that they opposed a new nuclear power station.

4.13.6 More than three quarters (77%) of local people believed that the country needs nuclear power as part of the energy mix. Just 14% disagreed.

4.13.7 The full survey results are shown in Appendix E.

b) Second Survey

4.13.8 The second poll focused solely on an examination of local views of EDF Energy’s proposed community investment. This assessed whether the proposed levels of investment were adequate and invited comments on the areas of community need that could most benefit from the increased level of Community Fund proposed.

4.13.9 The survey was undertaken by telephone between 30 March and 7 April 2011 and published on 20 April 2011. A press release was issued and published on the Project website www.edfenergyconsultation.info – see Appendix C.

4.13.10 The research showed that 75% of respondents thought that EDF Energy’s proposed £100 million of investment would have an impact in the area, with 53% saying it would have a big impact. Only 9% say it would have no impact.

4.13.11 As part of the £100 million investment, EDF Energy has proposed a £20 million Community Fund, which was increased from £1 million after consultation.

4.13.12 Almost two thirds of people considered the increased sum to be about right (54%) or too big (9%), with just 17% saying it was too small.




4.13.13 The survey also canvassed views on where the Community Fund should be spent. The favoured areas were: recreational facilities for children and young people; community amenities; education; and transport.

4.13.14 The results are shown in Appendix E.

4.13.15 Future polling in Somerset is planned to gauge any changing attitudes and to capture any emerging issues that might need to be addressed.

CHAPTER 5: CONSULTEE RESPONSE ANALYSIS

Consultee Response Analysis | October 2011 1

CONTENTS

5. CONSULTEE RESPONSE ANALYSIS ...........................................................................3

5.1 Introduction......................................................................................................................3

5.2 Qualitative Analysis Methodology – Schedule of Responses ..........................................4

5.3 Public Reference Tracking System..................................................................................9

5.4 External Surveys, Petitions and Standard Campaign Letters ........................................10

5.5 Response Sources ........................................................................................................11

TABLES

Table 5.1: Consultation Responses Received by Consultation Stage .........................................3

Table 5.2: Hinkley Point C Main (Development) Site Theme Framework – Illustrative Example..4

Table 5.3: Definition of Tickbox Options.......................................................................................6

Table 5.4: Schedule of Responses Terminology..........................................................................7

2 Consultee Response Analysis | October 2011


Consultee Response Analysis] | October 2011 3

5. CONSULTEE RESPONSE ANALYSIS

5.1 Introduction

5.1.1 To present the issues raised and EDF Energy’s responses to them, EDF Energy has devised a detailed process for categorising and analysing the thousands of consultation responses received during the formal consultation stages. This process has enabled EDF Energy to fulfil its duty to take account of responses received, as set out in s49 of the Planning Act 2008, (s37(7)) and in a form which is consistent with IPC Guidance Note 1.

5.1.2 The aim of this chapter is to outline the methodology behind this analysis and to explain how statutory consultees, other relevant stakeholders and the local community and general public can identify EDF Energy’s replies to their consultation responses.

5.1.3 More than 2,000 responses were received from consultees over the formal consultation stages (see Table 5.1). These responses varied in length and detail, with some being very technical, whilst others were brief, for example simply expressing support for, or objection to, the development proposals.

Table 5.1: Consultation Responses Received by Consultation Stage

Consultation Stage Public Responses –

Questionnaires

Public Responses –

Email, Letter Phone

Statutory and Other

Interested

Stakeholders’

Responses

Stage 1 472 154 54

Stage 2 541 303 79

Stage 2 Update 159 69 77

Junction 24 and Highways

Improvements

90 31 33

TOTAL 1,262 557 243

5.1.4 EDF Energy has processed these responses and categorised almost 33000 comments on a range of different issues on the Hinkley Point C (HPC) Project, including the associated development proposals.

5.1.5 The comments have been categorised in a Schedule of Responses according to the issues raised and grouped together into ‘topics’ (see Appendix H). Each topic contains a group of related comments; therefore EDF Energy has provided one overarching response per topic. This enables the reader to look at/study the detailed comments received within each topic and how EDF Energy has responded to the set of comments received. A consultee comment key has been created (see Appendix H) to help consultees identify how their individual comments have been categorised.

5.1.6 Within the Schedule of Responses, EDF Energy has provided acknowledgement of each individual comment received. This is represented through a ‘tickbox’ table


which, presented alongside each comment, reflects how the proposals or EDF Energy’s actions may or may not have changed following the particular consultation stage to which the consultee responded.

5.1.7 The Qualitative Analysis Methodology section below provides detail of how the comments have been identified, categorised, acknowledged and responded to.

5.2 Qualitative Analysis Methodology – Schedule of Responses

5.2.1 Each consultation response received during the formal consultation stages has been taken into account when developing the proposals for the HPC Project. In order to acknowledge all of these responses and demonstrate EDF Energy’s response to the issues they raise, a Schedule of Responses has been created (see Appendix H).

a) Schedule of Responses Framework

5.2.2 A categorisation framework was created to organise all the comments received and extracted from the consultee responses into a descending hierarchy of theme/category/topic, based on the HPC Project proposals and the identified issues.

5.2.3 This framework divides up the consultation comments into 24 overarching ‘Themes’ such as Accommodation, Transport, and individual Associated Development sites, which in turn are divided into ‘Categories’, often based on Environmental Impact Assessment areas, and which were further divided into a final ‘topic’ grouping allowing for a narrowing down or ‘sorting’ of responses. As an example, the Hinkley Point C Main (Development) Site theme is provided in Table 5.2. For the full framework, see Appendix H. In total, 1,256 topics were created to contain all of the

comments received across all formal consultation stages.

5.2.4 As necessary, the framework was adapted to accept new comments that raised unique and/or emerging issues that could not fit within an existing topic, and which came about during the consultation process. In particular, where the proposals evolved to include new or alternative associated development sites and uses such as the park and rides and campuses, it was necessary to include topics covering ‘discounted sites’ and ‘discounted uses.’ On the majority of occasions, these sit within the Associated Development sites, but in the case of the Bridgwater sites, there is a separate Theme called ‘Bridgwater (Discounted).’ Any comments sitting within these topics are not themselves discounted and are considered as important as any other consultation comment.

Table 5.2: Hinkley Point C Main (Development) Site Theme Framework – Illustrative Example

Theme Category Topic

Construction Impacts

Construction Land Use

Emergency Planning (during construction)

Landscaping (during construction)

Hinkley Point C Development Site

Construction

Lighting


Theme Category Topic

Overall Construction Strategy and

Programme

Watercourse Management Construction

Working Hours

Buildings and Structures

External Works

Landscaping and Restoration

Lighting

Masterplanning

On-site Transport and Access

Overhead Line Infrastructure (On-site and National Grid)

Masterplan, Design and

Landscaping

Utilities, Services and Drainage

Emergency Planning

Outages

Safety Operational Considerations

UK EPR Design

Consultation Other

Sustainability

Applications for Site Preparation Works

and Temporary Jetty

Cumulative and In Combination Effects

Environmental Management

Impacts, Assessment and Mitigation

Landscape Reinstatement

Preliminary Works

Temporary Jetty Use and Design

Availability of UK Waste Management and

Disposal Facilities

Clarification of Terminology

Decay Storage

Decommissioning Waste Management

Effluent Treatment Building and Interim

Storage Facility

Health & Safety Executive Statement

Hinkley Point C Waste Strategy

Management of Waste and Spent Fuel

from Other Nuclear Facilities

On-site Waste Storage

Hinkley Point C Development Site

Spent Fuel and Radioactive

Waste

Transport of Waste


5.2.5 All related comments are grouped together under each topic. For example, where consultees have made comments on the proposed transport strategy, specifically in relation to the Cannington bypass, these will have been organised in the grouping ‘Transport-Transport Strategy-Cannington Bypass,’ (i.e. Theme-Category-Topic).

5.2.6 Many comments contained multiple issues that were related and often interdependent, meaning that they did not always belong in a single topic. Splitting the comment into the individual issues would, in many cases, have resulted in a loss of context for the reader; therefore a process of multi-categorisation was pursued.

5.2.7 Multi-categorisation means that one comment could be categorised in more than one topic where it was impossible or undesirable to split it apart. For example, a consultee could be commenting on the overall transport strategy in relation to the Cannington Bypass, but in addition might also be commenting upon the impact to the surrounding area of the bypass. Therefore, in addition to the comment being placed in the Transport Theme, it would also be categorised in Cannington Bypass-Socio-economics-Impact.

5.2.8 EDF Energy has aimed to answer the relevant issues in each of the different topic responses, allowing all of the issues to be appropriately addressed. EDF Energy’s guiding criterion has been to be systematic in approach and to be as thorough as possible.

b) Acknowledgement of Comments

5.2.9 Following IPC guidance on the importance of acknowledging all consultee responses, EDF Energy has shown how it has taken account of, and made individual decisions in relation to, each comment. Set against every comment in the Schedule of Responses are three tickboxes designed to illustrate these decisions: Change/Confirmation of Intent, No Change, and Noted (see Table 5.3).

Table 5.3: Definition of Tickbox Options

Tickbox Definition

Change/Confirmation of Intent Ticked for stated or implied requests for a change and where a change has been made by EDF Energy to either the scheme (e.g. siting, route, design, form, scale), to the methodology applied, to the mitigation measures proposed or to any compensation measures proposed. Requests for information that led to further studies/changes to mitigation or any compensation measures also fall within this category.

Also ticked even if EDF Energy would have made the change or undertaken the requested action in any event, regardless of the comment having been made e.g. where comments at Stage 1 request the need for further studies which would have automatically followed at Stage 2 as the proposals progressed or were possibly even already underway.

No Change Ticked where a comment requested/suggested a change to the proposals (either explicitly or implied) and no change has been made in response.


Tickbox Definition

Noted Ticked primarily where statements have been made, whether

positive, negative or neutral, about the proposals or related

issues that do not require a response.

Also ticked where the respondent has misunderstood the

proposals and therefore it would not be appropriate to tick

Change or No Change.

NB. ‘Noted’ is as important a tickbox category as the other two

options and EDF Energy is acknowledging here that the

consultee comment has been taken into consideration.

c) EDF Energy Responses

5.2.10 As described in the above sections, the identified comments from the consultation responses have been organised into topics. These topics are groups of comments brought together under one heading in order to allow EDF Energy to provide one overarching response to the issues raised in each of the topics. This approach avoids excessive repetition of EDF Energy’s response where many respondents made similar comments.

5.2.11 Therefore, as there are 1,256 topics containing comments, there are also 1,256 EDF Energy responses.

5.2.12 These responses are set against the comments and tickboxes in the Schedule of Responses, thereby allowing the reader to view the individual comment, the associated tickbox decision to the individual comment and the overarching response from EDF Energy to the topic.

d) Terminology and Layout

5.2.13 An explanation of the terminology used in the Schedule of Responses can be seen in Table 5.4 below.

Table 5.4: Schedule of Responses Terminology

Term Definition

Consultation Response The complete/full response received from consultees during formal stages of consultation.

Comment An identified comment extracted from the Consultation Response and placed in the Schedule of Responses.

Theme The upper tier of comment categorisation in the Schedule of

Responses on a site-by-site or strategic level basis.

Category The middle tier of comment categorisation in the Schedule of

Responses.

Topic The lowest tier of comment categorisation in the Schedule of

Responses.

EDF Energy Response EDF Energy’s response to the issues raised by consultees.


Term Definition

Tickbox A choice of three different acknowledgements from EDF Energy

of the individual comments from consultees:

Change/Confirmation of Intent; No Change; Noted. These are

displayed in the Schedule of Responses.

Tickbox Decision EDF Energy’s specific acknowledgement of an individual

comment.

5.2.14 The Schedule of Responses contains the following information in each column:

• Respondent (consultee) reference: this shows the name of the organisation or a reference number, for example Tractivity 1234.

• Respondent type: this shows if the respondent is a local authority (s42b of the

Act), statutory consultee (s42(a) and 42(aa) of the Act), other relevant stakeholder, member of the public (including local community and general public) (s47 and s48) and if they have an interest in land (either for the Hinkley Point C development site or any of the associated development sites) (s42(d)). It also shows if the comment comes via a referral from the IPC, meaning EDF Energy is not aware of the respondent type.

• Consultation Stage: Stage 1, Stage 2, Stage 2 Update or Junction 24 and

Highways Improvements.

• Comment: this provides the extracted verbatim comment on the topic being considered.

• Comment ID: A reference number used by EDF Energy for internal purposes.

• Tickboxes: A comment specific tick, allowing EDF Energy to acknowledge each comment, showing where comments have been followed by change, no change or been noted.

• EDF Energy’s Response: this provides EDF Energy’s response to the group of comments in each topic.

e) Comment Identification

i. General

5.2.15 Consultation responses at each of the formal stages of consultation varied in length from short letters and questionnaires, often returned by the local community and public, to extensive and detailed technical responses received from statutory consultees and others.

5.2.16 EDF Energy was supported by a specialist data analysis company to help identify individual comments and then place them into the Schedule of Responses Framework described. This process of identification resulted in almost 33,000 comments being categorised and presented in the Schedule of Responses (Appendix H).

5.2.17 The comments have each been transferred directly into the Schedule of Responses, with no amendments made to spelling mistakes or other errors from the original documents. This does mean that, on occasion, a comment can appear to be


incorrectly displayed through there being only partial sentences or comments that do not seem to make sense. On a few occasions, this can be due to where a consultee has run out of room in the online questionnaire, whilst at other times the verbatim incomplete statement is simply all that the consultee wrote.

5.2.18 Many of the comments include a number or question at the beginning of the comment that were not written by the consultee. These refer to the questions in the formal consultation stage questionnaires and are provided to give context where a consultee is responding to a specific question. It is clearly stated at which stage of consultation a comment has been made, and the questionnaires are available to cross-reference against in Appendix C of this report.

5.2.19 Some comments may appear to be duplicated within one topic. This has occurred where a consultee may have said the same thing twice in their consultation response or where the IPC has received responses direct and then forwarded them to EDF Energy for consideration. For completeness, EDF Energy has chosen to include all comments, whether or not they are duplicates.

ii. Data Protection Act Requirements

5.2.20 Due to EDF Energy’s intention to publish the Schedule of Responses as an appendix to this report, a process of redaction has been followed to protect individuals’ privacy, in accordance with the Data Protection Act.

5.2.21 Where responses have been received from individuals, their names have been replaced by a unique tracking number in the consultee column of the Schedule of Responses and Consultee Comment Key (Appendix H).

5.2.22 In addition, where any of the following pieces of information have been included in the text of the comment, every effort has been made to remove them:

• Individual names.

• Contact details, including location and e-mail addresses and telephone numbers.

• Job titles.

• Academic/other titles e.g. the Reverend.

5.2.23 This thorough redaction process was undertaken by a specialist data analysis company.

5.2.24 Through taking the above actions, EDF Energy believes it has taken reasonable measures to protect the privacy of consultees.

5.3 Public Reference Tracking System

5.3.1 In order to comply with data protection legislation, members of the public that responded to the consultation have not been individually identified. Instead, all responses from individuals submitted during the formal consultation stages were assigned a unique tracking reference number.

5.3.2 The procedure for notifying individuals of their unique tracking reference number worked in different ways, depending on how their comments had been submitted.


5.3.3 Those who completed the online questionnaire via the project website, www.edfenergyconsultation.info, received an automatically generated email providing an individual tracking reference number. There were a very few instances where the online process ‘timed out’ and the individual failed to receive their tracking number. If this did occur, EDF Energy supplied the consultee with their tracking reference number.

5.3.4 Those who completed a hard copy of the questionnaire and returned it at the exhibitions, using the freepost address or by handing it in to EDF Energy’s Bridgwater office, were sent an individual reference number if they ticked the box at the end of the questionnaire requesting their reference number so that they could track their comments in due course.

5.3.5 Individuals who submitted their comments by post, email or telephone were sent an acknowledgement containing their tracking reference number. This was sent either by email or post, except where the individual declined to provide his or her contact details. Some comments were received from members of the general public after the close of the various consultation stages. These late comments were nonetheless taken into account by EDF Energy and were assigned a tracking reference number which was notified to respondents, as described above.

5.3.6 This system was applied at each stage of the formal consultation, so if a member of the public responded to each stage of the consultation they will have four tracking reference numbers. If respondents have misplaced any of their reference numbers they can be reminded of them by telephoning the freephone consultation line on 0800 169 6507.

5.4 External Surveys, Petitions and Standard Campaign Letters

5.4.1 During the consultation period, EDF Energy received a number of surveys, petitions and standard campaign letters. The comments within these were all taken into account by EDF Energy in preparing its proposals for the HPC Project, but because they are not individual responses, they are not included in the Schedule of Responses. Examples of each of the letters, petitions and results of surveys are included in Appendix D.

5.4.2 Cannington Parish Council undertook a survey of residents in the village on EDF Energy’s ‘Initial Proposals and Options’ during Stage 1 and on ‘Preferred Proposals’ at Stage 2. The results of these surveys were submitted within the Parish Council’s formal response to Stages 1 and 2 and can be found in Appendix D.

5.4.3 Otterhampton Parish Council undertook a survey of residents in the village on EDF Energy’s ‘Preferred Proposals’ at Combwich. The results of this survey were included in Otterhampton Parish Council’s formal response to the Stage 2 consultation and can be found in Appendix D.

5.4.4 Residents in Williton participated in a local survey, organised by a private individual and independently verified, during Stage 1 to ascertain local views on the merits of the proposed A and B sites in Williton, the results of which can be found in Appendix D.


5.4.5 Save Cannington Action Group handed in a petition to the Bridgwater office with 757 signatures. The petition was not in opposition to EDF Energy’s proposals for nuclear new build at Hinkley Point but against the associated development proposed for the village of Cannington. See Appendix D.

5.4.6 At Stage 1, 67 ‘Stop Hinkley’ standard campaign letters were received objecting to the principle of nuclear new build at Hinkley Point and referred to the impact of the development on surrounding communities. At Stage 2, a further 28 ‘Stop Hinkley’ standard campaign letters were received. See Appendix D.

5.4.7 Forty-four horse riders submitted a petition at Stage 2 expressing concern at the potential vehicular impact on horse riders close to the HPC Development Site. See Appendix D.

5.4.8 At the Junction 24 and Highways Improvements consultation, 24 standard campaign letters were received from residents living in the vicinity of Junction 24. Although these did not object to the proposal to move the park and ride and freight logistics facility to the Somerfield location, their objections to the Junction 24 proposals included the motorway slip road widening and potential loss of trees and footpath. See Appendix D.

5.5 Response Sources

5.5.1 The majority of consultation responses and comments taken into account by EDF Energy have been received directly through the various feedback routes provided as part of the formal consultation stages.

5.5.2 However, in a small number of cases, the identified comments come from correspondence sent directly to the Infrastructure Planning Commission (IPC), which were consequently passed onto EDF Energy in a redacted form, under the Environmental Impact Regulations (EIR).

EDF Energy has included these comments in its Schedule of Responses, and has marked them as ‘Comments received under the EIR from the IPC’ in the ‘Respondent Type’ column. Due to the fact that the personal details had been removed before receipt, EDF Energy is not aware of the identity of the authors. This has led to there being some repetition of comments in the Schedule of Responses where the IPC has passed on consultation responses that had also been sent directly to EDF Energy.


CHAPTER 6: CONCLUSION



6. CONCLUSION

6.1 The Consultation Process

6.1.1 This report has described in detail the consultation process undertaken by EDF Energy prior to the submission of its Development Consent Order (DCO) application to the Infrastructure Planning Commission (IPC) for the Hinkley Point C project.

6.1.2 The pre-application consultation process has been lengthy, extensive and comprehensive. Formal consultation, as required by the Planning Act 2008, first began in November 2009 and concluded in August 2011. Over a period of almost two years, EDF Energy has formally consulted for more than 30 weeks. Nearly 6,500 consultees have directly engaged. There have been 34 public exhibitions held, 67 meetings attended, numerous newsletters produced and a dedicated consultation website maintained.

6.1.3 In response, people in the local communities affected by the Hinkley Point C development, other stakeholders and the general public have returned 1,262 questionnaires and provided 557 responses to the consultation via email, letter and telephone. A further 243 responses have been received from statutory consultees. This, and other consultation and engagement activity, prompted more than 2,000 responses, out of which almost 33,000 comments were processed. These comments have been broken down and categorised into 23 overarching themes, which were sub-divided into 225 categories and further broken down into more than 1,200 topics requiring a response from EDF Energy.

6.1.4 Outside the formal consultation period, EDF Energy has continued to engage with the local community and statutory consultees.

6.1.5 Mechanisms for ongoing engagement with the local community, such as the EDF Energy Hinkley Point C Community Forum, community newsletters and the EDF Energy Bridgwater office, have been established during the pre-application period.

6.2 Consultation Compliance

6.2.1 EDF Energy believes that the pre-application consultation it has undertaken complies with the requirements of the Planning Act 2008, IPC guidance, central Government guidance and local authority advice. Where there have been mainly minor departures from formal guidance, these have been identified and justified in this report.

6.2.2 This report provides a response to all the comments received during the formal consultation periods. Comments, whatever the source, have been considered carefully and a response provided which indicates whether EDF Energy has accepted the point and changed its proposals, considered the point but not made any changes, or simply considered the point where a request for change had not been made.

6.2.3 Also summarised within this report is input from informal consultation and meetings with statutory bodies and other groups.

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6.3 Evolution of the Hinkley Point C Proposals

6.3.1 Since the start of formal consultation in November 2009, and up to submission of the DCO application, significant changes have been made to the proposals, many of which have been in response to comments from the local community, the general public and statutory consultees. The plans to be considered by the IPC are, in many respects, different from those first proposed, and their evolution over nearly two years owes much to the consultation inputs received by EDF Energy.

6.3.2 Following the Stage 1 consultation (November 2009 – January 2010), and in the published Stage 2 ‘Preferred Proposals’, the following key changes were made, largely in response to consultation:

The southern construction boundary at the main Hinkley Point C site was moved northwards, further away from local residents, with improved landscaping.

Accommodation campuses at Williton and Cannington were dropped. Instead, campus accommodation was concentrated on the Hinkley Point C Development Site and at Bridgwater.

Freight management facilities at Cannington were dropped and, instead, focused on sites near Junctions 23 and 24 of the M5 and at Combwich.

The size of the park and ride facilities at both Cannington and Williton were reduced, while the size of the park and ride near Junctions 23 and 24 of the M5 was increased.

A package of community support was proposed to mitigate the impact of the Hinkley Point C development.

6.3.3 Following the Stage 2 consultation (July – October 2010), and in the published Stage 2 Update proposals, the following key changes were made, largely in response to consultation:

The size of the accommodation campus at the main Hinkley Point C Development Site was reduced, landscaping was improved and public access to the sports facilities was proposed.

The size of the proposed accommodation campus on the Innovia site in Bridgwater was reduced and public access to the sports facilities was proposed.

The size of the Cannington park and ride site was further reduced.

The park and ride site at Williton was relocated from a greenfield site to a brownfield site, further away from the village, and reduced in size.

Plans for fabrication facilities at Combwich were dropped, the size of the freight storage area was reduced and bus parking was removed.

Improvements to the road network and safety enhancements were identified at locations in Bridgwater, Cannington and along the C182 to Hinkley Point.

The community support package was substantially improved, with an enhanced Community Fund and additional funding proposed to support local housing and skills training.

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Plans for the Main Site Neighbourhood Support Scheme, covering property price support and noise mitigation, were proposed for the five hamlets closest to the main Development Site.

Following the Stage 2 Update consultation and in the published Junction 24 and Highways Improvements consultation, and prior to the submission of the DCO, the following key changes were made, largely in response to consultation:

The brownfield Somerfield site near Junction 24 of the M5 was proposed as an alternative park and ride and freight management facility to the greenfield site close to Stockmoor village.

Further highway improvements were proposed in the Bridgwater area, including both new and enhanced schemes.

EDF Energy agreed to introduce a voluntary noise mitigation scheme in parts of both Cannington and Combwich.

6.3.4 Although important changes have been made in response to consultation, EDF Energy acknowledges it has not been possible to respond to all the expectations of the local community or fully address their concerns. Furthermore, in certain respects, local concerns about the potential impact of the Hinkley Point C proposals have increased during the consultation process as EDF Energy’s plans have evolved.

6.3.5 Some of the significant areas where the expectations of local communities have not been fully met, or where concerns have increased during the consultation process, include the following:

6.3.6 There has been strong public support for a northern Bridgwater bypass to be built connecting Junction 23 of the M5 to the C182 Hinkley Point road west of Cannington. EDF Energy considered this option carefully, but has not accepted that such a road is necessary or justified, as long as other measures to mitigate transport impacts are implemented.

6.3.7 There has been strong public opposition in Stogursey parish to an accommodation campus on the main Hinkley Point C Development Site (although this is generally supported by those living further afield). EDF Energy believes the on-site accommodation campus is an essential part of its accommodation strategy and will help to mitigate the overall transport impacts of the Project. In response to local concerns, the size of the campus has been reduced and other measures have been proposed to reduce the impact on the local community.

6.3.8 In Cannington there has been concern about the provision of a park and ride facility and traffic travelling through the village, leading to demands that the western bypass should be completed before major construction work begins at Hinkley Point. EDF Energy believes that traffic impacts in the village can be managed, prior to the opening of the bypass, and has proposed highway improvements and a noise mitigation scheme.

6.3.9 At Combwich there have been strong local concerns about noise, disturbance and increased traffic from the use of the existing wharf and the adjacent laydown area. EDF Energy believes that there is broad support for maximising the use of waterborne transport, and the use of the wharf for abnormal indivisible loads is essential. The laydown area proposed at Combwich is a vital part of the overall

Consultation Report – Chapter 6 Conclusion | October 2011 5



6 Consultation Report – Chapter 6 Conclusion | October 2011


freight strategy. In response to local concerns, EDF Energy has reduced the size of the laydown area and proposed mitigation of noise and visual impact.

6.3.10 As EDF Energy’s detailed plans have evolved and construction shift patterns have become clearer, strong concerns about long working hours and night-time working have been expressed from those living near the main site, in parts of Cannington and at Combwich. EDF Energy believes that some night-time working is essential and that longer working hours will help to reduce the overall period of construction. Noise mitigation and other mitigation measures have been proposed in those locations where this is likely to be a problem.

6.3.11 During the pre-application consultation process, it has not been possible for EDF Energy to resolve fully all the concerns of affected local communities about the Hinkley Point C project. However, EDF Energy has carefully considered all the views expressed in the formal consultations over a period of nearly two years, and the Project has evolved in response to this consultation process. Significant changes to the main and associated development site proposals have been made at various stages and, where fundamental changes have not been possible, EDF Energy has sought to propose appropriate mitigation measures.

6.3.12 EDF Energy welcomes the strong support shown for the HPC Project by many in the local community, notwithstanding concerns about specific issues requiring mitigation.

6.4 End Note

6.4.1 EDF Energy would like to express its appreciation to all those private individuals, community groups, elected representatives and other organisations that have responded to this consultation process. Many people have given freely of their time over a lengthy period to have their say during the consultation process and to provide detailed input to EDF Energy’s plans for Hinkley Point C.

6.4.2 EDF Energy would like to reassure those who responded to the consultation that all the views expressed have been listened to and carefully considered, even if they have not always been accepted. However, EDF Energy does believe that its proposals for Hinkley Point C have improved substantially as a consequence of this consultation and will have greater benefits and fewer impacts for local communities than would have been the case otherwise.