Vastavalt jaotuskavale
20.07.2020 nr 7-12/19/5896-11
Inglismaa uue tuumaelektrijaama Sizewell C piiriülese
keskkonnamõju hindamisest
Suurbritannia ja Põhja-Iiri Ühendkuningriik teavitas 2019. a vastavalt piiriülese keskkonnamõju hindamise
konventsioonile (Espoo konventsioonile) Eestit projektist ehitada Inglismaale uus tuumaelektrijaam
Sizewell C. Arendaja NNB Nuclear Generation kavandatavaks tegevuseks on ehitada kahe EPR-reaktoriga
tuumaelektrijaam oodatava koguvõimsusega 3,340 MW. 2019. a aset leidnud etapis jõudis Inglismaa pädev
asutus seisukohale, et eeldatavalt ei kaasne Eestile olulist kahjulikku piiriülest keskkonnamõju. Siiski saatis
Suurbritannia ja Põhja-Iiri Ühendkuningriik Eestile varakult Espoo konventsiooni kohase teate.
Keskkonnaministeerium korraldas teate avalikustamise. Tuginedes saadud tagasisidele teavitas
Keskkonnaministeerium Suurbritannia ja Põhja-Iiri Ühendkuningriiki, et Eesti ei soovi osaleda kõnealuse
projekti piiriülese keskkonnamõju hindamise menetluses.
Nüüd on Suurbritannia ja Põhja-Iiri Ühendkuningriik teavitanud riike sellest, et projekti menetlus on
jõudnud formaalsesse tegevusloa taotluse etappi (lisa 1). Ka käimasolevas etapis on Inglismaa pädev asutus
teostanud asjakohase hindamise ning jäänud varasemale seisukohale, et eeldatavalt ei kaasne Eestile olulist
kahjulikku piiriülest keskkonnamõju. Samas on aga riikidele antud võimalus esitada arvamusi kavandatava
tegevuse kohta, ingliskeelne materjal on leitav veebilehel
1
https://infrastructure.planninginspectorate.gov.uk/projects/Eastern/The-Sizewell-C-Project . Kuna
materjal on väga mahukas, on arendaja selle struktuuri kirjeldamiseks koostanud ülevaate (lisa 2). Kirjale
on lisatud ka dokument, mis kirjeldab ülevaatlikult projekti piiriülese keskkonnamõjuga seonduvat (lisa 3).
Juhul, kui teil on kommentaare kõnealuse projekti tegevusloa taotluse materjalide kohta, siis lähtuvalt
Suurbritannia ja Põhja-Iiri Ühendkuningriigi määratud vastamistähtajast palume need edastada
Keskkonnaministeeriumile 5. augustiks 2020.
Lugupidamisega
(allkirjastatud digitaalselt)
Kaupo Heinma
Asekantsler
Lisad:
1 – Suurbritannia ja Põhja-Iiri Ühendkuningriigi teavituskiri
2 – Arendaja materjali struktuur
3 – Piiriülese keskkonnamõju dokument
Rainer Persidski, 626 2973
[email protected]
1
Arendaja tegevusloa taotluse materjalid (sh keskkonnamõju hindamise materjalid) on leitavad veebilehel
https://infrastructure.planninginspectorate.gov.uk/projects/eastern/the-sizewell-c-project/?ipcsection=docs (valiku
„Developer’s Application“ all).
Narva maantee 7a/ Tallinn 15172/ 626 2802/
[email protected]/ www.envir.ee/
Registrikood 70001231
National Infrastructure Planning Customer Services: 0303 444 5000
Temple Quay House e-mail: sizewellc@planning
2 The Square inspectorate.gov.uk
Bristol, BS1 6PN
Sent via email
Your Ref:
Our Ref: EN010012-002286
Date: 8 July 2020
Dear Sir/Madam
Information in relation to the Convention on Environmental Impact
Assessment in a Transboundary Context (the “Espoo Convention”) and the
Convention on Access to Information, Public Participation in Decision-Making
and Access to Justice in Environmental Matters (the “Aarhus Convention”).
The Secretary of State has received an application for development consent in respect
of ‘The Sizewell C Project’, a new nuclear power station in Suffolk, on the East coast
of England, United Kingdom (UK).
The proposed Sizewell C Project includes two UK European Pressurised Reactor
(EPR™) units with an expected net electrical output of approximately 1,670
megawatts (‘MW’) per unit, giving a total of approximately 3,340MW. The Sizewell C
Project comprises the main nuclear power station facility and associated developments
in order to facilitate construction and operation of the nuclear power station including:
• Offshore cooling water infrastructure and other marine works;
• Temporary construction areas and the relocation, demolition and replacement
of certain existing ancillary facilities associated with the operational Sizewell B
nuclear power station;
• A number of associated development works away from the main site which are
required to facilitate construction or operation, including:
o Two temporary park and ride sites to manage traffic generated by the
construction workforce
o permanent road bypasses, link roads and highway improvements to
alleviate traffic and mitigate road safety effects during construction and
operation;
o Temporary freight management facilities during construction; and
o Temporary and permanent extensions and improvements to existing
railway infrastructure.
Phased construction of the Sizewell C power station development is anticipated to take
9-12 years and, once completed, it has an operational design life of 60 years followed
by a period of decommissioning.
https://infrastructure.planninginspectorate.gov.uk
This letter provides details of where further information on the Proposed Development
can be found on the Planning Inspectorate’s website.
Transboundary screening
The Proposed Development has been identified as a project within the scope of
paragraph 2 of Appendix 1 to the Espoo Convention and EU Directive 2011/92/EU on
the assessment of the effects of certain public and private projects on the
environment (“the EIA Directive”), as implemented by the Infrastructure Planning
(Environmental Impact Assessment) Regulations 2017 (“the EIA Regulations”).
Prior to receiving the application the Secretary of State (as provided for in Article 3(1)
of the Espoo Convention and Article 7 of the EIA Directive) undertook a screening
assessment in October 2019 to identify if there were likely significant adverse
transboundary effects on the environment in your state. This concluded that the
Proposed Development is not likely to have such effects.
Following receipt of the DCO application, the Secretary of State has now re-screened
the Proposed Development to reconsider if there is the potential for likely significant
adverse transboundary effects in your state. The Secretary of State remains of the
view that the Proposed Development is not likely to have such effects. This
assessment has adopted a precautionary approach to the information currently
provided by the Applicant. The screening assessment is available at:
https://infrastructure.planninginspectorate.gov.uk/document/EN010012-002271
Further information on the transboundary consultation applicable to the EIA process
can be found in the Planning Inspectorate’s Advice Note 12 available on our website:
https://infrastructure.planninginspectorate.gov.uk/legislation-and-advice/advice-
notes/
General provisions for proposed new nuclear electricity generating station
developments
The Secretary of State has had regard to the findings of the Espoo Convention
Implementation Committee in relation to EIA/IC/CI/5 and the UK’s obligations under
the Convention on Access to Information, Public Participation in Decision-Making and
Access to Justice in Environmental Matters (the ‘Aarhus Convention’).The Secretary of
State has therefore decided to inform your State of the Proposed Development as if
significant adverse transboundary effects on the environment in your State were likely
for the purposes of Articles 3(1) and 2(4) of the Espoo Convention.
This letter therefore invites your State to participate in the procedure under
paragraphs 5 to 8 of Article 3 and Articles 4 to 7 of the Espoo Convention in relation
to this application.
EIA participation and consultation
https://infrastructure.planninginspectorate.gov.uk
Your State is now being consulted and given the opportunity to provide the Secretary
of State with the opinions of your public and its relevant authorities on the Proposed
Development. You may wish to provide information on:
• The potential significant effects of the proposed development on the
environment of your State; and
• The measures envisaged to reduce or eliminate such effects.
Where you have undertaken consultation with the public of your State or with the
relevant authorities, where appropriate, it would be helpful to summarise these
comments in any response to the Inspectorate.
Information about the proposed application for development consent
Information about the Proposed Development is available in the application
documents, which include:
• The draft Development Consent Order (DCO);
• The Environmental Statement (and a non-technical summary); and
• The Habitats Regulations Assessment Report.
These documents are available on our website:
https://infrastructure.planninginspectorate.gov.uk/projects/Eastern/The-Sizewell-C-
Project/
The Applicant has also produced a ‘Navigation Document’, summarising the structure
of the application for development consent for the Proposed Development. This
document is available from:
https://infrastructure.planninginspectorate.gov.uk/document/EN010012-001619
Timeframe for comments on the Proposed Development
We propose a 6 week consultation period from the date of this letter for your State to
provide comments to the Inspectorate on the application for the Proposed
Development. On this basis the deadline for the comments is 19 August 2020. If we
do not receive any comments by this date, then we will assume that your State does
not have any comments to make on the Proposed Development in accordance with
the EIA Regulations.
We would be grateful if you could acknowledge receipt of this letter and confirm that
the proposed timescale is acceptable. Your reply to the Secretary of State should be
sent electronically to:
[email protected].
Information about the decision making timetable
The DCO application submitted to the Secretary of State has been accepted for
examination. The Proposed Development is now at the pre-examination stage. The
remaining stages of the DCO process are:
• Examination (the Examining Authority has a maximum of six months to carry
out the examination),
https://infrastructure.planninginspectorate.gov.uk
• Recommendation (three months for the Examining Authority to make a
recommendation to the relevant Secretary of State),
• Decision (three months for the relevant Secretary of State to make a decision
on whether to grant or refuse development consent); and
• Post-decision (six week legal challenge period).
Registering as an Interested Party
The Infrastructure Planning (Examination Procedure) Rules 2010 set out how your
state may become involved in the examination process – this is by registering as an
Interested Party. This will mean that your State will be automatically kept informed
about the progress of the application and the decision and you will be invited to take
part in the examination. By registering as an Interested Party, your state and any
members of your public who register are afforded the same ability as the UK public to
participate in the process should they wish to do so.
Registering as an Interested Party is a separate process, is not part of the EIA
Regulations and does not alter any rights of your state under the EIA Regulations. The
deadline to register as an interested party for this application closes on 30
September 2020 at 23:59 Greenwich Mean Time (GMT).
Further information about registering as an Interested Party can be found in the
Planning Inspectorate’s Advice Note 8.2, available on our website:
https://infrastructure.planninginspectorate.gov.uk/legislation-and-advice/advice-
notes/
Dissemination of information
You may additionally wish to consider the dissemination of information on the
proposed development for the public concerned in your State, under Article 3(8) of
the Espoo Convention, and Article 7(3) of the EIA Directive as implemented by the EIA
Regulations. The accessibility of information is detailed above.
Responding to this letter
The Planning Inspectorate (the independent body responsible for certain planning
matters) would be grateful if you could acknowledge receipt of this letter. Ideally your
reply should be sent electronically to
[email protected].
If you have any queries, please do not hesitate to contact the Planning Inspectorate’s
Environmental Services Team using the contact details provided.
Yours faithfully
David Price
David Price
Head of Operations
on behalf of the Secretary of State
This communication does not constitute legal advice.
Please view our Privacy Notice before sending information to the Planning Inspectorate.
https://infrastructure.planninginspectorate.gov.uk
The Sizewell C Project
1.3 Navigation Document
Revision: 1.0
Applicable Regulation: Regulation 5(2)(q)
PINS Reference Number: EN010012
May 2020
Planning Act 2008
Infrastructure Planning (Applications: Prescribed
Forms and Procedure) Regulations 2009
SIZEWELL C PROJECT – NAVIGATION DOCUMENT
NOT PROTECTIVELY MARKED
CONTENTS
1 Navigation Document ............................................................................................... 1
1.1 Introduction ............................................................................................................... 1
1.2 Document Categories ............................................................................................... 1
TABLES
Table 1.1: Book 1 Application Form ....................................................................................... 2
Table 1.2: Book 2 Plans ......................................................................................................... 3
Table 1.3: Book 3 Draft Development Consent Order ........................................................... 3
Table 1.4: Book 4 Compulsory Acquisition Information ......................................................... 4
Table 1.5: Book 5 Reports ..................................................................................................... 4
Table 1.6: Book 6 Environmental Statement ......................................................................... 5
Table 1.7: Book 7 Additional Information ............................................................................... 5
Table 1.8: Book 8 Other Documents...................................................................................... 6
PLATES
Plate 1.1: Books forming the Sizewell C Project application for development consent .......... 2
NOT PROTECTIVELY MARKED
Navigation Document | i
SIZEWELL C PROJECT – NAVIGATION DOCUMENT
NOT PROTECTIVELY MARKED
1 Navigation Document
1.1 Introduction
1.1.1 This Navigation Document summarises the structure of SZC Co.’s
application for development consent for the Sizewell C Project. The
application is made to the Secretary of State for Business, Energy and
Industrial Strategy under the Planning Act 2008 for powers to construct,
operate and maintain a nuclear power station in Suffolk, Sizewell C, and the
associated development in the vicinity necessary to facilitate the construction
or operation of the power station or to mitigate its impacts. The elements of
the scheme being applied for as part of the Application are together referred
to as the ‘Sizewell C Project’.
1.1.2 This Navigation Document is to provide an understanding of the structure of
the application for development consent and the principal contents within
each ‘Book’ of documents.
1.2 Document Categories
1.2.1 Due to the size and scale of the Application, the application documents have
been grouped to correspond with the Planning Inspectorate’s suggested
categories for application documents which have been grouped into Books.
There are eight different books as shown in Plate 1.1.
1.2.2 Each Book has been colour-coded as shown in Plate 1.1 and the
corresponding colour is displayed on the cover of each document within this
application for development consent to convey which Book it sits within. The
content of each Book is described in Tables 1.1 to 1.8. For ease of reference,
the table headings correspond to those shown in Plate 1.1. Plate 1.1 is
intended to convey corresponding colours and the relative scales of
documentation and is not an accurate description of the actual folder design.
NOT PROTECTIVELY MARKED
Navigation Document | 1
SIZEWELL C PROJECT – NAVIGATION DOCUMENT
NOT PROTECTIVELY MARKED
Plate 1.1: Books forming the Sizewell C Project application for development
consent
Table 1.1: Book 1 Application Form
Book 1: Application Form
This Book contains the Cover Letter (Doc Ref. 1.1), the Application Form (Doc Ref.
1.2) and this Navigation Document (Doc Ref. 1.3).
There are four appendices to the Cover Letter: a List of the Application
Documents (Doc Ref. 1.1a), the Section 55 Application Checklist (Doc Ref. 1.1b),
copies of the Section 48 Newspaper Notices (Doc Ref. 1.1c) and a Glossary (Doc
Ref.1.1d) which sets out the terms used in the Application.
NOT PROTECTIVELY MARKED
Navigation Document | 2
SIZEWELL C PROJECT – NAVIGATION DOCUMENT
NOT PROTECTIVELY MARKED
Table 1.2: Book 2 Plans
Book 2: Plans
This Book contains the various plans provided in support of the Application.
The Land Plans (Doc Ref. 2.1), Crown Land Plans (Doc Ref. 2.2), Work Plans (Doc
Ref. 2.3) and Access/Rights of Way Plans (Doc Ref. 2.4) would form part of the
Development Consent Order itself. The plans identify the following:
• Land Plans: the Order Limits which define the area within which the authorised
development may be constructed, operated and maintained and the individual plots
SZC Co. intends to exercise its compulsory acquisition powers over.
• Crown Land Plans: the land owned by the Crown included in the application for
development consent.
• Work Plans: the location of the work for which development consent is sought as
well as any the limits of deviation.
• Access/Rights of Way Plans: the location of the existing public and private rights
of way that would be stopped up or diverted and any new rights of way to be
provided either during construction or operation.
The other plans consist of a set of plans and drawings (including parameter plans
where appropriate) for the main development site and the off-site associated
development sites.
Further detail on the design of the Sizewell C Project can be found in the Main
Development Site Design and Access Statement (Doc Ref. 8.1) and Associated
Development Design Principles (Doc Ref. 8.3) contained in Book 8.
Table 1.3: Book 3 Draft Development Consent Order
Book 3: Draft Development Consent Order
This Book contains the Draft Development Consent Order (Doc Ref. 3.1) itself, the
Explanatory Memorandum (Doc Ref. 3.2) and the DCO Validation Report (Doc
Ref. 3.3).
The Draft Development Consent Order includes the legal powers and rights being
applied for in order to construct, operate and maintain the Sizewell C Project.
Schedule 1 includes the individual work packages which comprise the construction of
the Sizewell C Project and Schedule 2 sets out the requirements that would apply in
the construction, operation and maintenance of the Sizewell C Project.
The Explanatory Memorandum explains the purpose and effect of each provision of
the Draft Development Consent Order.
NOT PROTECTIVELY MARKED
Navigation Document | 3
SIZEWELL C PROJECT – NAVIGATION DOCUMENT
NOT PROTECTIVELY MARKED
Table 1.4: Book 4 Compulsory Acquisition Information
Book 4: Compulsory Acquisition Information
This Book contains compulsory acquisition information comprising the Statement of
Reasons (Doc Ref. 4.1), Funding Statement (Doc Ref. 4.2) and Book of Reference
(Doc Ref. 4.3). Compulsory acquisition information is required because powers of
compulsory acquisition are being sought.
The Statement of Reasons explains why the powers of compulsory acquisition
sought in the Draft Development Consent Order are necessary in order to
implement the Sizewell C Project, and why there is a compelling case in the public
interest to grant those powers.
The Funding Statement explains how the proposed Sizewell C Project and
compulsory acquisition is planned to be funded. The Book of Reference sets out
those interests over which powers of compulsory acquisition are sought.
Table 1.5: Book 5 Reports
Book 5: Reports
This Book contains various reports and statements that are provided in support of the
application for development consent.
The Consultation Report (Doc Ref. 5.1) presents the consultation activities which
SZC Co. has carried out in relation to its proposals for the Sizewell C Project, the
responses received to these consultation activities and how the Sizewell C Project
has evolved having regard to those responses.
The Flood Risk Assessments (Doc Ref. 5.2 to 5.9) for the main development site
and off-site associated developments assess all of the potential sources of flood risk
and present associated mitigation measures for the Sizewell C Project.
The Shadow Habitats Regulations Assessment Report (Doc Ref. 5.10) contains
the information necessary for the relevant authority to carry out the appropriate
assessment required under the applicable habitats legislation.
The Schedule of Other Consents, Licences and Agreements (Doc Ref. 5.11) lists
the other consents, licences and agreements which do not form part of the
development consent application and which SZC Co. will apply for separately.
The Statement of Statutory Nuisances (Doc Ref. 5.12) explains whether the
Sizewell C Project would cause any statutory nuisances.
NOT PROTECTIVELY MARKED
Navigation Document | 4
SIZEWELL C PROJECT – NAVIGATION DOCUMENT
NOT PROTECTIVELY MARKED
Book 5: Reports
The Community Impact Report (Doc Ref. 5.13) describes the assessed impacts on
the communities surrounding the Sizewell C Project.
The Equality Statement (Doc Ref. 5.14) assesses the impact of the new and revised
policies, practices and services against the requirements of the public sector equality
duty.
Table 1.6: Book 6 Environmental Statement
Book 6: Environmental Statement
This Book contains the Environmental Statement which sets out the assessment of
the likely significant effects of the Sizewell C Project on the environment. The
Environmental Statement comprises:
• A Non-Technical Summary (Doc Ref. 6.1).
• Volume 1 Introduction (Doc Ref. 6.2).
• Volume 2 contains the assessment of the main development site (Doc Ref. 6.3).
• Volumes 3 to 9 contain the assessment of the off-site associated developments
(Doc Ref. 6.4 to 6.10).
• Volume 10 on project-wide, cumulative and transboundary effects (Doc Ref. 6.11).
Each volume is divided into chapters with each covering a different topic of the
assessment contained within that volume. The figures showing relevant nature
conservation and historic environment features, and accompanying assessments,
can be found within the relevant topic chapters of the Environmental Statement.
Table 1.7: Book 7 Additional Information
Book 7: Additional Information
This Book contains the Grid Connection Statement (Doc Ref. 7.1) and the
Regulation 6 Additional Information (Doc Ref 7.2).
The Grid Connection Statement explains who would be responsible for designing
and building the connection of the Sizewell C power station to the national electricity
network. The Regulation 6 Additional Information identifies where the information
specified in Regulation 6 of the Infrastructure Planning (Applications: Prescribed
Forms and Procedure) Regulations 2009 relating to railway and highway
development, harbour facilities and hazardous waste facilities can be found within the
application material. Even though the Regulation itself does not strictly apply, SZC
NOT PROTECTIVELY MARKED
Navigation Document | 5
SIZEWELL C PROJECT – NAVIGATION DOCUMENT
NOT PROTECTIVELY MARKED
Book 7: Additional Information
Co. recognises that it may be helpful to the Planning Inspectorate to identify where
this information can be found.
Table 1.8: Book 8 Other Documents
Book 8: Other Documents
This Book contains additional documents which SZC Co. is submitting in support of
its application for development consent.
The Sizewell C Project design is contained in the Main Development Site Design
and Access Statement (Doc Ref. 8.1), the Outline Landscape and Ecology
Management Plan (Doc Ref. 8.2) and the Associated Development Design
Principles (Doc Ref. 8.3). These documents set out the design vision, principles and
concepts for the Sizewell C Project as a whole and its various components.
The Planning Statement (Doc Ref. 8.4) explains the rationale for the Sizewell C
Project and sets this in the context of the national, regional and local planning policy
to enable the decision maker to form a judgement on the overall planning balance,
including a consideration of the benefits of the Sizewell C Project verses its expected
impacts.
The Transport Assessment (Doc Ref. 8.5) describes the process SZC Co. has
conducted to identify impacts on transport of the Sizewell C Project and identifies the
proposed measures for managing the anticipated impacts.
The following plans provide information regarding workers and traffic:
• the Traffic Incident Management Plan (Doc Ref. 8.6).
• the Construction Traffic Management Plan (Doc Ref. 8.7).
• the Construction Worker Travel Plan (Doc Ref. 8.8).
The Economic Statement (Doc Ref. 8.9) sets out the proposed strategy for delivering
the economic benefits to the local area. The appendices include the Employment,
Skills, Education and Training Strategy (Doc Ref. 8.9A) and the Supply Chain
Engagement Strategy (Doc Ref. 8.9B).
The Accommodation Strategy (Doc Ref. 8.10) sets out the proposed approach to
securing accommodation in the local area for non-home-based construction workers.
The Accommodation Strategy (Doc Ref 8.10) sets out the demand for
accommodation from non-home-based workers, the accommodation proposed as
part of the associated development, the potential for worker use of existing local
NOT PROTECTIVELY MARKED
Navigation Document | 6
SIZEWELL C PROJECT – NAVIGATION DOCUMENT
NOT PROTECTIVELY MARKED
Book 8: Other Documents
accommodation and measures to avoid or reduce significant effects on households
and the operation of the housing markets.
The Code of Construction Practice (Doc Ref. 8.11) details the strategies, measures
and standards of work that SZC Co. and its contractors would adhere to when carrying
out the construction of the Sizewell C Project. Part A relates to the whole Sizewell C
Project, Part B relates to the main development site and Part C relates to the off-site
associated development.
The Mitigation Route Map (Doc Ref. 8.12) identifies the mitigation measures which
are proposed and where they would be secured.
The Sustainability Statement (Doc Ref. 8.13) presents the overall sustainability
strategy for the Sizewell C Project.
The Water Framework Directive Compliance Assessment Report (Doc Ref 8.14)
explains how the Sizewell C Project adheres to the European Water Framework
Directive.
The Combined Heat and Power Feasibility Study (Doc Ref. 8.15) determines
whether combined heat and power would be technically feasible at the main
development site and/or offer economic benefit to SZC Co.
The Community Safety Management Plan (Doc Ref. 8.16) presents SZC Co.’s
strategy to promote community safety and cohesion throughout the Sizewell C
Project.
NOT PROTECTIVELY MARKED
Navigation Document | 7
The Sizewell C Project
6.11 Volume 10 Project-wide, Cumulative and
Transboundary Effects
Chapter 5 Transboundary Effects
Revision: 1.0
Applicable Regulation: Regulation 5(2)(a)
PINS Reference Number: EN010012
May 2020
Planning Act 2008
Infrastructure Planning (Applications: Prescribed
Forms and Procedure) Regulations 2009
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
Contents
5 Transboundary Effects........................................................................... 1
5.1 Introduction ............................................................................................ 1
5.2 Legislation, Policy and Guidance ........................................................... 1
5.3 Methodology .......................................................................................... 5
5.4 EIA Topic Assessments ......................................................................... 8
5.5 Habitat Regulations Assessment ......................................................... 19
5.6 Summary ............................................................................................. 20
References ....................................................................................................... 21
Tables
None Provided.
Plates
None Provided.
Figures
Figure 5.1: Territorial Waters of Closest European Economic Area States
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | i
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
5 Transboundary Effects
5.1 Introduction
5.1.1 This chapter presents the assessment of transboundary environmental
effects associated with the construction and operation of the Sizewell C
power station at the main development site and the construction, operation
and removal and reinstatement (where applicable) of the associated
development sites (hereafter referred to as, the ‘Sizewell C Project'). A
description of the anticipated activities for the decommissioning of the
Sizewell C power station, including a summary of the types of environmental
effects that may occur, is provided in Chapter 5 of Volume 2 of the
Environmental Statement (ES).
5.1.2 This chapter and Appendix 5A of this volume represents SZC Co.’s
fulfilment of the requirements of the Planning Inspectorate’s Advice Note
Twelve (Ref. 5.1) through the discussion of likely significant transboundary
effects on other European Economic Area States.
5.2 Legislation, Policy and Guidance
5.2.1 In line with policy and guidance, SZC Co. has considered whether the
Sizewell C Project is likely to have significant transboundary effects during
the construction, operation, and removal and reinstatement phases.
a) International
5.2.2 International legislation or policy relevant to the transboundary effects
assessment includes:
• Directive 2014/52/EU Assessment of the Effects of Certain Public and
Private Projects on the Environment amending Directive 2011/92/EU
on the assessment of the effects of certain public and private projects
on the environment (‘EIA Directive’) (Ref. 5.2).
• Council Directive 92/43/EEC (Habitats Directive) (Ref. 5.3).
• Council Directive 2009/147/EC (Birds Directive) (Ref. 5.4).
• Convention on Environmental Impact Assessment in a Transboundary
Context (Espoo Convention) (Ref. 5.5).
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 1
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
5.2.3 A wide range of activities are listed in Appendix 1 of the Espoo Convention,
which includes all thermal power stations with a heat output of 300
megawatts (MW) and all nuclear power stations. Thus it is necessary to
consider whether the proposed development is likely to have a significant
transboundary effect.
5.2.4 The EIA Directive is transposed into UK legislation by the Infrastructure
Planning (Environmental Impact Assessment) Regulations 2017 (Ref. 5.6)
and the Marine Works (Environmental Impact Assessment) Regulations
2007 (as amended) (Ref. 5.7) (referred to collectively as ‘the EIA
Regulations’), as summarised in a national context below.
5.2.5 The Habitats Directive and Birds Directive require the establishment and
protection of sites known as Special Areas of Conservation (SACs) and
Special Protection Areas (SPAs) in order to ensure the protection of
important and endangered habitats and species, and rare, vulnerable and
migratory birds. SACs, SPAs, sites in the process of designation as SACs
and SPAs, and Ramsar wetlands (under UK policy) are each considered as
European sites and are considered as part of the Habitat Regulation
Assessment (HRA) process.
b) National
i. Legislation
5.2.6 National legislation relevant to the transboundary effects assessment
includes:
• Infrastructure Planning (Environmental Impact Assessment)
Regulations 2017 (Ref. 5.6).
• Marine Works (Environmental Impact Assessment) Regulations 2007
(Ref. 5.7).
• The Conservation of Habitats and Species Regulations 2017 (Ref 5.8).
• The Conservation of Offshore Marine Habitats and Species Regulations
2017 (Ref. 5.9).
5.2.7 Regulation 32 of the Infrastructure Planning (Environmental Impact
Assessment) Regulations 2017 (Ref. 5.6) imposes a requirement for all
significant transboundary issues set out in the EIA Directive (Ref. 5.2) to be
assessed through the EIA process.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 2
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
5.2.8 In England, the requirements of the Habitats Directive and Birds Directive are
transposed into domestic law by The Conservation of Habitats and Species
Regulations 2017 (Ref. 5.8) (more commonly known as the Habitats
Regulations) for European sites within territorial waters (i.e. 12 nautical
miles), and The Conservation of Offshore Marine Habitats and Species
Regulations 2017 (Ref. 5.9) (the Offshore Habitats Regulations) for
European sites within waters beyond 12 nautical miles.
5.2.9 The Habitats Regulations require that, before authorising a project likely to
have a significant effect on a European site, a competent authority (i.e. the
decision maker on any application for development consent) must “make an
appropriate assessment of the implications for that site in view of that site’s
conservation objectives” (regulation 63(1) of the Habitats Regulations).
Anyone applying for development consent must therefore provide the
competent authority with such information as may reasonably be required
“for the purposes of the assessment or to enable them to determine whether
an appropriate assessment is required” (regulation 63(2)). Information
relevant to an appropriate assessment includes any representations
(following consultation by the applicant) from statutory nature conservation
bodies, both within the UK and in other European countries, and how the
applicant has had regard to such feedback.
5.2.10 The effects of a plan or project on all European sites must be considered.
This includes European sites both within the UK and in other EU countries.
ii. Policy
5.2.11 The NPSs that are relevant to the Sizewell C Project are the Overarching
National Policy Statement for Energy (NPS EN-1) (Ref. 5.10) and the
National Policy Statement for Nuclear Power Generation (NPS EN-6) (Ref.
5.11). NPS EN-1 and NPS EN-6 were considered by Parliament and formally
designated in July 2011. As explained in further detail in the Planning
Statement (Doc Ref. 8.4), whilst NPS EN-1 and EN-6 do not formally have
effect to the Sizewell C DCO application, it is appropriate to treat them as
providing the primary policies relevant to the determination of the application.
5.2.12 The NPSs set out the Government’s energy policy, the need for new
infrastructure and guidance for determining an application for a DCO. The
NPSs include specific criteria and issues which should be covered by
applicants’ assessments of the effects of their scheme, and how the decision
maker should consider these impacts.
5.2.13 The National Policy Statement for Nuclear Power Generation (NPS EN-6)
(Ref. 5.11) states in paragraph 1.7.4 that “significant trans-boundary effects
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 3
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
arising from the construction of new nuclear power stations are not
considered likely. Due to the robustness of the regulatory regime there is a
very low probability of an unintended release of radiation, and routine
radioactive discharges will be within legally authorised limits.”
c) Regional
5.2.14 No regional policies are deemed relevant to the transboundary effects
assessment.
d) Local
5.2.15 No local policies are deemed relevant to the transboundary effects
assessment.
e) Guidance
5.2.16 Guidance relevant to the transboundary effects assessment includes:
• Planning Inspectorate’s Advice Note Ten (Ref 5.12); and
• Planning Inspectorate’s Advice Note Twelve (Ref. 5.1).
5.2.17 The Planning Inspectorate’s Advice Note Twelve: Transboundary Impacts
and Process (March 2018, version 5) (Ref. 5.12) provides further information
on the requirements for the assessment of transboundary effects, and sets
out how the Planning Inspectorate will meet its obligations in this regard.
Advice Note Twelve states that the applicant is requested to provide
information to the Planning Inspectorate to enable a view to be reached as
to whether the development in question is likely to have significant
transboundary effects on other European Economic Area States. Advice
Note Twelve provides specific advice for Nuclear NSIPs and states in
paragraph 6.1 that “Special arrangements will be applied to the
transboundary impact process for nuclear electricity generating station
NSIPs”. As described in paragraph 6.2, these arrangements largely apply to
the role of the Planning Inspectorate, including that “each nuclear NSIP will
be screened using the long list proforma”. SZC Co. has completed the long
list proforma on behalf of the Planning Inspectorate and included a copy as
provided in Appendix 4A of this volume. The information provided within the
appendix is considered to be sufficient to enable the Planning Inspectorate
to fulfil the remainder of their duties as prescribed in section 6 of Advice Note
Twelve.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 4
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
5.2.18 The Planning Inspectorate's Advice Note on HRA relevant to NSIPs (Advice
Note Ten) (Ref. 5.12) provides further guidance to applicants in relation to
the preparation of an HRA report and the Planning Act 2008 processes
relating to HRA. SZC Co. has had regard to Advice Note Ten (Ref. 5.12) in
undertaking its HRA.
5.3 Methodology
5.3.1 Transboundary effects have only been considered where the impacts of the
Sizewell C Project are likely to extend beyond the United Kingdom (UK) and
to Espoo Convention signatory states.
a) Scope of the assessment
5.3.2 The scope of this assessment has been established through a formal EIA
scoping process undertaken with the Planning Inspectorate. A request for
an EIA Scoping Opinion was initially issued to the Planning Inspectorate in
2014, with an updated request issued in 2019, provided in Appendix 6A of
Volume 1 of the ES.
5.3.3 The 2019 EIA Scoping Report outlined SZC Co.’s approach to the
assessment of transboundary effects associated with the Sizewell C Project.
The Scoping Report set out that SZC Co. would complete the transboundary
screening matrix as detailed in the Planning Inspectorate Advice Note Twelve
and provided as Appendix 5A of this volume and present a summary within
this chapter.
5.3.4 Comments raised in the EIA Scoping Opinion received in 2014 and 2019
have been taken into account in the development of the topic specific
assessment methodologies used throughout Volumes 2 to 9 of the ES.
These are detailed in Volume 1, Appendices 6A to 6C.
5.3.5 In the EIA Scoping Opinion, the Planning Inspectorate acknowledged that
the 2019 EIA Scoping Report did not indicate whether the Sizewell C Project
is likely to have significant transboundary effects. The response requested
that the ES should identify whether the Sizewell C Project has the potential
to result in significant transboundary effects and, if so, which European
Economic Area states would be affected.
b) Study Area
5.3.6 As shown on Figure 5.1, the nearest Espoo Convention signatory states
outside the UK to the Sizewell C Project are Belgium, Netherlands Germany
and France. The nearest territorial waters of these states are approximately,
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 5
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
112km (to French territorial waters), 119km (to Belgian territorial waters),
122.5km (to Netherlands territorial waters) and 380km (to German territorial
waters) from Sizewell C.
c) Assessment scenarios
5.3.7 This chapter considers the likely project-wide effects during construction,
operation, and removal and reinstatement (where applicable) for the Sizewell
C Project. Generally, the assessments have considered the following phases
of development:
• Construction assessment scenario which comprises.
• Construction at the main development site, including removal and
reinstatement of temporary development at the later stages of
construction.
• Construction, operation and removal and reinstatement of temporary
associated developments (i.e. northern park and ride, southern park
and ride, freight management facility and green rail route).
5.3.8 Operational assessment scenario which comprises:
• Operation of the permanent development at the main development site.
• Operation of permanent associated developments (i.e. two village
bypass, Sizewell link road, highway and rail improvements).
d) Potential environmental impacts
i. Environmental Impact Assessment
5.3.9 The EIA Regulations require the applicant to consider all of the potential
environmental effects of a project and identify those that are likely significant.
5.3.10 As part of the EIA process and through consultation with statutory
consultees, each environmental topic has an agreed study area (or zone of
influence (ZOI)) within which significant environmental effects could occur.
Further details of study areas, ZOIs and the consultation can be found within
Appendix 6D to Appendix 6Y of Volume 1 of the ES. Therefore, the
potential for transboundary impacts has been considered within the technical
chapters of Volumes 2 to 9 of the ES when identifying resources or receptors
likely to be affected by the Sizewell C Project. Where a transboundary effect
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 6
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
is considered likely, an assessment has followed standard assessment
methodologies described within Appendix 6D to Appendix 6Y of Volume 1
of the ES.
5.3.11 A summary of the potential transboundary effects associated with the
construction, operation and removal and reinstatement phases (where
appropriate) of the Sizewell C Project is provided in section 5.4 of this
chapter.
ii. Habitat Regulations Assessment
5.3.12 The HRA process typically follows a four-staged approach.
• Stage 1 Likely Significant Effect Screening: This stage involves the
identification of potentially affected European sites and a screening
process to determine whether or not there are likely significant effects
(LSEs) on the qualifying features of those sites, whether alone or in
combination with other plans or projects.
• Stage 2 Appropriate Assessment: If any LSEs are identified, Stage 2
assesses the implications of the project for the affected site, in light of
that site’s conservation objectives and proposed mitigation, and
whether it can be ascertained that the proposal will not adversely affect
the integrity of the site.
• Stage 3 Assessment of Alternative Solutions: If it cannot be shown that
there will be no adverse effect on the integrity of the European site,
Stage 3 considers whether there are alternative solutions. Identifying
and examining alternative ways of achieving the objectives of the
project to establish whether there are solutions that would avoid, or
have a lesser effect, on the European site(s).
• Stage 4 imperative reasons of overriding public interest: Where no
alternative solution exists, the next stage of the process is to assess
whether the project is necessary for imperative reasons of overriding
public interest and, if so, the identification of compensatory measures
needed to maintain the overall coherence of the Natura 2000 network.
5.3.13 The Sizewell C Development Consent Order (DCO) Shadow HRA Report
(Doc Ref 5.10) explains how SZC Co. has approached its HRA and presents
the findings of the HRA process for all development within the Sizewell C
Project.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 7
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
5.3.14 In addition to the 2019 EIA Scoping Report and 2019 EIA Scoping Opinion,
see Appendix 6A and 6B of Volume 1 of the ES, transboundary consultation
has been undertaken by SZC Co. as outlined within the Shadow HRA
Report (Doc Ref. 5.10).
e) Assumptions and limitations
5.3.15 The processes for EIA and HRA are inter-related but represent two distinct
environmental assessments, with a common evidence base. Both
assessments are referred to and relied upon in this transboundary
assessment.
5.3.16 In addition to carrying forward assumptions from the technical assessments
presented within Volumes 2 to 9 of the ES and the HRA, the following
assumptions have been made in this assessment:
• the magnitude of likely impacts are no greater than those described at
the Sizewell C Project level in Chapter 2 of this volume.
5.4 EIA Topic Assessments
5.4.1 As described in Volume 1, Chapter 6 of the ES, the EIA methodology
considers whether impacts of the Sizewell C Project would have an effect on
any resources or receptors. Assessments broadly consider the magnitude
of impacts and value/sensitivity of resources/receptors that could be affected
in order to classify effects.
5.4.2 The criteria for the assessment of transboundary effects are the same as the
assessment methodology for each of the individual technical assessments
presented in Appendices 6D to 6Y of Volume 1 of the ES; therefore
reference should be made to each technical chapter as relevant. This
includes the consideration of sensitive receptors, significance criteria and
classification of effects. Therefore, a range of terms is used to report effect
classifications where transboundary effects are predicted. As such, it should
be noted that the Marine Navigation and Major Accidents and Disasters
assessments consider the residual risk of an event occurring and therefore
use tolerability to define significance. Further information is provided in
Appendix 6T and Appendix 6X of Volume 1 of the ES. A clear statement is
made where no transboundary effects have been identified.
5.4.3 The following section discusses the potential for likely significant
transboundary effects associated with the Sizewell C Project that have been
identified through the EIA process and are detailed within technical chapters
of Volumes 2 to 9 of the ES.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 8
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
a) Spent Fuel and Radioactive Waste Management
5.4.4 Volume 2, Chapter 7 of the ES presents an overview of the proposed
arrangements for the management of radioactive wastes and spent fuel
arising during operation of the Sizewell C power station. The chapter also
identifies that potential effects associated with the storage of Low level waste,
intermediate level waste and spent fuel are considered within the radiological
assessment presented in Chapter 25 of Volume 2 of the ES. As such, the
potential transboundary effects associated with the management of spent
fuel and radioactive waste are considered as part of the radiological
assessment discussed in Section 5.4s of this chapter.
b) Conventional Waste
5.4.5 Transboundary effects could occur if wastes were transported beyond UK
borders. However, it is anticipated that wastes generated during the
construction and operation would be treated within Suffolk and/or east of
England, albeit with the possibility that recycled materials could be exported
to be manufactured into new products. Transboundary effects on waste
management facilities are therefore, negligible (not significant).
5.4.6 Volume 2, Chapter 8 also considered the potential effects of the Sizewell C
Project on the availability of concrete, steel, bitumen and gravel in the UK.
The assessment identifies that effects on availability of steel would be major
adverse (significant), whilst effects on availability of all other material
resources would be negligible to minor adverse (not significant). When
considered on an international scale the magnitude of impact on all material
resources would be reduced and transboundary effects would be negligible
to minor adverse (not significant).
c) Socio-economics
5.4.7 The Sizewell C Project is not predicted to have significant socio-economic
effects in any other European Economic Area States during the construction
or operation phases due to the distance between the Sizewell C Project and
any other European Economic Area States. Therefore, no transboundary
effects are predicted during the construction, operation or removal and
reinstatement phases of the Sizewell C Project.
d) Transport
5.4.8 The study area for the transport assessment covers parts of the east of
Norfolk, extending to Lowestoft in the north, Ipswich to the south and the
A140 to the west. The geographic extent of the traffic model has been agreed
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 9
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
with Suffolk County Council. Therefore no transboundary effects are
expected during the construction or operational phases of the Sizewell C
Project.
e) Noise and Vibration
5.4.9 As described in Appendix 6G of Volume 1 of the ES, the noise and vibration
assessment considers the potential for the Sizewell C Project to affect all
human receptors and other noise sensitive receptors, including public rights
of way, heritage and ecological designations, within 1km of a Sizewell C
Project site and affected road network. As the noise and vibration effects
from construction, operation and removal and reinstatement (where
necessary) activities would be localised to this ZOI, no transboundary
effects are expected during the construction or operation phases of the
Sizewell C Project.
f) Air Quality
5.4.10 Emissions to air from the construction, operation and removal and
reinstatement (where necessary) of the Sizewell C Project, would have
impacts that are localised to the source of the emissions and would have a
negligible effect at locations outside of the main development site. Emissions
to air from the transport of materials by sea have been screened out of the
assessment based on the scale of additional shipping emissions being too
low to be capable of having a perceptible impact at any relevant receptor
location. Overall, the contribution to air pollution at the nearest State (states
in continental Europe to the east) due to emissions from these potential
pathways would be negligible and not significant.
g) LVIA
5.4.11 The ZOI for the landscape and visual impact assessment boundary extends
15km (onshore and offshore) from the boundary of the onshore part of the
Sizewell C main development site and up to 2km (onshore only) from
associated development sites. However, during construction the ZOI is
limited to 2km from the onshore part of the Sizewell C main development site
and up to 2km from associated development sites. This has been defined by
the anticipated Zone of Theoretical Visibility arising from the operational
development, specifically for the main structures. As the geographic extent
of the ZOIs does not extend beyond UK borders, no transboundary effects
on landscape or visual amenity are expected during the construction or
operation phases of the Sizewell C Project.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 10
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
h) Terrestrial Ecology
5.4.12 Transboundary effects on important ecological features could occur if a
project impacts a species which travels between two or more European
Economic Area states (for example migration through territorial waters), or
where a project impacts a European Site. Effects on migratory fish species
are covered within section 5.4p) of this chapter when discussing effects on
marine ecology. The assessment of impacts on European Sites is provided
within section 5.5 of this chapter. For terrestrial ecological features,
migratory bird species/assemblages would be affected by habitat loss and
temporary disturbance during construction of the Sizewell C Project. Any
transboundary effects on migratory bird species/assemblages are predicted
to be negligible to minor adverse and not significant.
i) Amenity and Recreation
5.4.13 The assessment of amenity and recreation considers physical changes to
resources, changes to the numbers of people using resources, and changes
to the amenity experience of people using resources within the agreed ZOIs.
The ZOI for the Sizewell C main development site extends 8km (onshore and
offshore) from the onshore boundary with all associated development sites
considering onshore receptors only. As the geographic extent of the ZOIs do
not extend beyond UK borders, there will be no transboundary effects on
amenity and recreation resources during the construction or operation
phases of the Sizewell C Project.
j) Terrestrial Historic Environment
5.4.14 As potential effects on terrestrial historic environment are limited to terrestrial
historic assets within the UK, there will be no transboundary effects on the
terrestrial historic environment during the construction or operation phases
of the Sizewell C Project.
k) Soils and Agriculture
5.4.15 As potential effects on soils and agriculture could arise through loss of
agricultural land and loss of productivity of a land holding, effects would be
limited to Sizewell C Project sites and their associated land holdings. As
such, there is the potential for transboundary effects associated with
landholdings, if part of an affected landholdings is located within another
European Economic Area state. However, as the land holdings affected by
the Sizewell C Project are all contained within the UK no transboundary
effects on soils and agriculture are expected during the construction or
operation phases of the Sizewell C Project.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 11
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
l) Geology and Land Quality
5.4.16 Potential effects on geology and land quality could arise through direct
contact, dermal contact, inhalation, ingestion, leaching, migration and
discharge of contaminants during the construction and operation of the
Sizewell C Project. Through the analysis of potential contamination linkages,
the assessment identifies the North Sea as a potential receptor and is
considered further within the marine water quality and sediments assessment
in Section 5.4o) of this chapter. All other receptors considered within the
assessment are within UK borders, therefore no transboundary effects on
geology and land quality are expected during the construction or operational
phases of the Sizewell C Project.
m) Groundwater and Surface Water
5.4.17 Transboundary effects could occur through modification of the flow and
quality of groundwater, or surface watercourses, and subsequent discharge
to the marine environment. This could be in the form of an altered
groundwater flow regime, fluvial morphological changes, or changes in water
quality. Management of groundwater and surface water across all project
stages has been designed to maintain natural conditions as far as
practicable. Assessment shows no effects on groundwater would be seen
beyond the development boundary. Fluvial geomorphology effects would
also be restricted to within the development boundary. There would,
therefore, be no transboundary effects on groundwater and surface water
during the construction or operation phases of the Sizewell C Project.
n) Coastal Geomorphology
5.4.18 Effects on coastal geomorphology are localised and would be limited to the
Greater Sizewell Bay. The Greater Sizewell Bay is anchored in the north by
the Blyth river jetties and in the south by the Thorpeness Headland and
underlying erosion-resistant Coralline Crag, which outcrops sub-tidally. The
seaward boundary extends to the eastern flank of the Sizewell-Dunwich
Bank, to include the spatial extent of the proposed cooling water
infrastructure. The landward limit is delineated by the Mean High-Water
Springs (MHWS) tidal mark. As Greater Sizewell Bay does not extend
beyond UK territorial waters no transboundary effects on coastal
geomorphology are expected during the construction or operational phases
of the Sizewell C Project.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 12
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
o) Marine Water Quality and Sediments
5.4.19 Owing to the open coastal system of the Greater Sizewell Bay and the
exchange between it and the wider North Sea, the spatial extent of effects
on Marine Water Quality and Sediments arising from the Sizewell C Project
is dependent on the tidal regime and the transmission and persistence of a
pressure.
5.4.20 ZOIs for marine water quality and sediments have been informed by the
largest-scale potential impacts associated with the Sizewell C main
development site. For the Sizewell C Project, these impacts relate to:
• Results from suspended sediment plume modelling associated with
dredging and drilling activities.
• Thermal plume modelling of the in-combination impacts of Sizewell B
and Sizewell C cooling water discharges (applying the 2ºC mean
excess temperature contour at the seabed).
• Chemical plume modelling for operational releases required as part of
the cooling water system.
5.4.21 For these topics, detailed modelling has been undertaken in consultation with
the relevant statutory consultation bodies (such as the Environment Agency,
Natural England and the Marine Management Organisation). This includes
Suspended Sediment Concentration (SSC) plume modelling for dredging
and disposal activities as well as far-field modelling using internationally
recognised hydrodynamic modelling software. Full technical details of these
assessments and findings are provided within Volume 2, Chapter 21 of the
ES; in summary:
• Marine waters at Sizewell are well mixed such that localised elevations
of SSC quickly redistribute and return to background levels.
• Absolute thermal exceedance is constrained to a very small area
(<1ha). Modest thermal uplifts (2ºC) can extend over instantaneous
areas of thousands of hectares at the sea surface within the tidal
excursion but this does not extend into the waters of other European
Economic Area states.
• For all synthetic compounds released, concentrations rapidly decay in
part owing to the well-mixed conditions of the Greater Sizewell Bay.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 13
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
5.4.22 Based on a complete assessment of the Sizewell C Project and activities that
are capable of affecting water quality and sediments, with the implementation
of primary and tertiary mitigation measures, as detailed in Volume 2,
Chapter 21 of the ES, the environmental assessment undertaken concludes
negligible to minor adverse effects which are not significant.
5.4.23 Based on the highly precautionary ZOIs which have been used and the
subsequent assessments concluding negligible to minor adverse effects, it
can be concluded that there are no transboundary effects expected as a
result of the Sizewell C Project during the construction or operational phases
of the Sizewell C Project.
p) Marine Ecology
5.4.24 Effects on marine ecology and fisheries are assessed for a range of receptors
which, following consultation, are given the following groupings:
• plankton;
• benthic ecology;
• fish ecology;
• marine mammals;
• indirect and Food Web Effects; and
• fisheries.
5.4.25 A range of pressures have been assessed which were given the following
groupings:
• hydrological changes;
• pollution and other chemical changes from sediment resuspension or
discharges;
• physical loss;
• physical damage;
• other physical damage (e.g. noise and light); and
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 14
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
• biological pressures.
5.4.26 The geographical extent of the marine ecology study area was determined
by the potential ZOI for the Sizewell C main development site. The Greater
Sizewell Bay forms the initial reference area for marine assessment
purposes. The Greater Sizewell Bay extends from Blyth Piers in the north to
the Coralline Crag outcrops near Thorpeness in the south. The seaward
boundary extends to the eastern flank of the Sizewell-Dunwich Bank, to
include the spatial extent of the proposed cooling water infrastructure. The
landward limit is delineated by the Mean High Water Springs (MHWS) tidal
mark.
5.4.27 As noted above for marine water quality and sediments, the Greater Sizewell
Bay is an open coastal system and water exchanges between the bay and
the rest of the southern North Sea. The spatial extent of potential impacts
from the Sizewell C Project is therefore dependent on the tidal regime and
the transmission and persistence of the pressure.
5.4.28 The ZOI has been informed by the largest-scale potential impacts associated
with the Sizewell C main development site, which include:
• results from underwater noise modelling during construction activities
(impact pilling, dredging, drilling);
• results from suspended sediment plume modelling associated with
dredging and drilling activities; and
• thermal plume modelling of the in-combination impacts of Sizewell B
and Sizewell C cooling water discharges (applying the 2ºC mean
excess temperature contour at the seabed).
5.4.29 The consultation process identified the need to consider receptor specific
effects beyond the ZOI, particularly for highly mobile species. Effects on
marine ecological receptors are dependent on the distribution, mobility and
ecology of the species being considered relative to the impact. Therefore,
assessments will determine the receptor-specific spatial scale within the
‘Impact Magnitude’ narrative.
5.4.30 The boundary of the study area for commercial fisheries was determined to
be the International Council for the Exploration of the Sea (ICES) rectangles
accounting for the local fishery (ICES rectangle 33F1) and the regional
context (ICES rectangles 32F1, 32F2, 33F2, 34F1 and 34F2). The boundary
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 15
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
of the study area for recreational angling from beaches and boats was ICES
rectangle 33F1.
5.4.31 Applying these study areas and ZOIs, a comprehensive assessment of
effects on marine ecology and fisheries was undertaken concluding
negligible to minor adverse effects (not significant).
5.4.32 Some taxa considered within the assessment do interact with other waters
around British and other international waters; by way of example, recent
studies (BEEMS, 2016m) indicate Smelt from Sizewell and the Rivers
Thames, Waveney, and Great Ouse are from one population, with a total
range of 300km. It is considered probable that the Smelt originate from a
very large population in the River Scheldt in Belgium.
5.4.33 Similarly, due to their migratory nature, transboundary effects could occur
through effects on Twaite shad originating from the Scheldt estuary, Weser
estuary, and Elbe estuary in Germany. Potential effects on Twaite shad are
through the physical interaction between species and project infrastructure
which includes impingement of the fish. No significant effects on Twaite shad
have been identified, thus it is unlikely that significant transboundary effects
would exist
5.4.34 Whilst there is the potential for species to interact with the Greater Sizewell
Bay and other international waters (and therefore other nation states), this is
not expected to constitute any form of significant transboundary effect during
the construction or operation of the Sizewell C Project. This is owing to the
precautionary conclusions of the assessment and the fact that no known
species which undertake international passage are dependent on the specific
environment of the Greater Sizewell Bay (i.e. any species that interact with
the Greater Sizewell Bay as well as international waters are likely to be
accompanied by many other species from other environments elsewhere).
q) Marine Historic Environment
5.4.35 The geographical extent of the study area for the assessment of effects on
the marine historic environment comprises the Sizewell C main development
site boundary below mean high water mark and therefore limited to receptors
within the UK. No transboundary effects on the marine historic environment
are therefore expected during the construction or operation phases of the
Sizewell C Project.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 16
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
r) Marine Navigation
5.4.36 Transboundary effects could occur across national boundaries if Rotterdam
is chosen as the transhipment facility base for abnormal indivisible loads
(AIL) deliveries, leading to additional vessel movements in the Netherlands.
However, due to the low number of vessels involved in AIL deliveries during
the construction and operational phases, relative to the number of vessels
transiting between Rotterdam and UK ports, any transboundary effects are
considered to be negligible (not significant). As set out within Volume 2,
Chapter 24 of the ES, following the implementation of necessary mitigation,
the risk of collision with installation vessels, and the severity of consequence
associated with vessel grounding and fishing gear snagging would be
tolerable (not significant).
s) Radiological
5.4.37 As part of the planned operation of Sizewell C nuclear power station,
discharges of low levels of radioactivity will be made to both the atmosphere
and marine environment.
5.4.38 Volume 2, Chapter 25 of the ES contains a summary of the radiological
effects from the power station. The impacts of radioactive effluent discharges
on human and non-human biota from the operation of Sizewell C nuclear
power station are very low. As such, based on the international recognised
models used in SZC Co.’s assessment, the outputs of which are well below
regulatory threshold levels, it can be concluded that there would be no
significant effects on any Natura 2000 site or other ecological receptor,
designated site or representative person.
5.4.39 The radiological effects have been assessed for receptors in the immediate
vicinity of the Sizewell C nuclear power station, closest to the source of the
radiological discharges, and, as such, are considered to be bounding
because as distance increases from the source the concentration in the
environment will reduce further. Hence, the equivalent receptors in
neighbouring states will incur much lower doses due to the decrease in
radioactivity concentrations seen with distance from release. Collective dose
results have also been assessed and the risks are minuscule and can be
discounted. It is predicted that there will be no transboundary effects from
routine releases.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 17
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
t) Climate Change
i. Greenhouse gases
5.4.40 The receptor for the Greenhouse Gas (GHG) assessment is the global
climate. The impact of GHG emissions from the Sizewell C Project are by
their nature transboundary.
5.4.41 The assessment considers the contribution of the Sizewell C Project
emissions to meeting the UK’s carbon budgets during the construction
period. This covers the period of the published 3rd, 4th and 5th carbon budgets.
There are no recognised carbon budgets outside of the UK for which
transboundary effects could be quantified. On this basis, it is assumed that,
on a worst case basis, the effects described in Volume 2, Chapter 26, would
be considered to be of low magnitude and minor adverse at a transboundary
level.
ii. In-combination climate change impacts
5.4.42 The in-combination climate change impacts (ICCI) assessment considers the
combined impact of climate change and the Sizewell C Project on receptors
in the surrounding environment. The assessments detailed within the
technical chapters of Volumes 2 to 9 of the ES and the summaries provided
for each technical discipline within section 5.4 of this chapter consider ICCI.
u) Major Accidents and Disasters
5.4.43 By definition, unmitigated MA&D hazards and threats could result in
significant environmental effects and may result in transboundary effects.
Following the implementation of the identified mitigation (including
compliance with legislative and regulatory processes, as set out in Volume
2, Chapter 27 of the ES, all risks including any potential transboundary
effects are considered to be tolerable or tolerable if as low as reasonably
practicable and not significant.
v) Health and Wellbeing
5.4.44 Changes in environmental health determinants with the potential to impact
health and wellbeing (air quality and noise in particular) would be relatively
localised to the source. While changes in transport nature/flow rate and
employment would have a wider sphere of influence, this would not extend
any other European Economic Area States during the construction or
operation phases due to the distance between the Sizewell C Project and
any other European Economic Area States.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 18
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
5.4.45 As a result, no associated transboundary effects on health and wellbeing are
expected during the construction or operation phases of the Sizewell C
Project.
5.5 Habitat Regulations Assessment
5.5.1 At the scoping stage, SZC Co. identified a potential pathway for effects on
European sites within the UK. Following consultation on the HRA Stage 1
screening assessment, it was concluded that there was a potential for LSEs
on European sites in Belgium and Germany. As such, these were carried
forward to the HRA Stage 2 appropriate assessment, as potential LSEs could
not be excluded.
5.5.2 Details of these European sites, together with details of their qualifying
features, can be found in the appendices to the DCO Shadow HRA report
(Doc Ref. 5.10). Many of these European sites are distant from the Sizewell
C Project and are being considered because of the presence of migratory
fish that have the potential to interact with the zone of influence of the
Sizewell C Project (specifically the potential for impingement and
entrainment).
5.5.3 In accordance with the Planning Inspectorate’s Advice Note Ten, a screening
matrix for potential transboundary effects has been undertaken, for migratory
fish, identified during consultation at the HRA Stage 1 screening assessment
stage. The screening matrices are based on the assessment of effects and
consultation with relevant statutory and non-statutory bodies (see Appendix
B of Document Ref. 5.10).
5.5.4 Stage 2 of the assessment concluded that for all European sites with
migratory fish as qualifying features (river lamprey, sea lamprey and twaite
shad), the construction and operation of the Sizewell C Project will not have
an adverse effect on the integrity of these European sites.
5.5.5 Stage 2 of the HRA further assessed all LSEs identified at Stage 1. This
concluded that an adverse effect on integrity could not be excluded for the
Minsmere-Walberswick SPA and Ramsar site due to noise and visual
disturbance on the breeding marsh harrier qualifying interest feature during
the construction phase. Adverse effect on integrity can be excluded for all
other European sites, including within other European Economic Area states.
5.5.6 Full details of the HRA process and its findings are reported in the Shadow
HRA report (Doc Ref. 5.10).
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 19
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
5.6 Summary
5.6.1 Potential transboundary effects have been considered for individual topic
areas, which are described within this chapter, based upon available
information and professional judgement. The ES details the assessment for
each topic area and for each of the developments associated with the
Sizewell C Project. The potential for transboundary effects (i.e. effects
predicted outside of UK territory) is considered for each topic, and
conclusions are made as to whether or not any significant transboundary
effects are likely. LSEs have also been considered in the HRA, including the
potential for significant transboundary effects.
5.6.2 As a result of the Sizewell C Project it is predicted that there will be no
significant transboundary effects.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 20
SIZEWELL C PROJECT – ENVIRONMENTAL STATEMENT
NOT PROTECTIVELY MARKED
References
5.1 Planning Inspectorate (PINS) (2018), Advice Note Twelve: Transboundary
Impacts and Process.
5.2 European Commission (EC) (2014), Directive 2014/52/EU Assessment of
the Effects of Certain Public and Private Projects on the Environment (‘EIA
Directive’).
5.3 EC (1992), Council Directive 92/43/EEC (Habitats Directive).
5.4 EC (2009), Council Directive 2009/147/EC (Birds Directive).
5.5 Convention on Environmental Impact Assessment in a Transboundary
Context (Espoo (EIA) Convention) (1997), updated in 2017.
5.6 Her Majesties Stationary Office (2017) Infrastructure Planning
(Environmental Impact Assessment) Regulations 2017.
5.7 HMSO (2007) Marine Works (Environmental Impact Assessment)
Regulations 2007 (as amended).
5.8 HMSO (2017) The Conservation of Habitats and Species Regulations 2017.
5.9 HMSO (2017) The Conservation of Offshore Marine Habitats and Species
Regulations 2017.
5.10 Department of Energy and Climate Change. Overarching National Policy
Statement (NPS) for Energy (NPS EN-1), 2011. (Online) Available from:
https://assets.publishing.service.gov.uk/government/uploads/system/upload
s/attachment_data/file/47854/1938-overarching-nps-for-energy-en1.pdf
[Accessed July 2019].
5.11 Department for Energy and Climate Change (DECC) (2011) National Policy
Statement for Nuclear Power Generation (NPS EN-6)
https://www.gov.uk/government/publications/national-policy-statements-for-
energy-infrastructure [Accessed July 2019].
5.12 PINS (2017) Advice Note Ten: Habitats Regulations Assessment relevant to
nationally significant infrastructure projects.
NOT PROTECTIVELY MARKED
Volume 10 Chapter 5 Transboundary Effects | 21