B1122 Action Group

Response to Sizewell C Stage 2 Consultation 2 February 2017

Primary references:

1. The Document: EDF Energy Stage 2 Consultation document

2. The AECOM Study: Sizewell C, Route D2 and B1122 Study. AECOM, December 2014
produced for Suffolk County Council

Introduction

The B1122 Action Group represents the communities along the B1122 in relation to the issues raised
by Sizewell C. It includes parish councillors from Middleton, Theberton and Yoxford Parish Councils
as well as residents living on or near the B1122. It has never objected to the construction of Sizewell
C in principle, and has always chosen to be constructive in its approach to Sizewell C and the
consultation process. It trusts that its response is received with this in mind.

Stage 1 consultation (11.2)

The Document admits that respondents (no numbers given) expressed concerns that the existing
road is inadequate to accommodate increased levels of traffic, and the additional traffic should
require the provision of a new direct road from the A12. We are disappointed that EDF Energy has
failed to consider this more seriously, given this response.

B1122 - Sheer weight of traffic

We do not accept that the B1122 can carry the traffic that EDF Energy wants without unacceptable
increases in accidents, pollution, noise and congestion. We give our reasons below. EDF Energy
acknowledges that it needs to do further investigations on the likely effects of the increased traffic
flow on the environment, amenity, road safety and highway junction capacity (6.7.11). This calls
into question the the reliability of the modelling to date. Why has this work not been done in the
four years since Stage 1?

Much of the Document relies on gross data for vehicle traffic numbers, which is highly deceptive as it
equates a 40-tonne truck with a Mini. The vast majority of the increase in traffic will be in HGVs and
Park & Ride buses. The data focuses on total daily flows (with and without SZC traffic), and does not
explicitly address peak hourly traffic flows when congestion is most likely to occur, and SZC and non-
SZC traffic will be most adversely affected.

In terms of HGVs and buses through Theberton, the Document gives a total figure for the busiest day
as 1,540, and for the Peak Period 1,090 (Table 6.5). These numbers are comparable with daily
average HGV/bus counts on some sections of UK motorway, for example the M6 Toll (1,069), the
M48 (1,289) and the London end of the M20 (1,481) (https://www.dft.gov.uk/traffic-counts).

It is unacceptable that EDF Energy does not state how long its Peak Period will be. Will it be nine
months or nine years? Will it coincide with the Main Construction Period also unspecified in the
Documents construction labour graph (Fig 5.5)?
Congestion

EDF Energy claims that Traffic modelling identifies that there is no likelihood of congestion or
delay on the B1122. Traffic should continue to flow freely throughout the day (11.10.2). How can
this claim be made when EDF Energy is [still] developing a traffic model (6.5.1), and is continuing
to work with SCC to agree the Base Model (6.5.10)?

Given the sheer volume of traffic planned, we find the claim of no congestion very hard to believe,
and demand that the modelling includes:

- Traffic waiting to turn right across (vastly increased) oncoming traffic, in order to enter side
roads and properties for which current traffic has not been measured
- Normal on-road parking and deliveries
- Level crossing usage and maintenance
- Roadside collection of crops such as sugar beet and potatoes
- Breakdowns of Sizewell C and other vehicles
- Accidents
- Horses, cyclists and mobility scooters
- Pedestrians
- Refuse collection and other slow vehicles such as tractors
- Over-width vehicles e.g. combine harvesters
- Road repairs (see Condition of the B1122, below)
With a constant stream of vehicles in both directions, a significant proportion of which will be HGVs
and P&R buses, opportunities for overtaking slow or stopped road users will be very limited, and
significant congestion will in fact result. We challenge EDF Energy to provide examples of similar UK
roads which are able to carry this level of traffic without congestion or delay.

The Document ignores the impact of any short-term increases in non-Sizewell C traffic, and appears
to have made no allowances for them. EDF Energy confesses that there may be some seasonal
effects on the A12 and at other locations that are not captured by the existing traffic modelling. We
recommend that these are urgently investigated; they should include:

- Sizewell B outages
- Latitude festival
- Bank holiday tourist traffic

Public safety and road accidents

The traffic proposed will bring unacceptable risks to those living along the B1122, and those using it.
While we note EDFs good intentions in attempting to reduce the dangers, the limited measures
proposed barely scratch the surface.

The nature of the additional traffic volume brings substantial risk of accidents, the greatest of which
is, in our view, the junction with the B1125, but there are many other potentially dangerous
junctions and accesses to dwellings along the entire length of the B1122. Users and residents are
used to them, and have developed safety strategies based on the current low volumes of traffic.
Mirrors are used, though they are frequently misted by rain, dew and frost. Listening for oncoming
traffic is another approach, but the planned volume of traffic will prevent this. Some residents when
exiting turn left and make a safe U-turn rather than attempt to turn right across the traffic.
These are a few examples of potentially dangerous road junctions and access to properties:

Doughty Wylie Crescent, Theberton

Church Road, Theberton

Crossroads, Middleton Moor Red Lion pub, Theberton

New houses at Hopton Yard, Yoxford Golden Acres caravan site, Middleton

Valley Farm & Valley View, Middleton Trust Farm, Middleton

None of those shown above will be affected by the proposed changes to speed limits (11.12).
The above may explain why the AECOM study estimated that using the alternative D2 route would
save a net 103 accidents, and 158 injuries and fatalities (Table 7: Accident costs and benefits, page 8)
compared to using the B1122.

Experience from Sizewell B indicates that rat-running along the B1125 through Westleton and along
minor lanes will become the norm, to avoid the congestion. The Document acknowledges this
(6.7.1). This will add substantial traffic to routes not equipped for such volumes, and will increase
the likelihood of accidents further.

Pedestrians

Currently the B1122 is occasionally used on foot, due to the low levels of current traffic. There are
several sections of adjoining properties with no pedestrian footpaths, or very narrow and overgrown
paths. They include Middleton Moor, and from Beveriche cottages to the A12/ B1122 junction/ bus
stop.

The traffic planned for the B1122 will endanger any pedestrians, and will make using even the
limited footpaths risky and intimidating.

Speed limit reductions

Effective speed management depends on enforcement. We note that a recent (20 Dec 2016 to 9 Jan
2017) Theberton traffic monitor recorded 75-80% of drivers exceeding the 30mph limit. With
ongoing reductions in the size of the Suffolk Constabulary, and its concerns about policing already
voiced to EDF Energy, there will need to be substantial investment in speed cameras to ensure that
speed limits are observed and the already high number of likely accidents is not increased.

We recommend the implementation of an average speed camera system from the A12 junction to
the site entrance.

Health, noise and pollution

The population along the B1122 is older than average, and includes the residents of two retirement
homes. Health impacts are especially important given this vulnerable group. EDF Energy has yet to
research the noise and pollution levels that can be expected. Why has this not been conducted in
the four years since Stage 1?

We trust that EDF Energys research takes into account the very latest studies including the effects of
both noise and pollution on the incidence of dementia, Parkinson's disease, multiple sclerosis,
myocardial infarction (heart attacks), pre-eclampsia and pregnancy-induced hypertensive disorders.

Vibration damage

There are many properties along the B1122 that will suffer vibration damage, especially the older
(mostly listed) properties with little or no foundations. How will EDF Energy mitigate this and
compensate owners? What size and weight will the trucks be?
Tourism

The traffic volumes and road congestion on the B1122 will have a significant detrimental effect on
the important tourist industry, deterring visitors not only during construction, but also, in breaking
the habit of visiting, for some years afterwards.

Emergency Access (11.10.3)

We are very disappointed that, despite the concerns raised at Consultation Stage 1, the emergency
and evacuation route for Sizewell C and presumably A and B remains the B1122. Given the roads
inevitable congestion, this is a disaster waiting to happen. We note that EDF Energys comment that
in the event of an incident or accident preventing the free flow of traffic on the B1122, other routes
are available for both Sizewell C-related and other traffic. We demand that EDF Energy provides
details of these other routes and how traffic will be directed and managed on them, especially in the
case of a major emergency and evacuation, or terrorist incident.

A new direct road from the A12 (11.10.2)

EDF Energy argues that a new direct road is not necessary or appropriate for the following reasons:

Traffic modelling identifies that there is no likelihood of congestion or delay on the B1122.
Traffic should continue to flow freely throughout the day. This has been addressed under
Congestion, above.

the B1122 was the approved HGV route for Sizewell B and remains an approved HGV route,
(with) regular daily HGV movements EDF Energy is not aware of evidence to suggest that
either previous or current HGV usage of the B1122 has given rise to significant problems in
terms of congestion or accidents.

This is a spurious argument, as the proposed traffic is on an entirely different scale to what
has gone before, and the potential for congestion and accidents increases exponentially.
We challenge EDF Energy to produce comparable data from Sizewell B. EDF Energy will be
aware of the evidence of the AECOM study which estimated that building the D2 route
would save a net 103 accidents.

Even though Sizewell B is half the size of C, a direct access route from the A12 was seriously
considered for its construction, and the D2 was judged to be the optimum route. If it was a
serious consideration for B, why does EDF Energy refuse to countenance it for C?

since the construction of Sizewell B, the balance of planning policy has shifted to some
degree away from the provision of new highways infrastructure and more in favour of
measures to reduce traffic demand. The latter measures are not sufficient, and therefore
the former is necessary (see Planning policy considerations (11.3), below).

EDF Energys proposals for a major role for sea and rail deliveries, an accommodation
campus sited at the main development site and park and ride facilities are examples of
demand management measures. All these are factored into EDF Energys unacceptable
traffic forecasts. However if, for whatever reason, any measures have to be downgraded in
 scale, it will place an even greater burden on road transport and therefore the B1122. Will
EDF Energy then reassess the need for a direct link road?

Any new direct road from the A12 to the Sizewell C site would be likely to give rise to a
range of adverse environmental impacts, would be costly to develop and would in itself
require significant additional HGV movements on the local road network to deliver the
necessary materials for construction of the road.

o Environmental impacts: Examining the D2 alongside smaller by-pass concepts for

Theberton and Middleton Moor, the AECOM Study summarises as follows:
Biodiversity effects from all sites will be minimal although slightly more
adverse for the D2 route given its position on Greenfield sites and across
multiple water crossings. Through further investigation and more sensitivity
in design, this effect could be reduced further.
It was concluded that the proposed carriageway is likely to affect the water
perspective of the analysis due to the high amount of water crossing situated
along all routes. Appropriate mitigation measures can reduce the impact to
negligible to minor.
The AECOM study details and justifies these points in substantial detail.

o Cost: The AECOM study estimated that the D2 route would cost 54.8 million. This
would represent a 0.38% on-cost to Sizewell Cs probable c.15 billion price ticket.
D2 could however reduce other costs to EDF Energy, by saving on fuel and B1122
repairs, and by improving demand management measures such as workers
accommodation, Park & Ride and consolidation of deliveries.

o HGV movements required for building D2: These would precede or coincide with the
very earliest stages of Sizewell Cs construction, and it should be possible to route
the majority of movements via the A12. It would not be comparable to the traffic
that would otherwise have to use the B1122 if the D2 is not built.

Delivery of a new road may also require compulsory acquisition of land; and once the main
construction phase is complete, the long-term additional traffic flows and HGV movements
on the B1122 associated with the operational phase of Sizewell C would be considerably
lower than during the construction phase. This, therefore, reduces the justification for a
major new permanent road development in the form of a new direct road to the Sizewell C
site from the A12.

EDF Energys statement about the Cannington bypass for Hinkley Point C states: The work
forms part of a 16 million package of local road improvements paid for by EDF Energy to
provide a permanent lasting legacy from the construction of Hinkley Point C. If EDF Energy
is happy to provide a lasting legacy for the people of Somerset, we question why this is not
the case for Suffolk? (www.edfenergy.com/energy/nuclear-new-build-projects/hinkley-
point-c/construction)
Condition of the B1122 (11.10.3)

EDF Energy admits that it has not yet conducted any form of survey into the current structural
integrity of the B1122 (meeting 7 Jan 2017), and these would not take place until after Stage 3
consultation. Cracking can be seen in many places along the B1122; we believe these follow the join
of the original road with sections of extra width added for the construction of Sizewell B. It follows
that substantial repair and reconstruction is very likely before construction traffic can start, as well
as during the 12-year construction period, exacerbating congestion still further and delaying
construction. Given the significant cost involved we argue that surveys and cost estimates should be
completed immediately, so that alternatives such as the D2 can still be considered.

A12/ B1122 Junction (11.11)

We challenge the (incomplete) traffic modelling and its claim (11.11.7) that both the roundabout
and the traffic signals options would accommodate the Sizewell C traffic and any increases in traffic
flows, and neither would result in traffic queuing, including back to the junction of the A12 with the
A1120.

We understand that EDF has used the ARCADY computer model which was developed to optimise
the design of roundabouts in order to maximise flow rates. It is not clear whether this program is
capable of accurately predicting the lengths of queues, and further methods may be required. These
types of model, which should take account of random events such as the arrival of individual
vehicles, are not capable of giving absolute results and normally only provide average values. As a
result, their findings are sensitive to the assumptions made and the input data used. In traffic
analysis, averaged vehicle arrival rates will give vastly different results where vehicle strings, as are
normal on the A12, are accurately simulated. EDF Energy has used the average vehicle flow rates as
provided by traffic surveys which are likely to underestimate congestion levels. We ask EDF Energy
to conduct a more robust modelling exercise.

The effect on the A12/A1120 junction, only 150 metres away, has therefore not been properly
assessed, nor has it been included in either of the B1122 junction options. Traffic on the southbound
A12 also frequently backs up at the A12/A1120 junction when a vehicle needs to cross the
northbound traffic in order to join the A1120; it has been known to extend as far as the Westleton
Road junction, around 600m to the north. With the increased northbound traffic for Sizewell C and
the Darsham Park & Ride, this will quickly tail back onto the B1122 junction, bringing it to a halt.

The A12/A1120 junction also often backs up westwards along the A1120 (Yoxford High Street) as
vehicles wait to join the A12, exacerbated by (legally) parked cars which restrict the road to
alternate passing. As vehicles from the south will now have to wait to enter the new A12/B1122
junction - whether it is a roundabout or traffic light controlled this will cause lengthy queues and
congestion back along the High Street.

Neither the roundabout nor the traffic light options will be capable of handling the planned traffic
onto the B1122 unless a junction can be devised that encompasses both the B1122 and the A1120.
While we are not traffic engineers, we fail to see how this can be accomplished without the
demolition of one or more buildings, which would be unacceptable.

The only solution is to route A12 traffic bound for Sizewell C via a new direct road such as the D2.
Smaller village bypasses on the B1122 itself would not have any impact on the problems of the
A12/B1122/A1120 junction.
Planning policy considerations (11.3)

The Document quotes from the key planning guidance for Nationally Significant Infrastructure
Projects (NSIPs), such as Sizewell C, in National Policy Statement (NPS) EN-1:

Where mitigation is needed, possible demand management measures must be considered and if
feasible and operationally reasonable, required, before considering requirements for the provision of
new inland transport infrastructure to deal with remaining transport impacts.

EDF Energy acknowledges that the guidance recognises that, where residual transport impacts of
significance remain after demand management measures have been implemented, it may be
appropriate to propose new highway infrastructure measures to mitigate them.

The demand management measures proposed are insufficient, residual transport impacts of
significance do indeed remain, and there are no feasible further demand management measures
that would remove these. It is therefore inescapable that new highway infrastructure measures are
required.

Conclusion

EDF Energy states that it wants to be a good neighbour and that it is committed to limiting or
mitigating any adverse effects on local communities and the environment (Foreword).

It has also stated in meetings that safety is its overriding consideration.

In this context, and in the spirit of true consultation, we ask them to review the D2 option seriously,
given how it would improve the safety of local people and workers, and its benefits to the Sizewell C
project as a whole.

Charles Macdowell
Chair
B1122 Action Group