Interim Consultation Report

Transcription

1 Interim Consultation Report The Moorside Project SEPT 2017

2 Contents Executive Summary 7 Stage Two Consultation Response 7 Next Steps 8 1. Introduction Consultation This report Policy context Statutory context Overview of the pre-application process Preliminary consultation with statutory consultees Overview Identification of consultees Consultation activity Stage One: Statement of Community Consultation Legal requirements of the SoCC Informal local authority consultations Formal consultation on the draft Stage One SoCC Responses to the draft Stage One SoCC Stage One: Consultation with statutory consultees Statutory context Identification of local authorities and prescribed bodies using the methodology in section Stage One: Consultation with the Community (s 47) Stage One Consultation Details of individual activities Variations from the SoCC Stage One: Publicity under section Statutory context Publicity Regulation 11 of the Infrastructure Planning (Environmental Impact Assessment) Regulations Stage One: Feedback from Statutory Consultees Statutory context DCLG guidance Issues Stage One: Feedback from the Community (section 47) Quantitative data / feedback forms Demographics Results Qualitative data Group responses 45 PAGE 2

3 Contents 9. Stage Two: Consultation Statement of Community Consultation DCO Stage Two SoCC The lessons learned following the Stage One Consultation The Statement of Community Consultation Legal Requirements Informal local authority consultation Formal consultation on the draft Stage Two SoCC Responses to the draft Stage Two SoCC Consultation with local authorities Publication of SoCC Stage Two: Consultation with Statutory Consultees, Section Statutory Context Identification of Consultees Duty to Notify the Secretary of State of Proposed Application under Section Consultation Activity Stage Two: Consultation with the Public (s 47) Stage Two Consultation Consultation Documents Consultation Events Promotion 57 Direct mail 57 Press advertising campaign 58 TV/Radio 58 Posters 59 Social media 59 Presentations Information availability Variations from the SoCC 60 Additional activities 60 Deviations Stage Two: Publicity under Section Statutory Context Publicity Stage Two: Feedback under Section Overview DCLG guidance Issues Breakdown of feedback received: Statutory Consultees and Local Authorities Breakdown of feedback received: Non-Statutory Organisations Feedback Overview 70 PAGE 3

4 Contents 14. Stage Two: Community Feedback under Section Overview Respondent Location Methodology Feedback Overview Stage Two: Informal Engagement Processes Moorside Technical Group Elected Members Briefings Local Authorities, Planning Performance Agreement and Key Stakeholder Support EIA Quarterly Groups Health Impact Assessment Nuclear Transport Liaison Group Informal Local Stakeholder Workshops Moorside Parishes Group Sellafield / NDA Liaison Arrangements Schools and Community Further Education and Training Organisations Informal Consultation with other EEA States Local Liaison Arrangements 80 PAGE 4

5 Contents Appendices 81 Appendix 1. Preliminary Consultation Report 81 Appendix 2. Stage One Statement of Community Consultation a. Comments from local authorities b. Final Statement of Community Consultation c. Published SoCC Notice Appendix 3. Stage One Consultation 81 a. Overview 81 b. Newsletter 81 c. Press coverage 81 d. Advertisement 81 e. Poster 81 Appendix 4. Stage One: Hard to reach groups 81 List of groups and contacts 81 Appendix 5. Stage One: statutory consultees 81 Prescribed consultee list 81 Appendix 6. Stage One: s48 notice 81 a. Published notice 81 b. Letter to statutory consultees (Regulation 11) 81 Appendix 7. Stage One Consultation feedback 81 a. Issues raised by statutory consultees and organisations 81 b. Summarised issues raised by public response. 81 Appendix 8. Stage Two Statement of Community Consultation a. Consultation Strategy 81 b. Local authorities comments on the draft DCO Stage Two Statement of Community Consultation c. Statement of Community Consultation d. Published SoCC Notice Appendix 9. Stage Two: Statutory Consultees 81 a. Section 42 consultee list 81 b. Letter to statutory consultees 81 c. Section 46 Letter 81 PAGE 5

6 Contents Appendix 10. Stage Two Consultation 82 a. Proposed Scheme Overview 82 b. Newsletter 82 c. Advertisement 82 d. Poster 82 Appendix 11. Stage Two: Hard to reach groups 82 List of groups and contacts 82 Appendix 12. Stage Two: s48 notice 82 Published notice 82 Appendix 13. Stage Two Consultation feedback 82 a. Issues raised by statutory consultees and organisations 82 b. Summarised issues raised by public response 82 Appendix 14. Moorside Technical Group 82 a. Membership and terms of reference 82 b. LA Presentation on DCO Stage 1 82 PAGE 6

7 Executive Summary NuGeneration Limited is preparing an application for a Development Consent Order ( DCO ) to the Secretary of State for Business, Energy and Industrial Strategy and the Secretary of State for Transport in respect of the Moorside Project - a new nuclear power generating station, new rail infrastructure (railway track, spurs and platforms) and Associated Development that includes accommodation sites and other infrastructure development. The proposed DCO would relate to the Moorside Site, the Accommodation Sites and the Additional Sites, all of which are in Cumbria. The Moorside Site is located on the nominated area of land identified in the National Policy Statement for Nuclear Power Generation (EN-6). Consultation is a key part of the DCO preparation process. NuGen is committed to effective and inclusive consultation and engagement during the course of the preparation of the DCO application. Consultation enables stakeholders to engage meaningfully in the development of the Moorside Project before an application is submitted to the Secretary of State. NuGen has carried out a multi-stage consultation process. This report follows the completion of the Stage Two Consultation that asked for views on NuGen s Proposed Scheme. Previously in the Stage One Consultation NuGen asked for views on the strategic approach it should adopt. This report, the second Interim Consultation Report, brings together information on the consultations NuGen has carried out to date, and summaries of the views collected so far. As NuGen is currently analysing the responses received, this Report does not explain how NuGen has had regard to the responses. This explanation will be included in the final Consultation Report that will be submitted with the application once it is made. Stage Two Consultation response NuGen s first interim consultation report (defined as the Interim Consultation Report May 2016 in the Stage Two Consultation) was published in 2016 and provided information on its preliminary consultation and Stage One Consultation. This Interim Consultation Report 2 updates the original Interim Consultation Report and adds information on the more recent Stage Two Consultation. The Stage Two Consultation covered both prescribed consultees, and persons with an interest in land that could be affected by the proposals, as required by section 42 of the Planning Act 2008 (PA 2008). In addition, NuGen carried out a much wider consultation with the community as a whole as required by section 47 of PA 2008 and also nationally under section 48 of the PA The details of how these consultations were carried out, and summaries of the responses, received are included in this report and its appendices. In response to the Stage Two Consultation, NuGen received 38 responses from organisations and 1,226 responses from the community. This is a significant increase in the number of people who engaged in the Stage One Consultation the previous year, when NuGen s strategic approach had received strong support. PAGE 7

8 Executive Summary As part of the Stage Two Consultation, NuGen encouraged responses against a number of topics. The topics that generated most responses were: the layout of the Moorside Power Station and development in its immediate vicinity; the legacy benefits that NuGen will leave; highways issues; health and other impacts; and a number of responses falling outside the topics and into the other category. In relation to the location of the Moorside Power Station, the main issues were: closeness to Beckermet village; the location of the electricity substation; the landscape mounding; whether Nursery Road could be kept open; and suggestions for changes to the proposed Property Support Scheme (a voluntary scheme that NuGen has committed to offering). Under the topic of legacy benefits, a wide range of additional possible benefits were suggested for NuGen to consider. There was also a recognition of the economic benefits of the investment and the jobs being created through the Moorside development generally. The subject of the highways saw concerns raised about traffic and parking and many people thought NuGen needed to carry out more highway improvements than had been included in the proposals at Stage Two. The organisations that responded to the consultation, including statutory prescribed consultees who provided a wide range of comments overall. However, as many consultees have specific responsibilities, many responses were focused on those responsibilities only. A common theme from the Stage Two Consultation was the request for more detailed design information for the Moorside Project. NuGen is committed to an iterative consultation and sharing with the public its progress on developing the Moorside Project, even if this means that certain elements are not as advanced as other elements. This has the benefit of enabling the public and stakeholders to be part of the iterative and evolving design process, meaning that they can input and influence the design solutions. Following the conclusions of the strategic review and further design, survey and assessment work, NuGen is committed to presenting the Moorside Project at a further round of consultation before the final design is prepared for submission to the Secretary of State. Next steps In line with the potential change in shareholding at NuGen, it is undertaking a strategic review which may result in changes to the Moorside Project proposals. When the strategic review is completed, NuGen will continue developing the project, taking into account both the outcome of the review and all the consultation responses it has received. NuGen has used the consultation information received to help review the project and, wherever possible seek solutions in the project design that deliver the preferences of consultation respondents. This is a process that cannot be finalised until after the conclusion of the strategic review, when any changes to the project required by new investors are known. NuGen is committed to carrying out another consultation when additional information is available and any revisions arising from its strategic review and the Stage Two Consultation are determined. When the final project proposals have been developed, which will be after another round of statutory consultation, NuGen will prepare a formal statutory Consultation Report describing all the consultation carried out and how it has had regard to the responses received. This will be among the documents submitted with the DCO application. PAGE 8

9 1. Introduction NuGen has been developing proposals for the construction, operation and maintenance of a nuclear power station, together with railway works between Corkickle and Mirehouse, St Bees and at the Moorside Site, amongst other development (which includes a marine off-loading facility at the Moorside Site, highway improvements and worker accommodation). NuGen calls this the Moorside Project. The land for the proposed Moorside Power Station has been identified by the UK Government in National Policy Statement EN-6, as potentially suitable for a new nuclear power station. As the Moorside Power Station and the Moorside Project Railway are Nationally Significant Infrastructure Projects (NSIPs), NuGen is required to make an application to the Secretary of State for Business, Energy and Industrial Strategy and the Secretary of State for Transport for consent to build, operate and maintain the Moorside Power Station and the Moorside Project Railway, together with Associated Development. This consent is known as a Development Consent Order (DCO). At the time of publication of this updated Interim Consultation Report, the Moorside Project is the subject of a strategic review. The review will consider the future ownership of NuGen, its shareholder/investor structure and any implications of such changes on the Moorside Project. This report is, therefore, not intended to satisfy the statutory requirement, under section 37(3)(c) of the PA Section 37 requires the applicant to submit a report on the consultation that has been carried out and to demonstrate how the applicant has had regard to the consultation in developing its proposals. This can only be done when the development of the Moorside Project proposals is complete, further consultation has taken place and NuGen is in a position to set out how the final Moorside Project proposals take into account the consultation responses. Therefore, NuGen has chosen to produce this non-statutory report to keep stakeholders informed about NuGen s consultation activities. This report is intended to provide an update to the Interim Consultation Report published after the Stage One Consultation in Consultation Before a DCO application is submitted, NuGen is required to consult with those living in the vicinity of the land proposed for development under section 47 of the PA 2008, as well as publicising the proposed application nationally under section 48 of the PA In addition, section 42 of the PA 2008 requires applicants of DCO applications to consult with persons with an interest in the land and prescribed local authorities and statutory bodies. NuGen has carried out multiple stages of consultation on the Moorside Project so far. The stages of consultation can be summarised as follows: Preliminary consultation early engagement, January February 2012; Stage One Strategic Issues Consultation, 16 May July 2015; and Stage Two Proposed Scheme Consultation, 14 May July PAGE 9

10 1. Introduction Stage One Consultation was carried out in line with sections 47 and 48 of the PA Stage Two Consultation was carried out in line with sections 42, 47 and 48 of the PA 2008 These stages of consultation will help shape the Moorside Project prior to the DCO application being submitted. All of the issues raised in the consultation to date will continue to be considered by the project team as the proposals are further developed. Feedback as to how all of the issues raised have been taken into account in developing the Moorside Project will not be possible until after the final designs have been confirmed. NuGen has described the main issues that have been raised in the consultation later in this report. These will be highlighted and it will be indicated how they have influenced the development of NuGen s proposals when it consults again. NuGen is currently undertaking a strategic review of the Moorside Project. There will be a further formal Stage Three Consultation on the Moorside Project (together with an explanation as to any changes since the Stage Two Consultation) before the DCO is submitted This report This report includes the details of all formal consultation to date on the Project to date, including summaries of the relevant issues raised in both Stage One Consultation and Two Consultation. It also includes the details of the activities carried out as part of the Stage One Consultation and the State Two Consultation and the development of the Statement of Community Consultation that NuGen produced pursuant to the PA 2008 for both stages. In addition, a preliminary consultation, which was held with a number of statutory consultees and other groups early in the process, is covered in summary in this report. NuGen intends that this report will help keep stakeholders and the public informed about what is being done with their contributions to the Moorside Project to date. Following the close of the Stage Two Consultation, NuGen considered all the feedback received under sections 42, 47, and 48 of the PA 2008, and carried out a project options review which considered the stakeholder and public responses alongside engineering, delivery and cost considerations. This information has been used by NuGen to provide guidance that will be used in the next round of design development. The decision to undertake a strategic review of the Moorside Project means that any further design work is being held in abeyance until the review has been completed and any consequent implications for the project design understood. When NuGen submits its application for a DCO, a full consultation report, that complies with Section 37 of the PA 2008, will be submitted describing all the consultation NuGen has undertaken, the responses received, and explaining how these responses have been taken into account in the final scheme proposals. PAGE 10

11 1. Introduction 1.3. Policy context The Secretary of State must determine NuGen s future application for a DCO in accordance with the PA 2008 and the following national policy statements: Overarching National Policy Statement for Energy (NPS EN-1); National Policy Statement for Nuclear Energy Generation (NPS EN-6); and National Policy Statement for National Networks (NPS-NN). These documents can be viewed in detail at the following web addresses: Collectively, these national policy statements establish that there is an urgent need for new electricity generating capacity, including from nuclear. NPS EN-6 makes clear that the need for a nuclear generating station, at what is named the Moorside Site, has been demonstrated (it is referred to in the national policy statement as Sellafield ). The Moorside Project is a priority project in the National Infrastructure Plan (2014). Paragraph of NPS EN-6 states that the Secretary of State should not duplicate the functions of the nuclear regulators the Office for Nuclear Regulation (ONR) and the Environment Agency (EA). As such the remit of the DCO process will focus on local impacts but not matters related to nuclear safety, security, protection of people or the safe transport of nuclear material and environmental permitting matters. These matters will be considered by the ONR, the EA and other agencies through the nuclear site licence process and environmental permitting processes Statutory context NuGen intends to apply to the Secretaries of State under the PA 2008 for a DCO to construct, operate and maintain the Moorside Power Station, Moorside Project Railway and Associated Development related to it. The DCO is also proposed to include powers for the compulsory acquisition of land and interests in land to allow for the effective delivery of the Moorside Project. If the application is accepted, an Examining Authority will be appointed to examine NuGen s application and representations made on it by interested parties. The Examining Authority will then submit its recommendation on the application to the Secretaries of State who will make the final decision. Relevant local authorities will have an important role in this process. Local authorities, which may include Copeland Borough Council, Allerdale Borough Council, Eden District Council, Barrow-in-Furness Borough Council, Carlisle City Council and Cumbria County Council, may comment upon both the content and the quality of the statutory consultations carried out by making an adequacy of consultation representation to the Planning Inspectorate shortly after the application is submitted. Relevant local authorities will also be invited to produce a local impact report following the submission of NuGen s DCO application, which will give details of the likely impacts on the authorities area(s) arising from the Moorside Project. The Secretary of State must have regard to any local impact reports when deciding whether or not to grant a DCO for a project. Anyone will be able to comment on the proposals during a future Stage Three Consultation, and views from consultees will again be important in helping NuGen to develop the Moorside Project further. Once NuGen s application has been accepted for examination, then anyone will be able to register and make representations regarding the Moorside Project to the Examining Authority during the consultation that will take place following the acceptance of the application and before the commencement of the Examination. PAGE 11

12 1. Introduction Further information on the DCO process can be found on the Planning Inspectorate s website (www. infrastructure.planningportal.gov.uk/application-process/the-process) Overview of the pre-application process Section 42 Stage Persons with Interest in the Land (PILs) Prescribed bodies and local authorities Section 47 (local community) Section 48 (wider publicity) Preliminary December 2011 February 2012 Early engagement on top level issues and future consultation methods - Non-statutory consultation, covered in Chapter 2 of this Interim Consultation Report Stage One May July 2015 N/a Strategic issues consultation Non-statutory consultation covered in chapter 4 of this Interim Consultation Report Strategic issues consultation Statutory consultation covered in chapters 5 of this Interim Consultation Report Strategic issues consultation Statutory consultation covered in chapter 6 of this Interim Consultation Report Interim Consultation Report published 2016 and DCO Stage One Feedback Report November 2015 Stage Two May July 2016 Proposed Scheme Consultation Statutory consultation covered in chapter 10 & 13 of this Interim Consultation Report 2017 Proposed Scheme Consultation Statutory consultation covered in chapter 11 & 14 of this Interim Consultation Report 2017 Proposed Scheme Consultation Statutory consultation covered in chapter 12 of this Interim Consultation Report 2017 Interim Consultation Report 2017 Figure 1 Consultation Timeline NuGen adopted the approach recommended in DCLG Guidance that, to be of maximum value, consultations should take place at a formative stage, providing consultees with a real opportunity to influence the proposals. NuGen has consequently implemented a staged and iterative approach of preliminary consultation, then strategic issues consultation followed by consultations on the proposed scheme as it emerged. PAGE 12

13 2. Preliminary consultation with statutory consultees 2.1. Overview From December 2011 to February 2012, NuGen undertook preliminary consultation with various consultees. The aim of this consultation was to enable consultees to highlight any relevant technical information or initial comments the consultees felt should be considered at this early stage in the development of the Moorside Project. The information obtained from the comments received during this period helped inform the Moorside Project as well as the approach to future consultation. A full report on this preliminary stage of consultation is included in Appendix 1. This includes full details of who was consulted, the feedback received and how it has been taken into account Identification of consultees NuGen contacted 172 consultees as part of this preliminary consultation. Those contacted at this stage included statutory consultees and persons with an interest in the land as defined in section 42 of the PA 2008 and as were identifiable at this stage in the early evolution of the Moorside Project. NuGen took the view that it was also appropriate to extend this initial stage of consultation to selected, relevant non-section 42 consultees. These consultees consisted of the following. Relevant organisations not qualifying as prescribed consultees these included organisations which were likely to take on relevant functions and responsibilities of one or more prescribed consultees in the future. For example, the Cumbria Local Enterprise Partnership (LEP) was consulted in addition to the North West Regional Development Agency due to the abolition of Regional Development Agencies. Persons not qualifying as landowners who expressed a desire to make a comment at this initial stage of consultation these included local residents and nearby landowners who could be directly consulted at later stages of the consultation and engagement process, for example as part of the section 47 consultation with local communities Consultation activity Consultees were sent a pack containing the following information in December 2011: a letter outlining the Moorside project; initial questions on possible key issues; a site location plan; and a site context plan. The letter introduced consultees to the Moorside Project and NuGen s plans to build a nuclear power station and Associated Development in West Cumbria. Consultees were encouraged to contact NuGen with their initial feedback on a set of four questions. These questions sought comments on general, local and site-specific issues that consultees considered that NuGen should be aware of at this early stage, as well as a question seeking feedback on the methods of future engagement that NuGen should consider undertaking as the Moorside project progressed. NuGen received 56 responses from the 172 information packs issued. 428 individual comments were made in response to this preliminary consultation. A full report on this preliminary consultation is included as Appendix 1. PAGE 13

14 3. Stage One: Statement of Community Consultation This chapter summarises discussions and consultations around the drafting and publishing of a Statement of Community Consultation (SoCC) for the Stage One Consultation (referred to as the Stage One SoCC ), in accordance with section 47 of the PA This includes discussions with affected local authorities ahead of a first draft being issued for comment, the responses to the formal consultation on the Stage One SoCC, and NuGen s responses to them. Where projects carry out multiple stages of consultation, it is common to publish multiple distinct SoCCs. These SoCCs are typically similar in structure, evolving from the previously published SoCCs, using lessons learned from early stages of consultation to refine and improve consultation activity. In line with this approach, a revised SoCC was prepared and consulted for the Stage Two Consultation. The details of this process have been included in section 9 of this report Legal requirements of the SoCC Under section 47 of the PA 2008, applicants must prepare a statement setting out how the applicant proposes to consult, about the proposed application, with people living in the vicinity of the land. The content of the SoCC, must first be the subject of consultation with the host local authorities. For reference, section 47 of the PA 2008 says: 47. Duty to consult local community (1) The applicant must prepare a statement setting out how the applicant proposes to consult, about the proposed application, people living in the vicinity of the land. (2) Before preparing the statement, the applicant must consult each local authority that is within Section 43 (1) about what is to be in the statement. (3) The deadline for the receipt by the applicant of a local authority s response to consultation under subsection (2) is the end of the period of 28 days that begins with the day after the day on which the local authority receives the consultation documents. (4) In subsection (3) the consultation documents means the documents supplied to the local authority by the applicant for the purpose of consulting the local authority under subsection (2). (5) In preparing the statement, the applicant must have regard to any response to consultation under subsection (2) that is received by the applicant before the deadline imposed by subsection (3). (6) Once the applicant has prepared the statement, the applicant must: (za) make the statement available for inspection by the public in a way that is reasonably convenient for people living in the vicinity of the land; (a) publish, in a newspaper circulating in the vicinity of the land, a notice stating where and when the statement can be inspected, and (b) publish the statement in such manner as may be prescribed. (7) The applicant must carry out consultation in accordance with the proposals set out in the statement. PAGE 14

15 3. Stage One: Statement of Community Consultation The overarching goal of a SoCC is to lay out a consultation approach and framework that fully adheres with the statutory requirements and government guidance on pre-application consultation for NSIPs, while also adapting this to carry out effective communication and engagement for the specific local community in question Informal local authority consultations NuGen has maintained on-going dialogue with the relevant local authorities over a number of years prior to the development of the Stage One SoCC. This covered a broad range of issues related to the development of the Moorside Project. At this early stage, NuGen engaged with three local authorities over the Stage One SoCC: Copeland Borough Council; Cumbria County Council; and Allerdale Borough Council. The latter was included as a potential statutory consultee for the Stage One SoCC due to the possibility of Associated Development being located in that borough. In the event, no such developments were proposed in Allerdale at the Stage One Consultation. Key dates in the development of the Stage One SoCC are summarised in the following table: Date Action Purpose 16th October 2014 Local Authority meeting Review and advise 8th January 2015 Local Authority meeting Review and advise 3rd February 2015 Submission of an informal draft Early consultation 5th February 2015 Local Authority meeting Review and advise 2nd March 2015 Formal draft SoCC submission 28 day consultation period 1st April 2015 Responses received from Local Authority Review and comment 15th April 2015 Final SoCC publication Inform Figure 2 DCO Stage One SoCC Development At meeting of 8th January 2015 with the three authorities, NuGen presented the initial draft proposals for the Stage One SoCC consultation and a range of issues were discussed. These were as follow. What is being consulted on Scope of consultation o Geographical o Stakeholders Methods of consultation Publicising the consultation Programme PAGE 15

16 3. Stage One: Statement of Community Consultation SoCC o Stage One Consultation o Stage Two Consultation Proposed consultation locations Proposed structure of SoCC document Related consultations Hard-to-reach groups Opportunities for adjoining district councils and the Lake District National Park Authority (LDNPA) to influence the SoCC. Establishment of a fixed consultation exhibition at the proposed Whitehaven Civic Hall. This discussion, and the subsequent feedback provided by the local authorities, informed the first informal draft of the Stage One SoCC which was provided to them on 3rd February Comments were invited by 13th February 2015 in order to inform the final version of the draft Stage One SoCC that would be the subject of formal consultation Formal consultation on the draft Stage One SoCC The consultation draft of the Stage One SoCC was provided to Copeland Borough Council, Cumbria County Council and Allerdale Borough Council for their formal consideration on 2nd March Responses were requested to be submitted within 28 days beginning the day after the local authorities received the consultation document (as per section 47 of the PA 2008). Prior to that date, the other five planning authorities in Cumbria, Carlisle City Council, Eden District Council, South Lakeland District Council, Barrow-in-Furness Borough Council, and the Lake District National Park Authority, were informed by NuGen that the draft Stage One SoCC was being issued and that there was an opportunity for their views to be considered by submitting them to the County Council, to be incorporated into its formal response. Inviting feedback from these five authorities exceeded NuGen s statutory duty under the PA 2008 and was a process that had been agreed with Copeland Borough Council, Cumbria County Council, and Allerdale Borough Council in advance. A presentation on the content of the draft Stage One SoCC was made to the local authorities on the 11th March At the request of the County Council, NuGen gave presentations to the Copeland and Allerdale local sub-committees of the County Council on the proposed content of the Stage One SoCC. PAGE 16

17 3. Stage One: Statement of Community Consultation 3.4. Responses to the draft Stage One SoCC Responses were received from Copeland Borough Council, Cumbria County Council and Allerdale Borough Council covering 112 individual comments. The feedback was reviewed by the NuGen project team and 97 of the comments resulted in changes to the Stage One SoCC. Most of these were text changes and clarifications, as the main structure of the document had been the subject of earlier discussion at the informal stage. The main content changes to the Stage One SoCC included: clarifying NuGen s approach to engaging hard to reach groups; adding two further exhibition events to the consultation programme at Bootle and Wigton; a workplace event was added at the Sellafield Site; allowing for presentations to a wider range of parish councils on request; provision of information in public libraries and council offices; and clarification that responses from businesses were welcomed. A summary of the feedback received on the draft Stage One SoCC has been included in Appendix 2a. A copy of the published SoCC is also included in Appendix 2b and the published notice in the press in Appendix 2c. PAGE 17

18 4. Stage One: Consultation with statutory consultees 4.1. Statutory context The Stage One Consultation was carried out pursuant to section 47 and 48 of the PA 2008, but not pursuant to section 42 of the PA 2008 due to the Moorside Project proposals not being advanced enough to identify persons with an interest in the land. Despite not being carried out pursuant to section 42, the Stage One Consultation was carried out in line with the principles of section 42 with consultees on the prescribed list and the relevant local authorities (statutory consultees in this context). Section 42(1) of the PA 2008 states: 42. Duty to consult (1) The applicant must consult the following about the proposed application - (a) such persons as may be prescribed, (aa) the Marine Management Organisation, in any case where the proposed development would affect, or would be likely to affect, any of the areas specified in subsection (2) (b) each local authority that is within section 43, (c) the Greater London Authority if the land is in Greater London, and (d) each person who is within one or more of the categories set out in section 44 For the purposes of section 42(1)(a) of the PA 2008, the persons prescribed are those listed in Schedule 1 of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations Section 42(1)(b) local authorities are defined as those within which the land to which the proposed development relates is located (referred to as section 43(1) local authorities). It also includes those local authorities that share a boundary with that authority (referred to as section 43(2) local authorities). Section 42(1)(d) persons within section 44 of the PA 2008 are those persons who own, lease, tenant or occupy land to which the proposed development relates. It also includes those persons that are interested in the land or have power to sell and convey the land or to release the land. The third category is those persons entitled to make a relevant claim if the DCO sought by the proposed application were to be made and fully implemented. PAGE 18

19 4. Stage One: Consultation with statutory consultees 4.2. Identification of local authorities and prescribed bodies using the methodology in section 42 Whilst the Stage One Consultation was not carried out pursuant to section 42 of the PA 2008, NuGen followed the methodology in section 42 to identify the local authorities and prescribed bodies that it wanted to contact direct rather than rely on the methods under section 47 and section 48 of the PA Under section 42(1)(b), 11 local authorities were identified. Allerdale Borough Council Barrow-in-Furness Borough Council Copeland Borough Council Cumbria County Council Dumfries & Galloway Council Durham County Council Lancashire County Council North Yorkshire County Council Northumberland County Council Scottish Borders Council South Lakeland District Council Key Code A: is a neighbouring local authority (s43(3)) that shares a boundary with a B host authority; B: is either a unitary council or a lower-tier district council in which the Proposed Development and any associated development is situated (a host authority); C: is an upper-tier county council in which the Proposed Development is situated (a host authority); and D: is a neighbouring local authority (s43(3)) which is not a lower-tier district council and shares a boundary with a C authority. Figure 3 identification of local authorities Under Section 42(1)(a), 118 organisations were identified on the prescribed list. The full prescribed list is included in Appendix 5. As described above, due to the Moorside Project proposals not being developed enough to allow detail land referencing; section 42(1)(d) persons as explained above were not consulted directly during this stage of consultation. PAGE 19

20 5. Stage One: Consultation with the Community (s 47) 5.1. Stage One Consultation In this section of the report, NuGen sets out how the consultation requirements as set out in NuGen s Stage One SoCC were fulfilled during the Stage One Consultation, being the Strategic Issues Consultation. Some consultation activity has been carried out in addition to the requirements set out in the SoCC. Details of this activity have been in included in section 5.2 below Details of individual activities NuGen s approach and process for consultation with people living within the vicinity of the Moorside Project recognised that the development will have the greatest impact on the people that live nearest to the Moorside Project. Consequently, they were likely to have the greatest interest in the proposals. NuGen also recognised the large scale and widespread impact of the Moorside Project. NuGen arranged a programme of public exhibition events where people could learn about the strategic approach NuGen was proposing to adopt. They were able to speak to NuGen s technical experts in various areas related to the Moorside Project. They were also informed about how they could provide their views in response to the consultation. The purpose of the events was to supplement NuGen s consultation documents and provide people with the information they needed to make an effective response to the consultation. Event locations were selected to make sure that there were sufficient events in the communities close to the Moorside Site. In addition, NuGen ensured that there were events close to all the areas of search for Associated Development. In particular, this included the events at Whitehaven, Cleator Moor and Egremont. Closer to the Moorside Site, in the West Cumbria coastal strip, NuGen held public exhibitions so that the majority of people were within five miles of an event. NuGen held public exhibitions at: Whitehaven; Seascale; Cleator Moor; Bootle; St Bees; Egremont; Distington; Beckermet Millom; and Gosforth. Ravenglass; Further out from the Moorside Site, NuGen held public exhibitions in small towns so that the majority of people would be within eight miles of an event within the West Cumbria area. NuGen held events in: Workington; Maryport; Wigton; Cockermouth; Keswick; and Broughton-in-Furness. PAGE 20

21 5. Stage One: Consultation with the Community (s 47) In the wider sub-region, NuGen held events at the following key population centres: Carlisle; Kendal; and Penrith; Barrow-in-Furness. To ensure access for people with different commitments and working arrangements, these events were held from 11.00am to 7.30pm. NuGen provided all exhibition information, including display panels, on its consultation website so that any individuals who could not attend an event could view the information online, submit questions and their consultation responses. Hard copies of all documents were available to view at NuGen s Moorside Information Centre at the Civic Hall in Whitehaven town centre, where NuGen maintained an exhibition for the duration of the consultation period. The consultation documents were available at all the public exhibitions events, in selected libraries (set out on the NuGen website and newsletter), and in the main offices of Copeland Borough Council, Cumbria County Council and Allerdale Borough Council. Copies of the documents were also available to view and to download from the consultation website: com. NuGen sought to ensure that the Stage One Consultation was meaningful, inclusive and clear by providing consultees with information that could be easily understood, to enable constructive and informed comments on the Moorside Project. NuGen produced the following documents for the Stage One Consultation (all available on NuGen s consultation website). A short Consultation Overview Document. (Appendix 3a). The main Consultation Document (including a summary of preliminary environmental information and a questionnaire). The detailed Preliminary Environmental Information Appendix (comprising the draft Scoping Report for the Environmental Impact Assessment, and the Shadow Evidence Plan for the Habitats Regulation Assessment). This enabled different stakeholder groups to engage with the information at different levels as was appropriate and relevant to them. Summary consultation overview documents and one of NuGen s newsletters, launching the Stage One Consultation, were sent out to all addresses within the Whitehaven Travel to Work Area (TTWA). The criteria for defining TTWAs is that generally at least 75% of an area s resident workforce work in the area and at least 75% of the people who work in the area also live in the area. This area covers most of the area of Copeland Borough Council. A copy of the newsletter is reproduced in Appendix 3b. NuGen also ran advertising campaigns in the county of Cumbria advertising the SoCC and the programme of public events. Details can be found in Appendices 3c and 3d. NuGen also implemented a poster campaign promoting the consultation, the public events and how to respond to the consultation. The posters were particularly aimed at identified hard to reach groups including social housing estates, rural villages, older people and minority groups. A copy of the poster used is reproduced in Appendix 3e. NuGen promoted the Stage One Consultation and events by offering interviews and briefings to the press, radio, and television. NuGen used social media to publicise the consultation and to provide information on how to access events and information on how to respond. NuGen also reviewed social media activity to identify any key issues that may trend in relation to the Moorside Project. PAGE 21

22 5. Stage One: Consultation with the Community (s 47) NuGen offered to meet with and carry out presentations to any organisation when requested. In response, meetings were held with the individual sub committees of Cumbria County Council which represent Copeland (8th June 2015), Allerdale (30th June 2015), South Lakeland (23rd June 2015), Carlisle (19th June 2015) and Barrow (29th May 2015). Additional meetings were held with the Lake District National Park Authority (24th June 2015), Egremont Town Council, Cleator Moor Town Council (14th July 2015), Beckermet Parish Council (16th June 2015), and Askam and Ireleth Parish Council (13th July 2015). NuGen actively involved young people and engaged them. NuGen extended invitations to primary schools local to the Moorside Site for their students to attend a special preview consultation, when the consultation was taking place nearby. Beckermet Primary School was able to visit and their year 5 and 6 pupils were provided with the opportunity to ask questions and find out more from members of NuGen s Project team. Supplementary to the consultation, a number of local primary schools (Seascale, Beckermet, Frizington, Waberthwaite, Montreal School (Cleator Moor) and Gosforth) took up an offer from NuGen to participate in beach education sessions, during which environmental themes and the environmental impact of the Moorside Project were discussed. The four secondary schools closest to the Moorside Site were invited to participate, with Whitehaven Academy sending two coach-loads of students for special sessions at the Moorside Information Centre on 15th July NuGen ran a workshop with 30 young nuclear apprentices and graduates at the Moorside Information Centre on 21st July 2015 and representatives of the Cumbria Youth Parliament attended the opening consultation on the 15th May NuGen sought to ensure that the various means of participating in the Stage One Consultation meant that there were appropriate opportunities to engage the hard to reach groups (Appendix 4) that NuGen had identified. Prior to the launch of the Stage One Consultation, NuGen held a pre-consultation viewing of the exhibition material and documents at a meeting of the Moorside Technical Group a specially arranged group that includes technical representatives of key stakeholder organisations (membership at Appendix 14). A similar pre-consultation briefing was given to councillors from Copeland Borough Council, Allerdale Borough Council, Cumbria County Council and board members of the Lake District National Park Authority Variations from the SoCC The actions and processes set out in the Stage One SoCC were carried out in full. Additional activities, not specified in the Stage One SoCC, were carried out to respond to perceived needs as the consultation progressed. For example, a number of residents from the Braystones area and local caravan parks did not receive the direct mailing advising them of the timing and locations of local exhibition events until after the nearest event had occurred. Some local residents of caravan parks in that area did not individually receive the direct mailing at all. This was due to the caravan park being identified as only one address. Whilst there were other events within a five-mile radius after the late arrival of mailings, and a range of other means of promoting the events, NuGen considered that the residents of the area could be significantly affected by the Moorside Project and ought to be given an additional opportunity to engage. Consequently, an additional exhibition was arranged at the Tarnside Caravan Site at Braystones on Saturday morning, 11th July 2015 and was promoted, both by an advertisement in the Whitehaven News, through the local parish council and through a re-delivery by hand of consultation material to the caravan park residents. PAGE 22

23 5. Stage One: Consultation with the Community (s 47) An additional event was held on Thursday 16th July 2015 between 9am and 3pm at the canteen on the Sellafield Site. This was added to the schedule to increase the opportunity of working people visiting an exhibition event during the working day. The Sellafield Site accommodates in excess of 12,000 working people on an average day. The event was promoted internally at Sellafield using posters developed by NuGen. An additional event was added in Whitehaven covering the standard event hours of 11.00am to 7.30pm to deal with any concerns that people working in the retail sector In Whitehaven sufficient opportunity to visit a consultation event. Whilst scheduled events for Whitehaven included an event from 11.00am pm Monday to Friday and every Saturday morning for the 10-week consultation. the additional event at the Moorside Information Centre provided evening hours coverage outside normal retail trading hours to ensure small retailers and others had the opportunity to attend. An additional advert was placed in the Whitehaven News to promote this event and the additional Braystones event referred to above. As referred to in section 5.3, NuGen carried out a number of additional activities with different groups of younger people in order to provide opportunities for them to engage with the proposals. In addition to NuGen s commitment to provide hard copies in public libraries in the main towns in Cumbria (Whitehaven, Workington, Carlisle, Kendal, Penrith and Barrow-in-Furness), NuGen also provided the hard copies of documents to libraries at Cleator Moor, Egremont, Seascale and Beckermet Reading Rooms. PAGE 23

24 6. Stage One: Publicity under section Statutory context This chapter sets out the approach taken to publicity under section 48 of the PA 2008 for the Stage One Consultation. Section 48 of the PA 2008 requires: (1)The applicant must publicise the proposed application in the prescribed manner. (2) Regulations made for the purposes of subsection (1) must, in particular, make provision for publicity under subsection (1) to include a deadline for receipt by the applicant of responses to the publicity. Regulation 4 of The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 sets out the requirements for fulfilling section 48 of the PA According to these regulations the notice must include: (a) the name and address of the applicant (b) a statement that the applicant intends to make an application for development consent to the Secretary of State; (c) a statement as to whether the application is EIA development; (d) a summary of the main proposals, specifying the location or route of the proposed development; (e) a statement that the documents, plans and maps showing the nature and location of the proposed development are available for inspection free of charge at the places (including at least one address in the vicinity of the proposed development) and times set out in the notice; (f) the latest date on which those documents, plans and maps will be available for inspection (being a date not earlier than the deadline in sub-paragraph (i)); (g) whether a charge will be made for copies of any of the documents, plans or maps and the amount of any charge; (h) details of how to respond to the publicity; and (i) a deadline for receipt of those responses by the applicant, being not less than 28 days following the date when the notice is last published Publicity A notice fulfilling the requirements set out above was placed in the following publications on the following dates: Publication Dates The London Gazette 13th May 2015 The Times 14th May 2015 Lloyd s List 14th May 2015 Sea Fishing 11th May 2015 Edinburgh Gazette 13th May 2015 Whitehaven News 7th and 14th May 2015 Times and Star 8th and 15th May 2015 This fulfilled the requirements to publish a notice with details of the proposed application. A copy of the notice can be found in Appendix 6a. No distinct responses were received under section 48 of the PA PAGE 24

25 6. Stage One: Publicity under section Regulation 11 of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 NuGen is required to notify statutory consultees as part of Regulation 11 of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 ( the EIA regulations ) (as amended) that the proposed application is EIA development. This notification is to be made at the same time as the section 48 is published. Notification on Stage One Consultation and an invitation to respond was included in the Regulation 11 notifications. A copy of the letter issued is included in Appendix 6b. Of the 129 letters issued, 112 were received via the Royal Mail s Track and Trace service and delivery confirmed. Of the 17 remaining letters, six were re-issued via courier. The remaining letters, were either re-issued to different addresses (confirmed with the organisations) via the Royal Mail s Track and Trace service and delivery confirmed or re-issued via where no other option was available. PAGE 25

26 7. Stage One: Feedback from Statutory Consultees 7.1. Statutory context This section (and section 8) reports on the feedback received during the Stage One Consultation on NuGen s Moorside Project. This is split into feedback received from statutory bodies (the local authorities and prescribed bodies as referred to in section 4) and from the wider community under section 47 of the PA The detailed breakdown is included in Appendix 7. Whilst the Stage One Consultation was not carried out under section 42, the principles of identifying the prescribed bodies (section 42(1)(a)) and local authorities (section 42(1)(b)) was followed. Section 49 of the PA 2008 requires an applicant to have regard to all relevant responses received during statutory consultation (in the case of the Stage One Consultation, under sections 47 and 48). The statutory context and relevant Department for Communities and Local Government (DCLG) advice is included below. Section 49 of the Act states: (1) Subsection (2) applies where the applicant: (a) has complied with sections 42, 47 and 48, and (b) proposes to go ahead with making an application for an order granting development consent (whether or not in the same terms as the proposed application). (2) The applicant must, when deciding whether the application that the applicant is actually to make should be in the same terms as the proposed application, have regard to any relevant responses. (3) In subsection (2) relevant response means: (a) a response from a person consulted under section 42 that is received by the applicant before the deadline imposed by section 45 in that person s case, (b) a response to consultation under section 47(7) that is received by the applicant before any applicable deadline imposed in accordance with the statement prepared under section 47, or (c) a response to publicity under section 48 that is received by the applicant before the deadline imposed in accordance with section 48(2) in relation to that publicity. Full details as to how NuGen has had regard to the consultation responses in accordance with Section 49 of the PA 2008 will be included in NuGen s final consultation report which will accompany its DCO submission DCLG guidance Supporting the requirements of the PA 2008, DCLG has published guidance on the pre-application process including what a consultation report should contain ( Planning Act 2008: Guidance on the pre application process March 2015). The most relevant paragraph is included below. 80. Therefore, the consultation report should: provide a general description of the consultation process undertaken, which can helpfully include a timeline; set out specifically what the applicant has done in compliance with the requirements of the Planning Act, relevant secondary legislation, this guidance, and any relevant policies, guidance or advice published by Government or the Inspectorate; set out how the applicant has taken account of any response to consultation with local authorities on what should be in the applicant s statement of community consultation; PAGE 26

27 7. Stage One: Feedback from Statutory Consultees set out a summary of relevant responses to consultation (but not a complete list of responses); provide a description of how the application was in-formed and influenced by those responses, outlining any changes made as a result and showing how significant relevant responses will be addressed; provide an explanation as to why responses advising on major changes to a project were not followed, including advice from statutory consultees on impacts; where the applicant has not followed the advice of the local authority or not complied with this guidance or any relevant Advice Note published by the Inspectorate, provide an explanation for the action taken or not taken; and be expressed in terms sufficient to enable the Secretary of State to understand fully how the consultation process has been undertaken and significant effects addressed. However, it need not include full technical explanations of these matters. Responses were received from 37 statutory consultees. These are as follows: National governments (3) Government of Ireland Isle of Man Northern Ireland Government Local authorities (8) Allerdale Borough Council Carlisle City Council Copeland Borough Council Cumbria County Council Lake District National Park Authority (LDNPA) Lancaster City Council Northumberland County Council North Yorkshire County Council Parish and town councils (9) Askam & Ireleth Parish Council Beckermet with Thornhill Parish Council Bootle Parish Council Cleator Moor Town Council Egremont Town Council Millom Town Council Lowca Parish Council St Bees Parish Council Ennerdale & Kinniside Parish Council PAGE 27

28 7. Stage One: Feedback from Statutory Consultees Other statutory consultees (17) Civil Aviation Authority Copeland Health and Wellbeing Forum Environment Agency Highways England Historic England Marine Management Organisation Ministry of Defence National Grid Natural England NHS Nuclear Decommissioning Authority Office for Nuclear Regulation Public Health England Royal Society for the Protection of Birds The Coal Authority United Utilities National Trust 7.3. Issues The issues that have been raised by the above organisations from NuGen s Stage One Consultation are set out in the schedules in Appendix 7a. These issues are tracked and an update is provided on how they are being considered. NuGen s final Consultation report will explain how the application was informed and influenced by those responses as well as the responses to the Stage Two Consultation, outlining any changes made as a result and showing how relevant responses were addressed. The final consultation report will also provide an explanation as to why any responses requesting changes to the Moorside Project were not followed (where that is the case), including advice from statutory consultees on impacts. PAGE 28

29 8. Stage One: Feedback from the Community (section 47) 8.1. Quantitative data / feedback forms This section covers the feedback collected under section 47 of the PA 2008 in response to the Stage One Consultation including: the responses to various quantitative questions asked during the Stage One Consultation; and summaries of all the relevant issues raised from feedback to the Stage One Consultation. This fulfils the requirements of section 49 of the Act with regards to Stage One Consultation under section 47 of the Act. The Stage One Consultation found that, broadly speaking, the majority of respondents supported the Moorside Project and the benefits it could bring. Importantly, the strategic approach set out in the consultation received strong support. There was support for the focus on rail transportation and the selection of search areas for accommodation sites, providing a sound basis for the further development of the Moorside Project. This support was however, often conditional on the provision of various services (mostly healthcare) and infrastructure improvements (mostly highways). The Stage One Consultation also found that there was opposition to the Moorside Project. This was split between general opposition to nuclear power and its associated waste products, and therefore the Moorside Project by association, and opposition to the impact and disruption of the Moorside Project in particular. Concerns about the Moorside Project were predominantly around the impact on local services and the capacity of the transport network. Concern regarding the impact on the road network was extremely high There were also concerns around various radiological issues, the potential impact on and disruption to local communities, and concerns about the impact on the local environment particularly the marine and freshwater environments. NuGen also received a number of commercial representations during the consultation period including offers of potential land for development, which have been considered where appropriate in the development of the Moorside Project. This section covers the quantitative data collected from feedback forms during the Stage One Consultation from members of the community. Whilst quantitative data is limited in terms of providing detailed relevant responses that need to be considered and addressed, qualitative data can provide a valuable gauge of public opinion to various elements of the proposals. The information below is based on the 375 feedback forms returned during the public consultation. It does not include opinions expressed in other written feedback that could be aligned to various questions. Attempting to do otherwise would risk subjective interpretation. The number of feedback forms received provides a significant amount of data from a range of locations near the Moorside Site, potential Associated Development search areas and the wider UK. PAGE 29

30 8. Stage One: Feedback from the Community (section 47) 8.2. Demographics Out of the 375 feedback forms received, 345 respondents provided information on their gender and age. While the area does have a slightly older demographic than the UK average, the significant nature of the age group difference demonstrated during the Stage One Consultation is worth highlighting. People under 45 completed fewer than 20% of the feedback forms received. Similarly, the 2:1 ratio of male to female respondents is worth noting. NuGen considered how to address both of these disparities for the Stage Two Consultation and this is explained later on in this report. Gender Number Percentage Male % Female % Age Number Percentage Up to % 25 to % 45 to % % The origin of the feedback from respondents based on postcode information provided in the feedback forms is displayed on Figure 4. Figure 4 PAGE 30

31 8. Stage One: Feedback from the Community (section 47) 8.3. Results Question 1: Do you agree with the need to develop a new nuclear power station at the Moorside search area? Yes % No 55 15% Unsure 43 12% While the need for the Moorside Project is defined by government policy, this question was asked to ascertain a baseline of support for the need case for the Moorside Project. Feedback forms returned report a strong level of support for the need to develop a new nuclear power station at Moorside. Figure 5 illustrates the postcode location of these responses. Figure 5 PAGE 31

32 8. Stage One: Feedback from the Community (section 47) Question 2: The Moorside Project will bring a number of potential benefits to the local area. How important do you consider the following as part of NuGen s proposals? Very important Somewhat important Unsure Somewhat unimportant Very unimportant Employment Skills & training Local supply chain Local economy Transport Regeneration Health care Environmental The Moorside Project has the ability to deliver significant benefits to Cumbria, both directly and indirectly. At this strategic stage of the Moorside Project, information on which potential benefits people consider most important will help refine NuGen s detailed proposals. The feedback shows a high level of support for all the potential benefits. The lowest levels of support were shown for transport, regeneration, health care and environment. Question 3: Are there any other benefits you believe the project could deliver? Summarisation of suggestion Number of times suggested Improved transport infrastructure 33 Improvements to health services 18 Employment & training for locals 16 Cheaper or free electricity 16 National supply security 12 General benefits for West Cumbria 10 Rejection of the value of the benefits 10 NuGen notes that some of the suggestions reiterated options already presented in the questions. PAGE 32

33 Section 8 - Feedback under section 47 Question 4: Soil excavated on site can be used to landscape areas of the Moorside Search Area and may in part assist with noise and visual screening of the development and construction activities. It can also, in part, be removed from the site to be used on other projects, although this may cause environmental effects from the transportation of material. How important do you consider the following to be as part of NuGen s objectives for excavated soil? Visual screening Noise screening Creating a natural Landscape Reducing transport Effects Very important Somewhat important Unsure Somewhat unimportant Very unimportant As with any project of such a large scale, the Moorside Project will attract concerns about disruption from works and operations. The general consensus was that all four elements were important. When very important and somewhat important were added up for each, there was little difference. Question 5: After construction, the proposed Moorside passenger station and freight sidings, and marine off-loading facilities (MOLF) at the Moorside Search Area could be retained. This would offer certain benefits to the operation of the future power station and potentially to the adjacent Sellafield Site but could have certain visual and environmental impacts. Do you think we should consider retaining these facilities? Moorside Passenger Station and Freight Station Marine Off-Loading Facilities Yes % % No 20 6% 48 14% Unsure 44 12% 76 21% At this early stage of the Moorside Project, NuGen was able to get feedback from the community about the support for two of the key temporary development facilities. There was general support for retaining the additional infrastructure. More people were unsure about retaining the facilities than were opposed. PAGE 33

34 Section 8 - Feedback under section 47 Question 6: Having read our proposals to address the potential impacts of the permanent development and operation of the Moorside Project, do you have any comments about the proposals? Key issues # Concern regarding adequacy of roads 24 Support for mitigation proposals 22 Support for rail improvements and MOLF 14 Lack of health care provisions / access 13 Opposition to nuclear power 11 Support for nuclear power 8 Concern regarding visual impact 8 These issues are covered in more detail in the following section dealing with the qualitative feedback received. It is important to note that the largest concerns for the operational phase of the Moorside Power Station are roads and health care provision. Question 7: Having read our proposals to address the potential impacts of the temporary construction period, do you have any comments about the proposals? Key issues # Requirement of major road improvements 29 Support for rail and sea transport 15 Criticism of the transport plans 14 Specific concern regarding the A Support for mitigation proposals 11 Request for protection for the local villages 7 Request for improved health services 7 Request all HGV stay off roads 5 These issues are covered in more detail in the following section dealing with the qualitative feedback received. It is important to note the focus on transport issues was higher when talking about the construction period. PAGE 34

35 Section 8 - Feedback under section 47 Question 8: Do you agree with our transport strategy for the Moorside Project being rail-focused to minimise road usage, particularly at peak times? Yes % No 24 7% Unsure 17 5% NuGen s strategy is heavily focused on the use of rail. Overwhelming support was expressed for the focus on rail, and most importantly, the minimisation of road usage. The finding links strongly to the qualitative data, where a large number of respondents raised concerns regarding transport. More detail on this can be found in the following section, but in summary, that support is contingent on the strategy being implemented effectively. Question 9: After construction, the proposed temporary rail station at the Mirehouse Search Area could be retained. This would offer certain benefits to the connectivity and accessibility of the local area but could have certain visual and environmental impacts. Do you think we should consider retaining these facilities? Yes % No 24 7% Unsure 17 5% The results demonstrate strong support for retaining the station at Mirehouse despite the potential visual and environmental impacts. Question 10: Although we will seek to utilise as much local labour as possible, it is unlikely that we will be able to recruit the entire construction workforce from the local population. Therefore, we will need to bring extra workforce to the area and provide new accommodation. Our strategy for this temporary accommodation is to focus our search for sites within or next to existing towns and settlements, to direct expenditure to those areas, and where a potential legacy can be left, rather than locating them in remote locations unconnected to existing settlements and facilities. Do you agree with this approach? Yes % No 57 16% Unsure 49 14% PAGE 35

36 Section 8 - Feedback under section 47 The strategy of integration rather than isolation is one that was able to be tested at the early stage. The general preference for NuGen s strategy has been demonstrated but in the comments received there were strong arguments both for and against this approach. Question 11: Our strategy for any buildings and accommodation only required for the construction period is to consider their potential for future legacy use. Do you agree with this approach or would you prefer that the sites be returned to their previous uses? Yes % No 98 28% Unsure 52 15% Legacy usage is a major issue, one that determines the level of lasting impact the construction of the Moorside Project will leave. The answer to this question is less clear than a lot of the previous development options or strategies. There is still majority support for one option, legacy usage, but a substantial minority of people wanted a return to the land s previous use. When the unsure results are removed, almost a third of respondents rejected the principle of legacy use. Question 12: What do you think of the suitability for the following search areas for worker accommodation and transport during the construction period? Very supportive Somewhat supportive Unsure Somewhat opposed Very opposed Larger scale (up to 4000 workers): Whitehaven - Corkickle Whitehaven - Mirehouse Smaller scale (up to 1000 workers): Egremont Cleator Moor Siting temporary worker accommodation is one of the most significant issues for the Associated Development for the Moorside Project. The general finding is that respondents were supportive of all four areas, but that there was more opposition to Egremont and Cleator Moor. In order to better understand the support and opposition for each of the search areas, the support and opposition for each was mapped. These maps are overleaf. PAGE 36

37 Section 8 - Feedback under section 47 Whitehaven Corkickle Figure 6 Map of support and opposition for the search area PAGE 37

38 Section 8 - Feedback under section 47 Whitehaven Mirehouse Figure 7 Support and opposition for the search area PAGE 38

39 Section 8 - Feedback under section 47 Egremont Figure 8 Support and opposition for the search area PAGE 39

40 Section 8 - Feedback under section 47 Cleator Moor Figure 9 Support and opposition for the search area PAGE 40

41 Section 8 - Feedback under section 47 The maps of opposition and support show that opposition to the smaller sites (Egremont and Cleator Moor) are more focused around those areas and along transport routes; compared to the two Whitehaven sites which have a less concentrated show of opposition. Question 13: If there are any other search areas you think we should consider, please let us know. The most referred to sites were: Location No. Millom 35 South of Moorside 25 Seascale 19 Workington 13 St Bees 9 Bootle 8 Gosforth 7 Moorside itself 7 Drigg 6 Frizington 6 Barrow 5 Moor Row 4 Kangol factory site 4 Marchon factory PAGE site 41 4 Cockermouth 3 Haverigg 3 Maryport 3 Nethertown 3 Sellafield 3 PAGE 41

42 Section 8 - Feedback under section 47 Question 14: For the above search areas do you have any other views on their suitability, parts of the search areas that may or may not be more suitable, views on the potential scale of development that might be acceptable and whether you have a preference for worker accommodation on a single search area or multiple search areas? Multiple sites 50 Single site 9 A strong preference for multiple sites was expressed. Other relevant feedback included a strong preference for the use of brownfield sites, vacant premises and existing hotels/b&bs over new development. There was general opposition to the use of any greenfield sites. Strong arguments in favour of each were made in the open comment section. The key argument for multiple sites was to better integrate the development, its workforce and the benefits of the Moorside Project. Question 15: What are your views on possible future legacy uses for worker accommodation sites? Very supportive Somewhat supportive Unsure Somewhat opposed Very opposed Housing Business space Student accommodation Hotels and conference facilities Sports and leisure / open space Transport facilities Most of the possible uses received majority support. Student accommodation and hotels/conferencing facilities received the least enthusiasm, with a far higher proportion unsure and fewer very supportive. Sports, leisure and open space uses received the least opposition. A number of other suggestions were made, however these numbers were relatively small; the highest being retirement homes (five suggestions) and affordable or sheltered accommodation (four suggestions). PAGE 42

43 Section 8 - Feedback under section 47 Question 16: Do you have any other comments about the Moorside Project or the information presented in the Preliminary Environmental Information Pack? Comment # Concern regarding adequacy of infrastructure 42 General support for the Moorside Project 23 Concern regarding service provision (health) 20 General opposition to the Moorside Project 15 Support for the consultation process so far 10 Concern regarding impact on nearest villages 9 Need for infrastructure work before construction 9 Concern regarding nuclear waste 8 Transport and health again come up as the main concerns. There were relatively few focused comments regarding the information provided in relation to the contents of the Preliminary Environmental Information Pack and these are captured in the next section of this report Question 17: How did you hear about the consultation? (multiple choices allowed) Method / channel # % Advert 34 10% Newspaper coverage % TV/Radio 30 8% Leaflet % Poster 21 6% Website 36 10% Word of mouth % Social media 21 6% Other 50 14% PAGE 43

44 Section 8 - Feedback under section 47 The results of this question demonstrate that traditional methods of communication, such as leaflets, newspaper coverage and word of mouth have been more effective than adverts and social media. However, it is important to note the demographics of respondents which may have been a significant factor in the results. Question 18: How did you find the quantity and detail of information provided during the consultation? This question was asked to check if the amount and level of information provided during the Stage One Consultation was appropriate. Ensuring that a proportionate amount of information is provided as part of the Stage Two Consultation is vital to ensure that the public can provide meaningful feedback, whilst being aware that providing too much information can be a barrier to engagement. As can be seen from the results below, it is clear that the majority of respondents felt that the amount of information was about right. Too much About right Too little Total responses Quantity 9 2.7% % % 334 Detail 7 2.2% % % 320 Key issues # General praise for the consultation so far 20 Request for locals to be kept better informed 17 Request for more detailed information 10 Request for additional events (locations and types) 10 Complaint about not receiving notification 9 Request for more advertising 8 More engagement with parish councils 7 All of these suggestions will be considered for inclusion where possible in the next stage of consultation. PAGE 44

45 Section 8 - Feedback under section Qualitative data This section covers the written feedback received during the Stage One Consultation. This includes the open questions from the feedback form, the comment cards received and letters and s sent directly in response to the consultation. It excludes feedback received from statutory consultees and groups. The feedback received contained approximately 250,000 words (roughly equivalent to 500 pages of text in a typical paperback novel). In order to turn this amount of text into a digestible form NuGen has followed a process of summarising relevant feedback. The process used is as follows. Each individual piece of written feedback was reviewed one at a time. The salient points within the first piece of written feedback were summarised, as suggested in DCLG s published Guidance on the pre-application process (March 2015), and listed. The next piece of written feedback was then reviewed. Issues within the feedback that had already been summarised would be noted so that a record would be kept that the issue had been raised again and, if necessary, the summarisation would be updated to include additional relevant information. All issues that had not been already summarised would then be summarised as outlined above. Each summarised issue was assigned a theme that related to EIA topics and other project specific considerations (such as Associated Development search areas). In general, unless substantially irrelevant to NuGen s proposals for the Moorside Project, all issues were recorded and summarised, even if they were outside of the strict remit of the consultation as laid out in the SoCC. All summarised issues were then numbered to allow future tracking and to ensure that NuGen could be confident that each was considered fully. In order to avoid potential loss of context and content in the relatively small number of highly detailed representations from members of the public, where appropriate, some feedback text has not been summarised but simply recorded verbatim. Following this process has identified 619 individual issues across 24 themes. The full schedule of all summarised issues, organised by theme, can be found in Appendix 7b Group responses Responses, which are included in the summaries in appendix 7b, were received from organisations representing the concerns of a wider group including: The groups included the following: Allerdale and Copeland Green Party; Copeland and Workington Liberal Democrats; Cumbrian Community Rail Partnerships; Cumbrians Opposed to Radioactive Environment; Furness Line Action Group; Home Group; Friends of the Lake District; and Kick Nuclear. PAGE 45

46 9. Stage Two: Consultation Statement of Community Consultation 9.1. DCO Stage Two SoCC This section deals with the development of the Statement of Community Consultation that was prepared for the Stage Two Consultation (the Stage Two SoCC). It was considered that a new SoCC should be prepared for the Stage Two Consultation because: at the point of the Stage Two Consultation, options for Associated Development were being considered at locations within additional local authority areas that had not been formally consulted on the Stage One SoCC; and it provided the opportunity to make adjustments to the methodology in the light of the learning arising from the Stage One Consultation. As the Stage One SoCC was the result of considerable discussion with Copeland Borough Council, Cumbria County Council and Allerdale Borough Council, and the consultation process was considered to be successful, the Stage Two SoCC set out a broadly similar process but with enhancements The lessons learned following the Stage One Consultation Copeland Borough Council and Cumbria County Council independently assessed the effectiveness of the Stage One Consultation. This included sending assessors to each event. They concluded that: the events were well organised; high quality presentational material was used; NuGen event staff were engaging and interactive; a valuable event took place on the Sellafield Site; there was a valuable permanent exhibition at the Whitehaven information centre; and a flexible approach in arranging additional events as need was identified. And potential improvements could be: better signage outside venues; balancing staff number to visitors; more bespoke events as that arranged for Sellafield to better engage business and academic institutions; and clearer Hard to Reach Strategy required (See presentation to MTG by Copeland Borough Council Appendix 14b). In developing the Stage Two approach, this experience from the Stage One Consultation was taken into account adjustments were made: additional street signs were added outside events; visitor numbers recorded at the Stage One Consultation events to plan the numbers of NuGen staff that would be needed at each event; PAGE 46

47 9. Stage Two: Consultation Statement of Community Consultation more workplace events were arranged; three schools events were added; and NuGen s consultants, Copper Consultancy, carried out local research into the way hard to reach groups should be encouraged to engage. The findings were built into a Consultation Strategy that provided a framework for the approach NuGen adopted in the Stage Two SoCC. This Strategy is contained in Appendix 8a. NuGen s own analysis also identified that young people and women were under represented in the responses received during the Stage One Consultation. The additional focus during the Stage Two Consultation on centres of education and workplaces was designed to address this. NuGen prioritised requests to attend events frequented by younger people during the consultation period, increased its presence on social media, and instigated a significant campaign on CFM radio (an independent local radio station broadcasting to Cumbria and South West Scotland) during the consultation period. In the Stage One Consultation, some members of the caravan park community in Braystones had not received consultation information in the post as planned. This very local issue was resolved by a further hand delivery. It had stemmed from the individuals concerned not being permanently resident in the area as they occupied caravans at certain times of the year. These did not all have separate addresses on Post Office mailing lists. In the Stage Two Consultation NuGen ensured there were hand deliveries to individual caravans on all sites in the vicinity of Moorside. NuGen also created more opportunities for tourist visitors to the area to engage in the Stage Two Consultation by arranging events at Keswick and Braystones during school holidays The Statement of Community Consultation legal requirements The legal requirements for the Stage Two SoCC are the same as those for the Stage One SoCC set out in Section 3.12 of this document and are not repeated here Informal local authority consultation As with the development of the Stage One SoCC, informal consultation with the relevant local authorities was carried out in advance of the preparation of the formal draft of the Stage Two SoCC. NuGen met with Cumbria County Council, Copeland Borough Council and Allerdale Borough Council on 13th January 2016 to discuss the content and development of a new SoCC for the Stage Two Consultation. An initial informal draft of the Stage Two SoCC was provided prior to the meeting for discussion. The timetable for the formal consultation process was discussed at the meeting. Informal responses to the Stage Two SoCC were received and the draft Stage Two SoCC adjusted accordingly. When the Stage Two SoCC was being prepared, there was the possibility that Associated Development sites relating to transport logistics could be identified within the boundaries of Carlisle City, Barrow-in- Furness and Eden District. These three authorities were, therefore, informed of this possibility and were asked how they wanted to be engaged going forward. They declined to take part in the discussions over the content of the Stage Two SoCC at that time. PAGE 47

48 9. Stage Two: Consultation Statement of Community Consultation 9.5. Formal consultation on the draft Stage Two SoCC The consultation draft of the Stage Two SoCC was provided to Cumbria County Council, Copeland Borough Council and Allerdale Borough Council for their formal consideration on 5th February In addition, the draft Stage Two SoCC was also provided to Carlisle City Council, Eden District Council and Barrow Borough Council for formal consultation on the same day. Responses were requested to be submitted within 28 days which began the day after the local authority received the consultation documents. Whilst there was no apparent potential to locate any Associated Development in the District of South Lakeland or in the Lake District National Park, both authorities were advised by NuGen of the option of passing any comments they had on the Stage Two SoCC to the County Council who would formally include them in its own response. This was a process suggested by the County Council and agreed for the previous stage of consultation and adopted again for this stage of consultation. At meeting with Cumbria County Council, Copeland Borough Council and Allerdale Borough Council on 17th February 2016, the content of the Stage Two SoCC was discussed again prior to their responses being formally issued Responses to the draft Stage Two SoCC Consultation with local authorities Responses were received from Cumbria County Council, Copeland Borough Council, and Allerdale Borough Council to the formal consultation providing 61 individual comments. The NuGen project team reviewed the feedback. Six of the comments were supportive or complimentary, six suggested wording changes were declined, and 49 of the comments resulted in changes to the Stage Two SoCC. Most of these were textual changes and clarifications as the main structure of the document had been the subject of earlier discussion at the informal stage and was a development of the Stage One SoCC. The main content changes to the Stage Two SoCC included: more clarity on prioritising young people s groups; emphasising the importance of NuGen receiving responses; agreement on radius of mailing areas around Associated Development sites in Allerdale; specific agreement to meetings with Parish and Town Councils when requested; and textual adjustments. A summary of the feedback received on the draft Stage Two SoCC has been included in Appendix 8b. A copy of the published SoCC is included in Appendix 8c and the published SoCC notice in Appendix 8d. PAGE 48

49 9. Stage Two: Consultation Statement of Community Consultation 9.7. Publication of SoCC The Stage Two SoCC was published on 7 April 2016 and notices summarising the content of the SoCC appeared in the following publications: The Whitehaven News 07/04/2016 The Times and Star 08/04/2016 The Cumberland News 08/04/2016 The News and Star 07/04/2016 The North West Evening Mail 08/04/2016 The Cumberland and Westmorland Herald 09/04/2016 The Keswick Reminder 08/04/2016 The Westmorland Gazette 08/04/2016 A full copy of the SoCC was provided on NuGen s website ( and printed copies were available at the following offices and libraries as set out below from 7th April until the end of the statutory consultation on 30th July NuGen s Moorside Information Centre, Civic Hall, Lowther Street, Whitehaven, Cumbria CA28 9LS. Open 9am-5pm, Monday-Friday; The Copeland Centre, Catherine Street, Whitehaven, Cumbria CA28 7SJ. Open 8.45am-5.15pm Monday, Tuesday and Thursday, 10am-5.15pm Wednesday and 8.45am-4.30pm Friday; Allerdale House, Workington, Cumbria CA14 3YJ. Open 8.45am-5pm Monday to Thursday and 8.45am-4.30pm Friday; The Courts, Carlisle, Cumbria CA3 8NA. Open 9am-5pm Monday to Thursday and 9am-4.30pm Friday; County Hall, Kendal, Cumbria LA9 4RQ. Open 9am-5pm Monday to Thursday and 9am-4.30pm Friday; Whitehaven Library, Lowther Street, Whitehaven, CA28 7QZ; Workington Library, Vulcans Lane, Workington, CA14 2ND; Carlisle Library, 11 Globe Lane, Carlisle, CA3 8NX; Barrow Library, Ramsden Square, Barrow-in-Furness, LA14 1LL; Penrith Library, St. Andrew s Churchyard, Penrith, CA11 7YA; Kendal Library, Stricklandgate, Kendal, LA9 4PY; Cleator Moor Library, Market Square, Cleator Moor, CA25 5AP; Egremont Library, Main Street, Egremont, CA22 2DB; Seascale Library, Gosforth Road, Seascale, CA20 1PN; Mirehouse Library, Meadow Road, Whitehaven, CA28 8ER; Gosforth Library, Public Hall, Gosforth, Seascale, CA20 1AS; and Cockermouth Library, 92 Main Street, Cockermouth, CA13 9LU. Copies of the Stage Two SoCC were also sent to all the parish and town councils that had a Moorside consultation event planned for their area. PAGE 49

50 10. Stage Two: Consultation with Statutory Consultees, Section Stage Two: Consultation with Statutory Consultees, Section 42 This section describes how the Stage Two Consultation was carried out between 14th May and 30th July. The Stage One Consultation had determined that there was support for the strategic approach NuGen were proposing to take. On that basis, NuGen developed the details of the Proposed Scheme in readiness for another round of consultation: the Stage Two Consultation. The consultation asked for views on the Proposed Scheme. The following suite of documents were prepared for the purpose providing the information on the Moorside Project proposals at different levels of detail to meet varied consultee requirements. Document Reference Proposed Scheme Overview Proposed Scheme Feedback Form Newsletter Non-Technical Summary of the Preliminary Environmental Information Report Description A summary of the Proposed Scheme document. The main Stage Two Consultation document, outlining NuGen s Proposed Scheme. The document provides an opportunity to respond to NuGen with your views on the Stage Two Proposed Scheme Consultation. A summary of the proposed Moorside Project. A non-technical summary of environmental information which has been gathered into the Preliminary Environmental Information Report by NuGen, so far to enable preliminary identification and assessment of the likely significant environmental effects of the Moorside Project. Technical Folder which included: Preliminary Environmental Information Report Habitats Regulations Assessment Evidence Plan Draft Outline Construction Environment Management Plan Draft Outline Biodiversity Management Strategy Draft Transport Strategy Plans and Drawings Notice of Proposed Application under s48 Planning Act 2008 This document presents full details of the environmental information which has been gathered by NuGen so far to allow preliminary identification and assessment of the likely significant environmental effects of the Moorside Project. The HRA Evidence plan details the information that NuGen anticipates will be necessary to inform the Habitats Regulations Assessment (HRA) process and gives an outline of the further steps needed to determine any likely significant effects on the wider designated sites under the Habitats Directive. The Draft Outline CEMP provides the outline structure of how environmental issues during the construction period will be managed on site. This is the NuGen strategy which outlines how it intends to think about ecological and biodiversity management for the Moorside Project. Sets out NuGen s strategy for transporting workers, goods and materials during the construction and operation of the project. Provides drawings and plans which illustrate and support the content of the Stage Two Consultation documents. Formal notice advertising the project and the consultation in national and local publications. Draft Property Support Scheme and Draft Local Mitigation Scheme Figure 10 DCO Stage Two Consultation Documents Draft proposals for NuGen s voluntary scheme to assist residents owners within a defined area close to the Moorside Power Station. PAGE 50

51 10. Stage Two: Consultation with Statutory Consultees, Section Statutory context This section includes details of the Stage Two Consultation with statutory consultees under section 42 of the PA 2008, which includes: prescribed consultees, local authorities defined by section 43 and each person within one or more categories set out in section 44 of the 2008 Act. Section 42(1) of the PA 2008 states: 42. Duty to consult (1) The applicant must consult the following about the proposed application (a) such persons as may be prescribed, (aa) the Marine Management Organisation, in any case where the proposed development would affect, or would be likely to affect, any of the areas specified in subsection (2) (b) each local authority that is within section 43, (c) the Greater London Authority if the land is in Greater London, and (d) each person who is within one or more of the categories set out in section 44 For the purposes of section 42(1)(a) of the PA 2008, the persons prescribed are those listed in column 1 of the table in Schedule 1 to the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 (the APFP Regulations). In addition, as the Moorside Project will affect areas under the jurisdiction of the Marine Management Organisation, NuGen is required to consult with the Marine Management Organisation under section 42(1)(aa). In compiling the list of consultees under section 42, NuGen ensured compliance with the following: Schedule 1 to The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009; consultees who were notified to NuGen by the Planning Inspectorate under Regulation 9 of The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009; Planning Inspectorate. Advice Note 3; and DCLG guidance Identification of consultees Section 42(1)(b) local authorities are defined as those within which the land to which the proposed development relates to is located (referred to as section 43(1) local authorities). It also includes those local authorities that share a boundary with that authority (referred to as section 43(2) local authorities). The prescribed local authorities that were consulted are listed below. Allerdale Borough Council Barrow Borough Council Carlisle City Council Copeland Borough Council Cumbria County Council Dumfries and Galloway Borough Council Durham County Council Eden District Council Lake District National Park Lancashire County Council Northumberland County Council Northumberland National Park South Lakeland District Council Scottish Borders Council Yorkshire Dales National Park Authority Beckermet Parish Council Brigham Parish Council Cockermouth Town Council Egremont Town Council Haile and Wilton Parish Council Lowside Quarter Parish Council Moresby Parish Council Parton Parish Council Ponsonby Parish Council St Bees Parish Council Whitehaven Town Council Workington Town Council PAGE 51

52 10. Stage Two: Consultation with Statutory Consultees, Section 42 Additional local authorities which NuGen felt may have an interest in the proposals due to proximity were also consulted on the same basis. This was a voluntary action by NuGen as consultation with these bodies is not required under section 42. These are listed below. Arlecdon and Frizington Parish Council Camerton Parish Council Dean Parish Council Distington Parish Council Cleator Moor Town Council Ennerdale and Kinniside Parish Council Gosforth Parish Council Great Clifton Parish Council Great Southern Parish Council Lowca Parish Council Seascale Parish Council Seaton Parish Council Weddicar Parish Council Winscales Parish Council Section 42(1)(d) requires those persons within section 44 of the PA 2008 to be consulted. These persons are those who own, lease, tenant or occupy land to which the proposed development relates (referred to as Category 1 persons). It also includes those persons that are interested in the land or have power to sell and convey the land or to release the land (referred to as Category 2 persons). The third category is those persons entitled to make a relevant claim if the DCO sought by the proposed development were to be made and fully implemented (referred to as Category 3 persons). In order to establish the identity of these persons with an interest in the land (PILs), consultants acting on behalf of NuGen carried out land referencing which included land registry searches, requests for information and one to one meetings with landowners, tenants and land agents. There is a duty on NuGen, when consulting a person under section 42, to notify them of the deadline for receipt of comments to the consultation (section 45(1)). This must be a minimum of 28 days, commencing on the day after the person receives the consultation documents (section 45(2)). Consultation material must be supplied to the person by NuGen for the purposes of the consultation (section 45(3)). A full list of consultees consulted under section 42 can be found in Appendix 9a, excluding PILs whose addresses have not been published for reasons of data protection Duty to notify the Secretary of State of proposed application under Section 46 Aligned with statutory consultation under section 42 is the requirement for the applicant to notify the Secretary of State of the application under section 46 of the PA This must be done on or before commencing consultation under section 42 and the Secretary of State must be supplied with the same information as is proposed to be used for consultation under section 42. NuGen wrote to the Planning Inspectorate, the body that manages the DCO application process on behalf of the Secretary of State, on Friday 12th May 2016 informing him of the consultation to be carried out under section 42 of the PA (Appendix 9c) contains the section 46 letter notice to the Secretary of State. The consultation material used for section 42 consultation was included with the letter. PAGE 52

53 10. Stage Two: Consultation with Statutory Consultees, Section Consultation activity NuGen wrote to all consultees listed in Appendix 9a, inviting comments on the Moorside Project under section 42 of the PA 2008 (Letter in Appendix 9b). This included 202 statutory consultees (section 42(1) a), 42(1)(aa) and 42(1)(b)), 73 additional discretionary bodies (bodies NuGen voluntarily consulted) and 2,135 PILs (section 42(1)(d)). In addition to those PILs NuGen was required to consult with under section 42(1)(d), 558 properties included within a zone around the Moorside Site were sent the draft Property Support and Mitigation Scheme that formed part of the section 42 consultation pack. The following consultation materials were sent to those bodies under section 42(1)(a). 42(1)(aa) and 42(1)(b): a letter notifying the consultee of consultation under section 42 of the PA 2008; a letter notifying the consultee under Regulation 11 of The Infrastructure Planning (Environment Impact Assessment) Regulation 2009; a copy of the section 48 notice (see section 12 below); the Proposed Scheme Overview document; a feedback form; a guide to the consultation documents; the Non-Technical Summary of the Preliminary Environmental Information Report; and a USB with copies of all the consultation documents (See Figure 9 DCO Stage Two Consultation Documents above). The following consultation materials were sent to PILs (section 42(1)(d)): a letter notifying the consultee of consultation under section 42 of the PA 2008; the Proposed Scheme Overview document; a feedback form; a guide to the consultation documents; and a USB with copies of all the consultation documents. Packs were either initially distributed by Royal Mail Track and Trace or hand delivered by members of the project team. Where initial delivery failed, or where consultees were identified after the start of consultation, follow up delivery was organised by courier to ensure the respondents had at least 28 days from the day after receipt of the documents to provide feedback. 1,762 packs were hand delivered to PILs. 349 PILs who were not local to the area or where initial delivery by hand had failed were sent information by the Royal Mail s Track and Trace. Packs were either initially distributed by Royal Mail Track and Trace or hand delivered by members of the project team. Where initial delivery via Royal Mail failed, or where consultees were identified after the start of consultation, follow up delivery was organised by courier to ensure the respondents had at least 28 days from the day after receipt of the documents to provide feedback. A number of PILs were identified late in the consultation process. These consultees were sent information and given at least 28 days to return feedback. All feedback from consultees was accepted. PAGE 53

54 11. Stage Two: Consultation with the Public (s 47) Stage Two Consultation This section sets demonstrates how NuGen fulfilled its consultation requirements as set out in the May 2016 Stage Two Proposed Scheme Consultation SoCC. Some consultation activity was carried out in addition to the requirements set out in the Stage Two SoCC. Details of this activity have been in included in section Consultation documents The Stage Two Consultation consisted of a number of documents relating to the proposed Moorside Project. The documents were designed to allow access at different levels of interest. A short overview document and a newsletter were available for those who wished to access project information at a high level and more detailed documentation, plans and maps were available for those needing more detail. Physical representations of the Moorside Project were digitised wherever possible, including a virtual reality view from all angles including the views from various homes in the area. Full sets of information were made available on a USB card (the size of a credit card) and were available free of charge. All the documents listed below were available to view on the consultation website, at NuGen s continuous exhibition in the Moorside Information Centre in Whitehaven, at the public exhibition events listed in section 11.3 below, and at selected local council offices and libraries Consultation events A programme of consultation events were arranged for the Stage Two consultation to enable members of the community to speak to NuGen s experts about all areas related to the Moorside Project. They were also informed about how they could provide their views in response to the consultation. As before, the purpose of the events was to supplement NuGen s consultation documents and provide people with the information they needed to make an effective response to the consultation. As with the Stage One Consultation, NuGen s approach and process for consultation with people living within the vicinity of the Moorside Project, recognised that the development will have the greatest impact on the people that live nearest to the Moorside Site. Consequently, they were likely to have the greatest interest in the proposals. NuGen also recognised the large scale and widespread impact of the Moorside Project. The structure of the programme of events in the Stage One Consultation was, therefore, repeated with a high density of events closer to the Moorside Site but also providing opportunities for the wider Cumbria Community by holding events in all the main County towns. All the previous locations for events were included again but extra events were added to meet the additional objectives set following the learning review of Stage One Consultation as described in Section 9.2. Thirty-two public exhibitions and information days were held over a period of 11 weeks. This allowed members of the community to have an opportunity to talk to the project team about the Moorside Project, and to help understand the proposals and respond to the consultation. The exhibitions included paper copies of all consultation documents for members of the public to review. USB cards, with a full set of documents, were made available to all attending events or otherwise requested. 3D digital visualisations of the proposals were available to view enabling individuals to view the proposal from various angles and locations in including from their own homes and gardens. Videos were available explaining the project and the proposals. PAGE 54

55 11. Stage Two: Consultation with the Public (s 47) The eleven weeks of consultation was a longer than the Stage One Consultation and extended into school holiday weeks that allowed for more tourist/ visitor engagement. Events held during the school holidays (both half term and summer) were in areas that experienced more tourist visits. Approximately 2,800 people attended the events during the consultation period that ran from 14th May to 30st July All consultation events were held from 11am to 7.30pm unless otherwise advertised. A list of the consultation events with a breakdown of attendees is set out below. Date Place Venue Attendees Sat 14th May Whitehaven Moorside Information Centre, Civic Hall, Lowther Street, Whitehaven CA28 7SH Tues 17th May Egremont Market Hall, Main Street, Egremont, Cumbria, CA22 2DF Wed 18th May St Bees Management Centre, Whitelaw Building, School House Lane, Saint Bees CA27 0AA Thurs 19th May Beckermet Reading Rooms, Sellafield Road Beckermet CA21 2XN Mon 23rd May Seascale Methodist Church Hall, Gosforth Road, Seascale, Cumbria CA20 1PU Tues 24th May Gosforth Village Hall, Gosforth, Seascale, Cumbria CA20 1AS Wed 25th May Cleator Moor Civic & Masonic Centre, The Square, Cleator Moor, Cumbria CA25 5AU Sat 28th May Young Farmers (*10am to 4pm, stall at event) Calder Farm, Seascale Cumbria CA20 1EH 59 Tues 31st May Keswick Greta Suite, Skiddaw Hotel, 31 Main Street, Keswick, Cumbria CA12 5BN Wed 1st June Ravenglass Muncaster Parish Hall, Ravenglass, Cumbria CA18 1SQ Thurs 2nd June Braystones Tarnside Caravan Park, Braystones, Cumbria CA21 2YW Tues 7th June Mirehouse Community Centre, Seathwaite Avenue, Whitehaven CA28 9SW Wed 8th June Westlakes Samuel Lindow Building, Westlakes Science and Technology Park, Cumbria, CA24 3JY Thurs 9th June Distington Community Centre, Church Road, Distington, Cumbria CA14 5TE Tues 14th June Wed 15th June Askam-in- Furness Barrow-in- Furness Community Centre, Duke St, Askam-in- Furness, Cumbria LA16 7AD Rydal Room, The Forum, Duke Street, Barrow-in-Furness, Cumbria LA14 1HH PAGE 55

56 11. Stage Two: Consultation with the Public (s 47) Date Place Venue Attendees Thur 16th June Broughton-in- Furness Victory Hall, Station Road, Broughton-in- Furness, Cumbria LA20 6HN Tues 21st June Cockermouth Town Hall, Market Street, Cockermouth, Cumbria CA13 9NP Wed 22nd June Maryport St Mark s Methodist Church, Kirkby St, Maryport, Cumbria CA15 6EX Thurs 23rd June Mirehouse Labour Club, Labour Club, Honister Road, Mirehouse, Cumbria CA28 8HO Monday 27th June Tues 28th June - Thurs 30th June Calderbridge ( ) Schools events ( at each) Village Hall, Calderbridge, Seascale, Cumbria CA20 1DN Whitehaven Academy, St Benedict s, Millom Tue 5th July Workington Bridge Centre, Central Square, Workington, Cumbria, CA14 3BG Wed 6th July Lillyhall Energus, Atrium, Blackwood Road, Lillyhall, Workington, Cumbria CA14 4JW Thurs 7th July Sellafield ( ) Estimated 400 total Seascale. Cumbria CA20 1PG 186 Tues 12th July Kendal Town Hall, Kendal, Cumbria LA9 4DL 31 Wed 13th July Millom Pensioner s Hall, Mainsgate Road, Millom LA18 4JZ Thurs 14th July Bootle Millstones, Conservation and Energy Centre, A595, Bootle, Cumbria LA19 5TJ Tuesday 19th July Wigton Market Hall, Church Street, Wigton, Cumbria CA7 9AA Wed 20th July Carlisle Merlot Suite, Hallmark Hotel, Court Square, Carlisle, Cumbria CA1 1QY Thurs 21st July Penrith Masonic Hall, 6 Portland Place, Penrith CA11 7QN Wed 27th July Whitehaven Moorside Information Centre, Civic Hall, Lowther Street, Whitehaven CA28 7SH PAGE 56

57 11. Stage Two: Consultation with the Public (s 47) Promotion Direct mail The Proposed Scheme Overview document (a 12-page summary document explaining the proposed scheme for the Moorside Project), a newsletter (with details of the consultation events), and a copy of the Feedback Form were sent to all postal addresses within the area indicated by the map shown below. This area equates to the Whitehaven Travel to Work Area, combined with addresses within 0.5km of any associated development site that is outside the Whitehaven Travel to Work Area. This distribution included approximately 40,000 addresses (Proposed Scheme Overview attached as Appendix 10a). The Royal Mail carried out the distribution beginning with a newsletter giving advance notice of the Stage Two Consultation on 25th March 2016 followed by the main mailing on 16th May Newsletter attached as Appendix 10b). Figure 11 Whitehaven Travel to Work Area PAGE 57

58 11. Stage Two: Consultation with the Public (s 47) Press adverting campaign A press advertising campaign ran from April 2016 combining press releases and advertisements. The campaign announced, and gave information about, the Stage Two Consultation. Advertisements were placed in publications throughout the wider region, as listed in the table below. SoCC Insertion Event promotion announcements Specific advert promotion for events Print Date Date Date 1 Date 2 The Whitehaven News 07/04/ /04/ /05/ /06/2016 The Times and Star 08/04/ /04/ /05/ /06/2016 The Cumberland News 08/04/ /04/2016 N/A N/A The News and Star 07/04/ /04/2016 N/A N/A The North West Evening Mail The Cumberland and Westmorland Herald 08/04/ /04/2016 N/A N/A 09/04/ /04/2016 N/A N/A The Keswick Reminder 08/04/ /04/2016 N/A N/A The Westmorland Gazette 08/04/ /04/2016 N/A N/A Advertisements were placed on the following newspaper websites, throughout May, June and July 2016 (see Appendix 10c): A public relations campaign, designed to raise awareness and interest the Stage Two Consultation was carried out, generating editorial coverage of the consultation, as listed below. 12/05/2016: ITV Border 12/05/2016: Whitehaven News 16/05/2016: News and Star 16/05/2016: Big Issue North 17/05/2016: Whitehaven News 18/05/2016: News and Star 19/05/2016: Whitehaven News 19/05/2016: News and Star 20/05/2016: Whitehaven News TV/Radio NuGen promoted the Stage Two Consultation and events through a mixture of paid-for, and news coverage, on local, TV and radio. Coverage and advertisement details are listed below. This included a paid for radio campaign on CFM radio aimed at reaching younger people. This involved 128 radio spots between 2 May and 24 July PAGE 58

59 11. Stage Two: Consultation with the Public (s 47) Posters Posters with details of local exhibitions and how to respond to the Stage Two Consultation were sent to parish and town councils in the areas of the Moorside Project Sites to enable them to promote the Stage Two Consultation (see Appendix 10d). The parish and town councils were: Askam & Ireleth Parish Council Barrow Borough Council Beckermet with Thornhill Parish Council Bootle Parish Council Broughton East Parish Council Carlisle City Council Cleator Moor Town Council Cockermouth Town Council Distington Parish Council Egremont Town Council Gosforth Parish Council Kendal Town Council Keswick Town Council Lowside Quarter Parish Council Maryport Town Council Millom Town Council Muncaster Parish Council Penrith Town Council Seascale Parish Council St Bees Parish Council Whitehaven Town Council Wigton Town Council Wokington Town Council The posters and other information were also sent to organisations and intermediaries that had strong relationships with hard to reach groups. Social media NuGen used its social media channels, Twitter and LinkedIn, to publicise the Stage Two Consultation through its network of followers, which directed people to the consultation website, where more detailed information could be found. Presentations The following organisations requested presentations on aspects of the Stage Two Consultation during the consultation period. All invitations were accepted and presentations provided to: Lake District National Park Authority, Drigg Parish Council, Ponsonby Parish Council, Haile and Wilton Parish Council and Beckermet Parish Council Information availability All Stage Two Consultation documentation and details of the consultation, including event locations and timings, were available on the Moorside Project s consultation website com, which was also sign-posted in all key literature. All consultation documents were available for review at the Moorside Information Centre. The Centre had 445 visitors during the consultation period. Hard copies of all the documents were available from 14th May 2016 to 30th July 2016 at: Whitehaven Library, Lowther Street, Whitehaven, CA28 7QZ; Workington Library, Vulcans Lane, Workington, CA14 2ND; Carlisle Library, 11 Globe Lane, Carlisle, CA3 8NX; Barrow Library, Ramsden Square, Barrow-in-Furness, LA14 1LL; Penrith Library, St. Andrew s Churchyard, Penrith, CA11 7YA; and Kendal Library, Stricklandgate, Kendal, LA9 4PY. PAGE 59

60 11. Stage Two: Consultation with the Public (s 47) Hard copies of the Proposed Scheme Overview and the Proposed Scheme documents were also available from 14th May 2016 to 30th July 2016 at: Cleator Moor Library, Market Square, Cleator Moor, CA25 5AP; Egremont Library, Main Street, Egremont, CA22 2DB; Seascale Library, Gosforth Road, Seascale, CA20 1PN; Mirehouse Library, Meadow Road, Whitehaven, CA28 8ER; Gosforth Library, Public Hall, Gosforth, Seascale, CA20 1AS; and Cockermouth Library, 92 Main Street, Cockermouth, CA13 9LU. As set out in the published Stage Two SoCC, members of the community were free to comment on any element of the proposals that they wished through several different feedback mechanisms. However, it should be noted that the Stage Two Consultation documentation made it clear that the specific locations of the reactors within the Moorside Site were fixed and not the subject of consultation. This was because geological studies, technical and safety issues curtailed the potential for relocation. The Stage Two Consultation included several questions designed to focus comments on key aspects of NuGen s proposals. These questions were included in the Proposed Scheme document and replicated in a Feedback Form, which was widely available both printed and online. The questions were open questions inviting views on the issues raised, unlike the Stage One Consultation that included many multiple-choice answers. As result, the method of analysis reflects this difference. Members of the community could provide feedback via a feedback form, comment card or any other recorded medium in any of the following ways. In person at a public exhibition or at the Moorside Information Centre at the Civic Centre, Whitehaven (open from 10am to 4pm Monday to Friday and additionally 10am to 12 noon on Saturdays during the Stage Two Consultation period). Online at By post to FREEPOST - MOORSIDE HAVE YOUR SAY By to haveyoursay@nugenconsultation.com Variations from the SoCC Additional activities An additional exhibition was held at a young farmers event on Saturday 28th May. NuGen was asked to support the event and it was felt an opportunity to engage with young people in rural areas, a group that is often hard to reach. NuGen received representations from Ponsonby Parish Council and some people living in that area suggesting that an additional event at Calderbridge would be beneficial. An event in this location was not originally proposed due the village s proximity to other events in Beckermet, Seascale and Gosforth that were close by. However, NuGen wanted to make sure no area felt under consulted and therefore, held the additional event on Monday 27th June. Three specific events were designed for three local secondary schools with activities to encourage students to engage. This was part of NuGen s continuing effort to encourage responses from a younger age group. Mailing of the Proposed Scheme Overview document, newsletter, and cover letter was made to organisations with relationships with hard to reach groups along with the poster as mentioned above. The mailing list is attached as appendix 11. This action was carried out following research carried out on the best way of engaging hard to reach groups as part of the development of NuGen s Consultation Strategy. Deviations There were no other deviations from the published Stage Two SoCC. PAGE 60

61 12. Stage Two: Publicity under Section Statutory context This section sets out the approach taken to publicity under section 48 of the PA 2008 for the Stage Two Consultation. Section 48 of the PA 2008 requires: (1) The applicant must publicise the proposed application in the prescribed manner. (2) Regulations made for the purposes of subsection (1) must, in particular, make provision for publicity under subsection (1) to include a deadline for receipt by the applicant of responses to the publicity. Section 4 of The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 sets out the requirements for fulfilling this section of the PA According to Regulation 4, the notice must include: (a) the name and address of the applicant (b) a statement that the applicant intends to make an application for development consent to the Secretary of State; (c) a statement as to whether the application is EIA development; (d) a summary of the main proposals, specifying the location or route of the proposed development; (e) a statement that the documents, plans and maps showing the nature and location of the proposed development are available for inspection free of charge at the places (including at least one address in the vicinity of the proposed development) and times set out in the notice; (f) the latest date on which those documents, plans and maps will be available for inspection (being a date not earlier than the deadline in sub-paragraph (i)); (g) whether a charge will be made for copies of any of the documents, plans or maps and the amount of any charge; (h) details of how to respond to the publicity; and (i) a deadline for receipt of those responses by the applicant, being not less than 28 days following the date when the notice is last published Publicity A notice fulfilling the requirements set out above was placed in the following publications on the following dates: Publication Dates The London Gazette 19/05/2016 The Times 19/05/2016 Lloyd s List 19/05/2016 Sea Fishing 25/05/2016 Edinburgh Gazette 20/05/2016 Whitehaven News 12/05/2016 and 19/05/2016 Times and Star 13/05/2016 and 20/05/2016 PAGE 61

62 13. Stage Two: Feedback under Section Overview This section reports on the feedback received during the Stage Two Consultation. This is split into feedback received under section 42 of the PA 2008 in this section, and from the public under section 47 and section 48 in the next section. Further detail is included in Appendix 13a and b. Section 49 of the PA 2008 requires an applicant to have regard to all relevant responses received during statutory consultation (under sections 42, 47 and 48). This section of the Interim Consultation Report 2 and its related appendices sets out NuGen s progress towards meeting this requirement. The requirements of section 49 of the PA 2008 with regards to the Moorside Project can only be met when final decisions have been taken on the content of the proposals, which will be based on the representations received from the Stage One Consultation and Stage Two Consultation, continuing design work, project requirements, and continuing environmental impact assessment. This will be met fully in the statutory Consultation Report that will be submitted with NuGen s DCO submission. The statutory context and relevant Department for Communities and Local Government (DCLG) advice is included below. Section 49 of the PA 2008 states: (1) Subsection (2) applies where the applicant: (a) has complied with sections 42, 47 and 48, and (b) proposes to go ahead with making an application for an order granting development consent (whether or not in the same terms as the proposed application). (2) The applicant must, when deciding whether the application that the applicant is actually to make should be in the same terms as the proposed application, have regard to any relevant responses. (3) In subsection (2) relevant response means: (a) a response from a person consulted under section 42 that is received by the applicant before the deadline imposed by section 45 in that person s case, (b) a response to consultation under section 47(7) that is received by the applicant before any applicable deadline imposed in accordance with the statement prepared under section 47, or (c) a response to publicity under section 48 that is received by the applicant before the deadline imposed in accordance with section 48(2) in relation to that publicity DCLG guidance Supporting the requirements of the PA 2008, DCLG has published guidance on the pre-application process including on what a consultation report should contain. The most relevant paragraph is summarized in 7.2 above Issues Feedback was received by 38 statutory consultee organisations. Some of the parish and town councils consulted with are not formally statutory consultees under section 42, but NuGen considered that given their elected status as representatives of the community, they should be considered alongside similar bodies under section 42. PAGE 62

63 13. Stage Two: Feedback under Section 42 From the 2,135 identified PILs, NuGen received 146 comments in relation to the consultation. Many of the comments received did not explicitly comment from the standpoint of an interest in the land and these have been included and analysed alongside the responses under section 47. However, In future updates the responses of PILs will be separated and will be the subject of separate analysis and reporting. At the time NuGen began its strategic review, this work had not been completed. This specific assessment will be carried out before the next iteration of project proposals are determined and made available in advance of any future consultation. Any detailed concerns expressed relating to land interests have not been included in this report or its appendices for data protection reasons. In the meantime, NuGen will continue to work with landowners on an individual basis. A number of PILs submitted the Residents Affected by Moorside (RAM) response as their responses, and these have also been included and analysed under section Breakdown of feedback received: Statutory Consultees and Local Authorities Below is a breakdown of statutory consultees and local authorities responding and the theme of the issues they raised. PAGE 63

64 13. Stage Two: Feedback under Section 42 Consultation Theme Consultees Proposed Development within the Moorside Site Accommodation Sites General Accommodation Sites Mirehouse Accommodation Sites Egremont Corkickle to Mirehouse Railway Beckermet with Thornhill Parish Council Bootle Parish Council Copeland Borough Council Cumbria Constabulary Cumbria County Council Egremont Town Council Environment Agency Highways England Historic England - North West Millom Without Parish Council National Trust Whicham Parish Council Allerdale Borough Council Bootle Parish Council Copeland Borough Council Cumbria Constabulary Cumbria County Council Egremont Town Council Millom Town Council Millom Without Parish Council Sellafield The Coal Authority United Utilities Whicham Parish Council St Bees Parish Council Beckermet with Thornhill Parish Council Egremont Town Council Bootle Parish Council Copeland Borough Council Egremont Town Council Parton Parish Council PAGE 64

65 13. Stage Two: Feedback under Section 42 Consultation Theme Consultees Highway Improvements Public Rights of Way and Amenity Routes Highways Common Land Site preparation application(s)* Beckermet with Thornhill Parish Council Blawith and Subberthwaite Parish Council Bootle Parish Council Carlisle City Council Copeland Borough Council Cumbria Constabulary Cumbria County Council Duddon Parish Council Egremont Town Council Gosforth Parish Council Highways England Lake District National Park Millom Town Council Millom Without Parish Council NDA NHS - Transport Enabling Group for West, North & East Cumbria (WNEC) Success Regime Parton Parish Council St Bees Parish Council Weddicar Parish Council Whicham Parish Council Beckermet with Thornhill Parish Council Copeland Borough Council Cumbria County Council Egremont Town Council Gosforth Parish Council National Trust St Bees Parish Council Weddicar Parish Council Beckermet with Thornhill Parish Council Bootle Parish Council Copeland Borough Council Cumbria County Council Duddon Parish Council Egremont Town Council Millom Without Parish Council Ponsonby Parish Council Weddicar Parish Council Whicham Parish Council Copeland Borough Council Cumbria County Council Natural England Copeland Borough Council Cumbria County Council Egremont Town Council Millom Without Parish Council Whicham Parish Council PAGE 65

66 13. Stage Two: Feedback under Section 42 Consultation Theme Consultees The Benefits and Legacy that NuGen wants to leave How NuGen s design for the Moorside Project has evolved Landscape Strategy Land & Property Allerdale Borough Council Askam and Ireleth Parish Council Blawith and Subberthwaite Parish Council Bootle Parish Council Carlisle City Council Cleator Moor Town Council Copeland Borough Council Cumbria County Council Duddon Parish Council Egremont Town Council Gosforth Parish Council Millom Town Council Millom Without Parish Council NDA Ponsonby Parish Council St Bees Parish Council Weddicar Parish Council Whicham Parish Council Askam and Ireleth Parish Council Beckermet with Thornhill Parish Council Copeland Borough Council Duddon Parish Council Egremont Town Council Beckermet with Thornhill Parish Council Blawith and Subberthwaite Parish Council Bootle Parish Council Copeland Borough Council Cumbria Constabulary Cumbria County Council Egremont Town Council Gosforth Parish Council Millom Without Parish Council National Trust Ponsonby Parish Council Askam and Ireleth Parish Council Beckermet with Thornhill Parish Council Copeland Borough Council Cumbria County Council Egremont Town Council NDA Network Rail Sellafield PAGE 66

67 13. Stage Two: Feedback under Section 42 Consultation Theme Consultees Health impacts Other (See 14.3 for breakdown) Allerdale Borough Council Beckermet with Thornhill Parish Council Bootle Parish Council Carlisle City Council Cleator Moor Town Council Copeland Borough Council Cumbria Constabulary Cumbria County Council Duddon Parish Council Gosforth Parish Council Highways England Lake District National Park Millom Without Parish Council NHS NHS - Cumbria and the North East (on behalf of Local Health Resilience Partnership) NHS - Transport Enabling Group for West, North & East Cumbria (WNEC) Success Regime St Bees Parish Council Weddicar Parish Council Whicham Parish Council Allerdale Borough Council Askam and Ireleth Parish Council Beckermet with Thornhill Parish Council Blawith and Subberthwaite Parish Council Bootle Parish Council Cleator Moor Town Council Cumbria Constabulary Cumbria County Council Duddon Parish Council Egremont Town Council Environment Agency Gosforth Parish Council Highways England Historic England - North West Lake District National Park Marine Management Organisation Millom Town Council Millom Without Parish Council National Trust Natural England NDA Network Rail Ponsonby Parish Council Public Health England PAGE 67

68 13. Stage Two: Feedback under Section 42 Consultation Theme Consultees Other (See 14.3 for breakdown) Consultation** Scottish Natural Heritage SEPA St Bees Parish Council The Coal Authority United Utilities Whicham Parish Council West Cumbria Sites Stakeholder Group Allerdale Borough Council Askam and Ireleth Parish Council Beckermet with Thornhill Parish Council Bootle Parish Council Copeland Borough Council Cumbria Constabulary Cumbria County Council Duddon Parish Council Egremont Town Council Environment Agency Gosforth Parish Council Highways England Historic England - North West Lake District National Park Marine Management Organisation Millom Town Council Millom Without Parish Council National Trust Natural England NDA NHS NHS - Cumbria and the North East (on behalf of Local Health Resilience Partnership) Ponsonby Parish Council Public Health England Scottish Natural Heritage SEPA United Utilities Whicham Parish Council * Any potential site preparation application(s) to Copeland Borough Council would not form part of the DCO application, however it was appropriate to consult on these proposals during Stage Two Consultation. ** Issues relating to the consultation itself fall outside of the scope of Stage Two but are valuable feedback on the process. PAGE 68

69 13. Stage Two: Feedback under Section Breakdown of feedback received: Non-Statutory Organisations Below is a breakdown of non-statutory bodies and local authorities that raised issues with regards to each of the key consultation themes. Whilst these are not Statutory Consultees, they have been treated in the same manner for reporting purposes at present. They are represented as a separate section in Appendix 13a. Consultation Theme Proposed Development within the Moorside Site Accommodation Sites General Accommodation Sites Corkickle Corkickle to Mirehouse Railway Highways Public Rights of Way and Amenity Routes Common Land The Benefits and Legacy that NuGen wants to leave How NuGen s design for the Moorside Project has evolved Landscape Strategy Land & Property Health and impacts Other Consultation** Consultees Residents Affected by Moorside Egremont Anglers Group Regeneration North East Copeland St Begh s Parish and Junior School Community Rail Cumbria Residents Affected by Moorside Residents Affected by Moorside Lake District Area Ramblers Natural England Residents Affected by Moorside Cumbria ACTion Residents affected by Moorside Residents affected by Moorside Residents affected by Moorside esidents affected by Moorside Cumbria Wildlife Trust Duddon Estuary Partnership Friends of the Lake District Residents affected by Moorside Cumbria Local Enterprise Partnership Residents affected by Moorside PAGE 69

70 13. Stage Two: Feedback under Section Feedback overview A full breakdown of the issues raised by each organisation as well as how NuGen has had regard to the responses will be included in the final consultation report submitted with the DCO application. Appendix 13a sets out an overview of the key issues raised by different types of organisation under each of the themes identified in the tables above in the left-hand column. The idea behind Appendix 13a is to provide all those interested in the Moorside Project with an idea of the themes emerging from the Stage Two Consultation and before any future round of consultation. It is not intended to be a detailed assessment of each response and how NuGen is having regard to them, as this is currently on-going. This is not comprehensive as it summarises the responses into 142 entries in the table out of a total of more than 1,000 issues raised by consultees. The full, detailed set of points made in the responses are recorded and numbered and will be taken forward for consideration in future project design phases after the completion of NuGen s strategic review. NuGen s Consultation Report, which will be prepared and submitted with the DCO application, will explain how the application was informed and influenced by those responses. The report will also be informed by responses to future consultation(s), outlining any changes made as a result, and showing how significant relevant responses were addressed. The final Consultation Report will also provide an explanation as to why any responses requesting major changes to the Moorside Project were not followed (where that is the case), including advice from statutory consultees on impacts. In addition to a wide variety of detailed points raised, there was an overriding view from key statutory stakeholders that there was a need for more project detail and more assessment under the EIA and fully developed mitigation plans. They believed that this further information was needed in a number of areas before they could fully comment on the project. In line with this they believed that a further consultation would be needed when the information was available. PAGE 70

71 14. Stage Two: Community Feedback under Section 47 Overview During the Stage Two Consultation, 1,226 responses were received from members of the public, an increase on the 779 responses received during the Stage One. Currently this has been included in this figure responses from PILs, who are statutory consultees under section 42 of the PA In future updates, the responses of PILs will be separated and will be the subject of separate analysis and reporting. At the time NuGen began its strategic review this piece of work had not been completed. This specific assessment will be carried out before the next iteration of project proposals are determined and made available in advance of any future consultation. The feedback received totalled approximately 350,000 words - a significant increase on the level of feedback received at Stage One. A full breakdown of the issues raised will be included within the consultation report accompanying the DCO submission. That report will also include details of how NuGen has considered and had regard to the issues and if they lead to any changes in the Moorside Project. The average age (where declared) of respondents (from the data collected) was 56.4 years old, which is similar to Stage One. Where data was available, the ratio of male to female respondents appears to have become more equal since the Stage One, respondents were approximately 60% male and 40% female (respondents to the Stage One Consultation were approximately 68% male and 32% female). The average age of responders varied little from Stage One despite the additional actions that were incorporated into the consultation process to engage with a greater number of younger people Respondent location Of those who gave feedback to the Stage Two Consultation, 564 supplied postcodes. The graphic below shows the location of respondents across the region. Where no number is identified in a highlighted location this reflects a single response. PAGE 71 Figure 12 location of respondents across the region

72 14. Stage Two: Community Feedback under Section 47 Below is the national location of respondents, based only on those respondents that provided postcodes Figure 13 location of respondents nationally Methodology This section covers the written feedback received during the Stage Two Consultation. This includes the open questions from the feedback form, the comment cards received and letters and s sent directly in response to the consultation. It excludes feedback received from statutory consultees and groups that have been discussed in the previous section. The process used is as follows. 1. Each individual piece of written feedback was reviewed, one at a time. 2. The salient points within the first piece of written feedback were summarised, as suggested in DCLG s published Guidance on the pre-application process (March 2015), and listed. 3. The next piece of written feedback was then reviewed. Issues within the feedback that had already been summarised would be noted so that a record would be kept that the issue had been raised again and, if necessary, the summarisation would be updated to include additional relevant information. All issues that had not been already summarised would then be summarised as outlined above. 4. Each summarised issue was assigned to one of the themes used. In general, unless substantially irrelevant to NuGen s proposals for the Moorside Project, all issues were recorded and summarised. Responses that were clearly directed towards National Grid s North West Coastal Connection project were referred to National Grid as appropriate. PAGE 72

73 14. Stage Two: Community Feedback under Section 47 All summarised issues were then numbered to allow future tracking and to ensure that NuGen could be confident that each was considered fully. In order to avoid potential loss of context and content in the relatively small number of highly detailed representations from members of the public, where appropriate, some feedback text has not been summarised but simply recorded verbatim. Following this the process has identified that there were over 5,600 individual incidents of issues being raised involving 426 different summarised issues across the 18 themes set out (including an Other theme). A schedule of the most frequently occurring summarised issues, organised by theme, can be found in Appendix 13b Feedback overview The 1,226 respondents to the Stage Two Consultation provided over 5,600 individual issues. The most commonly raised themes were the proposals for the Moorside Site (13.3%), the benefits and legacy of the Moorside Project (11.20%), and health issues and potential impacts (9.92%). Other significant areas of comment were NuGen s proposed highways improvements (8.40%), and general comments regarding the proposals for the Accommodation Sites (7.14%). A further 4.98% of issues were made about specific proposed Accommodation Sites, with Corkickle attracting the most amount of feedback. The breakdown is set out in Figure 13 number of responses by theme, below Egremont Accommodation Site Mirehouse Accommodation Site Evolution of Project Design Common Land Site preparation application Corkickle Accommodation Site Corkickle to Mirehouse Railway Landscape Strategy Land and Property Rights of way/ amenity routes Consultation Accommodation Sites General Health and Impacts Highways Nugen; Legacy and Benefits Moorside Power Station Site Other Figure 14 number of responses by theme PAGE 73

74 14. Stage Two: Community Feedback under Section 47 There were also a number of additional issues raised that were outside of the themes set out by NuGen during the Stage Two Consultation (14.17%). These have been summarised into 38 different issues. Comments were also made about the consultation process itself (5.39%) Amount of exported energy Reactor technology Emergency evacuation plans Public should decide democratically Impact on tourism View from National Park Should be somewhere else Concerns about nuclear waste Support for opposition groups General Support Concerns about environment Concerns about safety Opposition to the project Figure 15 Most raised additional summarised issues under the Other theme Support for highways proposals with some additional Support retention of Nursery Road Scepticism that there will be any health benefit from the Support for reuse of Waste Heat Concern about property prices and adequacy Property Concern Hospital or primary care services will not have Highways improvements do not go far enough Don t recognise validity of consultation process for Concerns about environmental impact Concern for safety Scepticism that benefits and legacy will be achieved General opposition to project Figure 16 Most raised summarised Issues across all themes (including Other) PAGE 74

75 14. Stage Two: Community Feedback under Section 47 Proposed Scheme Document topic Proposed Development within the Moorside Site Highway Improvements 43 The Benefits and Legacy that NuGen wants to leave # Proposed Scheme Document topic 68 Landscape Strategy Public Rights of Way and Amenity Routes How NuGen s design for the Moorside Project has evolved Other 38 Highways 12 Corkickle to Mirehouse Railway 32 Accommodation Sites Mirehouse 9 Accommodation Sites General 32 Accommodation Sites Egremont 9 Consultation 25 Accommodation Sites Corkickle 8 Land and Property 24 Common Land 7 Health and Impacts 22 Site preparation application(s) 5 # Total 426 Figure 17 Number of different summarised issues raised by theme PAGE 75

76 15. Stage Two: Informal Engagement Processes The previous section describes the approach to statutory consultation by NuGen in developing the Moorside Project. In addition, continuous informal engagement with stakeholders in the development of proposals was a key part of the development process. Key technical agencies had regular inputs to the Moorside Project particularly through the Moorside Technical Group (MTG) and its sub groups. (See appendix 14). These agencies were, and will continue to be, involved in periodic testing of developing concepts, assessments and information. Project development progress was regularly discussed with non-technical stakeholders. NuGen has a high profile in the locality by providing community support and being involved in a number of partnerships. This has promoted greater understanding of NuGen s presence and developing proposals. It has provided NuGen with a full understanding of the local context within which its proposals need to be rooted. It has also increased awareness of the project, the consultations and other engagement opportunities. This has facilitated more informed and constructive responses to the formal consultation processes Moorside Technical Group The MTG, which was established in 2015, is an overarching body bringing together representatives of technical stakeholder organisations, unions and representatives of parish councils. The group provides an opportunity for these organisations to be part of an ongoing stakeholder dialogue with NuGen and its key delivery partners. Meetings have been independently facilitated and have allowed NuGen to keep its stakeholders informed about the development of its proposals and have provided an opportunity for stakeholders to contribute towards the plans. Terms of reference and list of attendees are included in Appendix 14a. This group provided oversight on all aspects of the Moorside Project whilst detailed work and engagement takes place in more focused working arrangements Elected Members Briefings Following each meeting of the MTG, NuGen held meetings with elected representatives from throughout Cumbria to keep them briefed on the latest developments, and provide the opportunity to have their questions answered. The objective was to make sure that the same information was available to elected members as available to the technical officers in the MTG but at a less technical level. All councillors from Cumbria County Council, Copeland Borough Council and neighbouring Allerdale Borough Council, were invited to the meetings, as were members of the Lake District National Park Planning Board. Representatives of Parish and Town Councils were also invited Local Authorities, Planning Performance Agreement and Key Stakeholder Support NuGen entered into a Planning Performance Agreement with the two directly relevant s authorities, Copeland Borough Council and Cumbria County Council. Under this agreement working arrangements were set up which involved regular meeting with the authorities and groups working at different levels of seniority and detail on different topics. PAGE 76

77 15. Stage Two: Informal Engagement Processes These arrangements evolved to suit the nature of the tasks required at any given time. For most of the development period up to the Stage Two Consultation regular working group meetings included: Strategic Executive Group (Director Level); Strategic Management Group at (key practitioner and management level); and working under the guidance and management of the above, sub groups covering topics including: Transportation, Consultation; Planning and Environment; Section 106/ Legacy Benefits*. * The scope of sub group meetings has varied over time to suit the demands of the workloads at different stages in the project development process. Representatives of other relevant organisations were invited to the working meetings as necessary. The local authorities were provided with information on studies, assessments, options and draft documents as and when they were produced outside of then statutory consultation processes EIA Quarterly Groups Work on producing the Preliminary Environmental Information Report (PIER) was supported by regular engagement with 23 stakeholders at Environment Impact Assessment (EIA) Quarterly meetings and topic specific sub groups. The attendance and process was developed with the advice of the statutory stakeholders and includes quarterly meetings of the following sub groups. Noise and Air Quality Ornithology Marine Ecology Marine Coastal Physical Processes and Marine Water Quality Soils, Geology and Land Quality, Ground water and surface water Transport, Countryside Access and Recreation. Socio economics Historic Environment and Landscape Terrestrial and Fresh Water Ecology Landscape and Visual Health Impact Assessment NuGen has supported and funded the establishment of a health impact assessment work stream. This is led by an independent steering group and is chaired by the County Council s Director of Public Health. In this body NuGen engages with health-related organisations and officials to develop NuGen s health impact assessment for the Moorside Project. The group has developed a community profile and has carried out wider engagement through health workshops. NuGen provides an ongoing presence at the group and provides the secretariat. PAGE 77

78 15. Stage Two: Informal Engagement Processes Nuclear Transport Liaison Group NuGen regularly attends the Nuclear Transport Liaison Group meeting to discuss and coordinate transport related issues. Other developers that have plans impacting on the transportation system are also in attendance. It is also attended by a large number of regional and local agencies with an interest in transportation. This level and type of attendance facilitates coordination and consideration of cumulative effects. The group is independently convened and chaired by Cumbria County Council Informal Local Stakeholder Workshops Between the Stage One Consultation and Stage Two Consultation, a series of local workshops were established for each of main proposed development search areas. This included the Moorside Site, Corkickle in Whitehaven; Mirehouse in Whitehaven; Cleator Moor and Egremont. These workshops were aimed at engaging representatives very local to the search areas, to discuss the pros and cons of developing in those locations. The workshops allowed the search areas to be refined to produce specific development site proposals to be included within the Stage Two Consultation. This ensured that the defined sites took into account local issues and views about the best way to develop in that area. In addition, the workshops led to one of the search areas at Cleator Moor being removed as a development site from NuGen s emerging proposals. At the advice of Copeland Borough Council, members of the pre-existing relevant local area partnerships were used as a basis for the invitation list alongside additional representatives from parish and town councils Moorside Parishes Group NuGen meets with representatives of parish councils around the Moorside Site on a regular basis to keep them informed and up to date on progress and give them the opportunity to raise issues and ask questions. Parishes directly affected by the Moorside Site proposals are invited to these sessions including Beckermet Parish Council, Ponsonby Parish Council, Lowside Quarter Parish Council and Haile and Wilton Parish Council. In addition, the Residents Affected by Moorside action group is also invited to send representatives as they draw their membership from a similar area Sellafield / NDA Liaison Arrangements NuGen has established multi-level liaison arrangements with Sellafield and the NDA, which incorporate processes of engagement from the CEO down to the detailed working level in focused topic sub groups Schools and Community NuGen has had an active engagement with local schools providing support as well as raising awareness of the Moorside Project and potential careers in the nuclear sector. NuGen launched Bright Sparks in 2015 with three local secondary schools: Millom, St Benedict s and Whitehaven Academy. Bright Sparks is an education initiative to supplement the work of local schools in curriculum areas including climate change, social responsibility, energy efficiency and low-carbon energy production. PAGE 78

79 15. Stage Two: Informal Engagement Processes The initiative runs through an academic year, and includes visits, mentoring and tutorials, and an end-of-year schools energy conference where pupils compete against each other in series of energyrelated challenges. Bright Sparks was one of five shortlisted entries from around the world in the PIME 2017 award for Communications Excellence - and emerged on top after ratification from an expert panel of European judges, and a vote from more than 120 delegates from 22 countries. Bright Sparks also won Silver at the UK Chartered Institute of Public Relations, North-West PRide Awards in November Alongside this NuGen has also been running its Green Grants initiative, a means of supporting environmental initiatives in the local community as well as maintaining a high level of awareness of the Moorside project amongst local communities. The scheme, launched in October 2015, invited community projects close to the Moorside Site to apply for funding up to 5k to help improve and enhance the local environment resulting in long term benefits to the local communities. 17 community projects received support out of 64 applicants. NuGen won a further PRide award from the UK Chartered Institute of Public Relations in November 2016 in the Community Relations category. NuGen s GreenStem programme has built on the success of the environmental partnership with Primary Schools. The programme, delivered in partnership with Cumbria s Wildlife Trust, teaches students about the environment near them and the importance of habitats on land and in marine environments. NuGen s team has been volunteering enthusiastically on projects benefitting the community and the environment with activities including litter picking, tree planting, decorating and planting a community garden. NuGen supports the Well Whitehaven initiative; has put in place a charity partnership with Cumbria Youth Alliance, funding apprentices; sponsored local business awards, dinners, and other local business and charity events Further Education and Training Organisations NuGen engages and works with partners locally in the skills and training area. NuGen is an active member of the Cumbrian partnership, the Centre for Nuclear Excellence (CoNE), which brings together the wide range of nuclear-related organisations and people in the locality to develop a centre of specialist skills and innovation, and develop the area as place to do business. NuGen s Head of Training and Qualifications leads the CoNE skills group and also sits on the Local Enterprise Partnerships Skills Group. An ongoing dialogue is held with local skills providers such as Cumbria University, Lakes College and Gen 2. Nationally, NuGen s Head of Training and Qualifications is a Board Member of the Nuclear Sector Skills Group and the Advisory group to the National Skills Academy for Nuclear. Both these groups are charged developing the skills for the sector and supporting Cumbria s requirements NuGen is a member of Britain s Energy Coast Business Cluster where interaction with the potential local supply chain takes place. Helping the local supply chain prepare for future contract opportunities from NuGen and its business partners is a priority. PAGE 79

80 15. Stage Two: Informal Engagement Processes Local Liaison Arrangements NuGen s Moorside Information Centre at the Civic Hall in Whitehaven provides an exhibition area, meeting rooms and staff offices. There is permanent exhibition on its proposals which can be viewed by the public. The Centre is the base for NuGen s Cumbrian-based team members, including engagement personnel, who are available to provide a contact point for local stakeholders. Liaison with local authorities, including the office of Copeland s Elected Mayor takes place on a day-to day-basis. There is an ongoing schedule of meetings with county and district council committees, Lake District National Park Planning Board, parish and town councils and other representative bodies. Staff also attend public meetings when requested by others elected bodies and representatives. Engagement with tenants and landowners on, and neighbouring the Moorside Site is conducted directly and through NuGen s appointed land agent. NuGen attends and updates the National Grid s North-West Coast Connections Project stakeholder meetings Regular meetings take place with MPs and Sellafield trade unions. NuGen keeps under review the need to provide additional information and engagement opportunities to local stakeholders. PAGE 80

81 Appendices Appendix 1. Preliminary Consultation Report Appendix 2. Stage One Statement of Community Consultation 2015 a. Comments from local authorities 2015 b. Final Statement of Community Consultation 2015 c. Published SoCC Notice 2015 Appendix 3. Stage One Consultation a. Overview b. Newsletter c. Press coverage d. Advertisement e. Poster Appendix 4. Stage One: hard to reach groups List of groups and contacts Appendix 5. Stage One: statutory consultees Prescribed consultee list Appendix 6. Stage One: s48 notice a. Published notice b. Letter to statutory consultees (Regulation 11) Appendix 7. Stage One Consultation feedback a. Issues raised by statutory consultees and organisations b. Summarised issues raised by public response. Appendix 8. Stage Two Statement of Community Consultation 2016 a. Consultation Strategy b. Local authorities comments on the draft DCO Stage Two Statement of Community Consultation 2016 c. Statement of Community Consultation 2016 d, Published SoCC Notice 2016 Appendix 9. Stage Two: Statutory Consultees a. Section 42 consultee list b. Letter to statutory consultees c. Section 46 Letter PAGE 81

82 Appendices Appendix 10. Stage Two Consultation a. Proposed Scheme Overview b. Newsletter c. Advertisement d. Poster Appendix 11. Stage Two: hard to reach groups List of groups and contacts Appendix 12. Stage Two: s48 notice Published notice Appendix 13. Stage Two Consultation feedback a. Issues raised by statutory consultees and organisations b. Summarised issues raised by public response Appendix 14. Moorside Technical Group a. Membership and terms of reference b. LA Presentation on DCO Stage 1 PAGE 82

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