Environment Agency Consultation on Two New Applications for permissions in relation to the Bradwell B Load Test Site
The objections below concern two applications to the Environment Agency.
These two applications have been received from Bradwell Power Generation Company Limited for a site at
Bradwell B (BRB) load test site
For the new water transfer licence application NPS/WR/033410
For the new bespoke water discharge activity (WDA) environmental
permit application EPR/RB3096
The following brief comments are submitted to explain this objection. Whilst the ultimate use of this site may be argued as not for consideration in this consultation, this objection strongly requests that, in fact, it is considered here because of the very major extent of the work and its effects which cannot be disentangled.
The works to which the applications refer are in themselves significant, and significantly greater than the previous groundworks for the same purpose – that of informing and enabling the development of a new nuclear power station, including amongst other things involving considerable civil engineering works and associated effects over a three year period.
The site concerned is presently a stretch of peaceful rural land, with considerable history. The immediately adjacent coastline is much used by local and visiting people for walks and recreation and by significant quantities of visiting birdlife. The quality of the water is essential for both local foo- related businesses as well as leisure activities, such as yachting and swimming.
The comments in this objection are to request that the granting of the licences is refused, not only because of the extent of the actual works on their own but including the ultimate use, in accordance with the aims of the Environment Agency.
The EA has been asked to provide licences for certain work. This objection suggests that to issue these particular licences does not further the aims and ambitions, purpose and priorities of the EA.
eg. website, et al:
to protect and improve the environment
eg. EA’s ambition to 2020, et al:
We improve the quality of our water, land and air by tackling pollution
Protecting people, wildlife and business is a big job, so we need to be ambitious
Our purpose, set out in the Environment Act, hasn’t changed: to protect and enhance the environment and promote sustainable development
Our vision. Create a better place for people and wildlife
Our principles. How we will make choices
• Put people and wildlife first: our goal is to create a better place for them.
• 80/20: we will focus on the 20% that makes 80% of the difference.
• Support local priorities: every place and community has its own needs.
The 25 Year Environment Plan
The Government’s 25 Year Environment Plan sets out a comprehensive long- term approach to protecting and enhancing the environment. The vision at the heart of the plan is that we will be the first generation to leave the environment in a better state than we found it. The Environment Agency will play a central role in delivering the plan. We will work to deliver all 10 of the goals it lays out:
• Clean air
• Clean and plentiful water
• Thriving plants and wildlife
• Reducing risk of harm from environmental hazards
• Using resources from nature more sustainably and efficiently
• Enhancing beauty, heritage and engagement with the natural environment
• Mitigating and adapting to climate change
• Minimising waste
Managing exposure to chemicals
• Enhancing biosecurity
eg. website, amongst others:
protect and improving water, land and biodiversity
improve the way we work as a regulator to protect people and the environment and support sustainable growth
The Purpose (which the ground investigations are to inform)
The intention is to construct a nuclear power station on this site for which the objections, which are well known to the EA, in summary include:
nuclear requirement significantly weakened
climate change, increasing awareness of
vast scale and impacts
radioactive waste storage
decommissioning and unknown waste storage and toxicity into the far future
Extent of the Works
The works to which the WTL and WDA refer are not small, in fact, they are of considerable size physically and in the work required, eg:
Site area 10 hectares
Considerable civil engineering works
Working hours all week plus alternate weekends
The load test pit alone is 200,000 or 350,000 cubic metres in the discrepant documents
Excavating down to -7.00m AOD; consequential work above eg of arisings; later reinstating
Work duration 3 + years, of which:
The first 7 months
The last 6 months
are the more intensive construction works
Piling and banging and so on in between
Monitoring and constant pumping and attendances throughout the interim
Many HGV journeys in varying amounts over 3+ years.
These investigations are considerably more intrusive than the initial groundworks already carried out. We would argue that further more substantial work on this site is unnecessary at this stage. It is particularly unreasonable for these works to be carried out now when the case for the new station is far from certain, and the approval process for that station still in its very early stages.
The case for the new station has been undermined in recent years by
> a decrease in UK energy consumption
> the increase in alternative renewable energy supplies
> the strike price for comparable stations now being uneconomic
> increasing government concerns for national security of UK infrastructure
Issues, in addition to the objection of the ultimate purpose proposed for the site, which singularly or collectively this objection feels may be reason to not grant the licences applied for:
Noise (transmits over water especially in calm weather)
Air pollution – numerous diesel engines, including constant running of pumps
Light pollution (an incongruous eg of specifics that cannot be considered in the WDA), possibly but not understood from information provided, visible from eg Mersea
Local issues, protected areas, wildlife, etc.
CO2 emissions – large work over a prolonged period
Risk of contamination from existing nuclear site water
3 year period of disturbance to environment and local communities
The brief comments in this objection are to request that the granting of the licences is refused, not only because of the extent of the actual works on their own but including the ultimate use, which is construction of a wasteful and very expensive, unnecessary power plant, high in carbon production during the one to two decades of construction, and which will allow toxic waste and storage to accumulate.
The aims of the Environment Agency appear to not be furthered by granting the licences.
We believe these applications would be contrary to the Environment Agency’s stated aims and cannot be justified. The ensuing environmental harm may prove to have been unnecessary if the ultimate aim of a new nuclear power station does not get approval.
We must also object to the ground investigations and water permits on the grounds that these extensive 3 year works will cause unacceptable damage to the environmentally protected areas and protected species.
We further object on the grounds that the investigations and water permits are clearly a speculative step towards the construction of a new nuclear power station and waste storage complex. This cannot somehow be considered as an independent purposeless exercise without the ultimate approval also being included for consideration – they are intrinsically entwined. The generic design process for the new nuclear power station cannot be presumed. Similarly the Bradwell site approval for nuclear development expires in 2025, well before BRB’s nuclear power station could be completed; a further 12 – 15 years approval would be needed.
Conditions from climate risk into the 22nd century include increased flooding risk, sea level rise – the future threat level is unknowable especially with the need for long-term on-site spent fuel storage. By contrast less expensive and less hazardous renewables are increasingly available with far shorter construction times. There will be new site designations reflecting the changed situation and circumstances and it cannot be presumed that the Bradwell site will be redesignated as suitable after 2025.
We also object on the grounds that the applications are presumptive and premature until these essential approvals are first obtained. The urgency originally claimed for new nuclear 10 years ago has been proven false so a few more years delay in permitting these disruptive investigations is a small sacrifice to avoid unnecessary damage to the protected areas and environment – in accordance with the EA’s principles.
We also urge the EA to defer its decisions on the applications until BRB has been granted design approval for the Hualong 1 reactor and also the Bradwell site has been granted approval for nuclear development after 2025.
Prepared by Roger Mullis and Barry Turner
On behalf of the Blackwater Against New Nuclear Group (BANNG)
June 15, 2020