Environment Agency (EA) Policy Paper
Generic Design Assessment (GDA) of the UK HPR1000: consultation plan
Comments from the Blackwater Against New Nuclear Group (BANNG)
(BANNG Paper No. 47)
BANNG welcomes the forthcoming consultation on the GDA of the UK HPR1000. The plan details the EA’s intention to consult widely and to engage with stakeholders and the general public. As a leading NGO concerned with the proposed deployment of the UK HPR1000 at Bradwell-on-Sea Essex, BANNG wishes to engage with the EA. In particular we wish to engage through a specific EA/BANNG liaison meeting.
This should be similar to, but not a substitute for, our regular ONR/EA engagement meetings. We also have some observations to make on the consultation plan.
Purpose of the consultation
The process of consultation is set out in detail, including methods of consultation, the range of organisations to be consulted and the way responses will be handled. But, very little is conveyed on what the consultation will be about, what is its purpose and the substance of its concern. The EA provided a very detailed, informed and challenging response to BRB’s Stage I Pre-Application consultation. It was highly critical of the inadequate information, evidence and detail provided by BRB. The EA’s response covered a myriad of issues from the impacts of climate change to the need for appropriate standards and safeguards and measures to protect and enhance the environment.
It would be helpful to have a statement on the relationship between the EA’s response to the BRB consultation and its consultation on the GDA. It would be helpful to have a clear appreciation of the issues that will be covered and the EA’s view on the adequacy of BRB’s proposals. It would also be helpful for the consultation to provide a clear statement of purpose and its views on the proposals. This would establish the context for public responses and might also indicate those areas where views would be especially helpful and welcome.
Generic or Site Specific
It would be helpful if the status of the consultation with respect to the Bradwell site could be established. As a generic assessment presumably the power station development would be applied to a ‘generic’ site. And yet, the consultation is aimed at the public and stakeholders near the Bradwell site. It would be helpful to know if the generic site has the parameters of a specific site, notably an estuarial location quite similar to Bradwell. Perhaps the mystical distinction between specific and generic has been sufficiently elided so that the site under consideration in the consultation is, to all intents and purposes, Bradwell. Clarification of the point will be necessary and helpful to avoid confusion among respondents. Perhaps you could clarify how the public are expected to respond to a consultation on a generic site when most respondents will obviously respond specifically on Bradwell. How will the EA take these views into account?
It is anticipated that the EA consultation will cover the range of issues identified in the NPS EN-6 (2010). These include impacts on habitats, heritage, marine environment and related societal implications. However, there are some major intergenerational issues that have become more significant since the NPS was published almost a decade ago. In particular, climate change has become a transformative issue affecting energy and environmental policy. For coastal sites, especially Bradwell, the longer term implications of climate change on site viability are of fundamental concern. It is anticipated that the EA consultation will present forecasts and models of sea level rise, storm surge and coastal process impacts at the Bradwell site and the potential risk to the power station complex. This applies especially to the spent fuel store which will remain at the site until well into the next century on current projections for long-term management of radioactive wastes. It will be helpful to have the EA’s view on the long-term risk and the viability of mitigation measures in the unknowable circumstances of the far future.
The Bradwell proposal is massive in scale and would undoubtedly transform the rural environment into an industrial and urbanised complex affecting economy and wellbeing. You may be aware that in its response to the BRB Stage 1 consultation BANNG has called for a Social Impact Assessment to be undertaken while Colchester Borough Council has requested a Health Impact Assessment in addition to this. We assume the EA will make comments on the impacts of the project as a whole and the extent to which environmental harm will be comprehensive and irreversible.
Participation in the Process
As indicated above, BANNG is keen to participate in the consultation. We shall welcome the full documentation that sets out your conclusions. We shall be interested in your statement of what you do and, more especially, what you do not do. Our experience has been that the EA presents convincing evidence and conclusions but is less assertive in ensuring adequate implementation. We hope that, on this occasion, participation in the exercise will be purposeful and effective. And we shall welcome a clear indication of where our responses have been taken into account and impact on outcomes.
In terms of specific input, BANNG will: attend relevant online events; visit drop-in events; hold a conference (remotely) to hear the EA’s views; and attend an EA/BANNG engagement meeting (possibly with others to be determined).
We look forward to participating fully in your consultation on the GDA for UK HPR1000.
Professor Andrew Blowers, OBE
Chair of BANNG, on behalf of BANNG 31 December 2020