Response to Environment Agency Consultation on Fusion – BANNG Paper No. 51
(Prepared by Peter Banks, BANNG Co-ordinator)
BANNG is not responding to the Isles of Scilly (IoS) part of the Consultation, so the only questions addressed re Fusion are:
Question 5. Do you agree with our proposal to introduce a new specified radioactive substances activity definition (c) in section 2(1) of the Environmental Permitting Charging Scheme?
Whilst BANNG welcomes the introduction of another regulatory category to cover radioactive substances potentially used in Fusion, it is with concern that this is unspecific. BANNG also suggests that this is unknown and awaits fuller information.
Question 6: Do you agree with our assessment of the economic impact of this proposal to broaden the specified radioactive substances activity (S-RSA) definition in the Environmental Permitting Charging Scheme?
The estimate given of £100k per annum is not specified and BANNG considers a more precise budget should be given.
Please share any additional comments that you think may help us improve our current proposals or future consultations.
BANNG appreciates the regulatory framework needs to be extended to cover this emerging sector. However, there is no government decision for a National Policy Statement regarding siting of potential Fusion sites. This is despite a raft of speculative developers putting in a bid to be considered for the STEP programme for sites.
This disparate and disjointed approach confirms the lack of co-ordination of all key stakeholders, including the Environment Agency. BANNG views this with great concern, especially as Bradwell on Sea, Essex, is listed as one of the sites mentioned above.
2 September, 2021