CONSULTATION ON THE STRATEGIC SITING ASSESSMENT PROCESS AND SITING CRITERIA
FOR NEW NUCLEAR POWER STATIONS IN THE UK
RESPONSE TO THE CONSULTATION ON BEHALF OF THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)
A PRELIMINARY OBSERVATIONS
Blackwater Against New Nuclear Group (BANNG)
This submission is presented on behalf of the Blackwater Against New Nuclear Group (BANNG), a citizens’ based organisation (CBO) formed to oppose any proposal to develop a new nuclear power station on land neighbouring the former Bradwell Magnox NPS. The Aims and Purpose of BANNG are set out in Appendix A to this response. The supporters of BANNG take a variety of perspectives on the nuclear issue. BANNG was formed in April 2008 and is mainly based in West Mersea although its membership is being extended to other communities surrounding the Blackwater estuary. This consultation response has been circulated to the membership of BANNG and has been discussed and approved by its Core Group. It may be said, therefore, to represent the views of the organisation.
Concerns about the SSA Consultation
We are particularly concerned about the inadequacy and partial nature of the SSA consultation. We have six concerns.
Our first and most important concern is that the siting process is inadequate, flawed and unfair. In many respects it is a reversion to the discredited ‘Decide Announce Defend’(DAD) approach where sites are identified and nuclear facilities imposed on communities. The justification for existing sites rests on three criteria (none of which is firmly included in the SSA proposed list). These are: sites available in friendly ownership; available facilities and infrastructure; public acceptability among the local communities. A condition imposed on a ‘Credible Nuclear Power Operator’ (CNPO) is that they must demonstrate they ‘have taken steps to engage local communities living in the vicinity of the nominated site..’ (p.9). It is not sufficient merely to provide publicity, hold meetings and invite views. Engagement involves open deliberation and participation in the decision making process.
Second, although this consultation focuses on strategic siting criteria, it is a matter of local concern. These are general criteria to be applied in specific contexts. However, the identification and specification of criteria needs to be informed by local as well as generic factors. There is little evidence that effort was made to draw on local perspectives in drafting the criteria. We believe the government should engage with a wide range of local communities and stakeholders.in its further development of the draft criteria.
However, and this is our third point, it seems that very little effort has been made to promote this consultation and no effort at all to involve local citizens and communities in the process. It appears that the significance of this consultation has not been drawn to the attention of local authorities and parish and town councils in potentially affected areas. For example, we were disappointed to learn that Colchester Borough Council had been unaware of the consultation and West Mersea Town Council, representing the population of a town within two miles of the Bradwell site, had not considered responding to the consultation. On an issue as important as this, it would seem neglectful at best on the part of government not actively to encourage communities in potentially affected areas to respond.
Our fourth concern is that the criteria appear to have been drawn up with specific sites in mind. Indeed, this should be no surprise when the nuclear White Paper states as follows: ‘We expect that applications for building new power stations will focus on areas in the vicinity of existing nuclear facilities. Industry has indicated that these are the most viable sites’ (BERR, January 2008, para. 78). The draft criteria suggest that none of these existing sites will be automatically ruled out. This implication was confirmed by a spokesperson for British Energy who stated there are no criteria which, applied to Bradwell, would eliminate it as a potential site. There are only four exclusionary criteria and they are set at levels that are highly unlikely to exclude any existing site. On the other hand, criteria that might exclude such sites, notably flooding or tsunamis, storm damage and coastal processes are in the discretionary category and, in any case, framed in such a way that, even if they were exclusionary, it is unlikely that any existing site would be ruled out.
A fifth point is the absence of criteria that, perhaps, should have been included. One criterion that might have been included is location in relation to demand. It may be argued that sites in remote locations require long-distance transmission and consequent loss of electricity in transmission and of heat that might be utilised in Combined Heat and Power (CHP) systems. A criterion on health effects would also seem a candidate for inclusion. Another additional criterion should be on socio-economic impacts which should evaluate overall disbenefits as well as benefits and impacts on well-being in the sub-region surrounding a proposed site.
It might also be expected that public acceptability should be a criterion. The idea that those living near nuclear facilities are familiar with them and appreciate the economic benefits flowing from the investment is contentious to say the least. It may equally be argued that greater knowledge increases anxiety and resistance to nuclear facilities. Although there is considerable research on issues of public awareness and perspectives, questions of methodology, representativeness and interpretation make it difficult to draw any conclusions.
Our sixth and final concern is the need for independent consultation and research. We wish to stress that many aspects of siting strategy related to criteria are under-researched. This is true both for generic as well as site-specific aspects. A further problem is that some aspects of consultation, for example, engagement with local communities, are the responsibility of site operators. We do not consider it appropriate for research or public consultation to be commissioned or undertaken by CNPOs. In order to achieve public trust and the credibility of process it is important that research and consultation is seen to be distanced from any vested interest and that it is independent, peer reviewed, credible and robust.
We conclude that this consultation is deeply flawed and represents a means of seeking to legitimate siting decisions already taken in principle and being applied in practice through the selling of British Energy and Nuclear Decommissioning Authority (NDA) sites and the Government’s efforts to facilitate the development of new power stations on existing nuclear sites. This is an inequitable approach, in effect imposing risk, now and in the future, on communities who already bear the risk from the previous generations of nuclear activities.
We propose that, if the government proceeds with the development of new nuclear power, it adopts an equitable siting strategy based on the principles recommended by the Committee on Radioactive Waste Management (CoRWM) and endorsed by government (CoRWM, 2006, 2007; Defra, 2008)).
New power stations will also be, in effect, long term spent fuel and radioactive waste management stores. They are likely to be present on sites for at least a hundred years and could remain there longer depending on whether and when a national repository becomes operational. In its proposals for implementation CoRWM suggested that in order to inspire public confidence its recommendations for legacy wastes could be applied to central or regional waste stores (CoRWM?, 2007, p.10). Given that new nuclear stations will also be waste management facilities, it seems logical that the voluntary approach to siting should be applied to finding sites.
Our response to the consultation is to urge a fair and voluntary siting strategy which is based on open, deliberative engagement enabling local communities to be involved and to participate in the decision making process.
B RESPONSE TO THE SPECIFIC QUESTIONS IN THE CONSULTATION PAPER
The six concerns in Section B above underlie our response to the specific questions in the consultation paper which we address below.
Do you agree that, at this time, the SSA should focus only on sites that are nominated as being suitable candidates for deploying new nuclear power stations by the end of 2025? If not, why not?
We do not agree for the reasons outlined in our Preliminary Observations. The government is urging vigorous action to achieve new nuclear power stations. Consequently, it is highly likely that nominated sites will be at the location of existing nuclear facilities. Our reasons for not agreeing with the proposition may be summarised as follows:
The siting process should be fair and apply the principles of intra-generational equity. This principle requires that actions should not impose an unfair or undue burden on individuals or groups within the current generation. Communities living near existing sites already bear or have experienced a burden of risk and it would be unfair to impose further risk upon them. An equitable approach should consider a wide range of possibilities and engage with the public in a voluntary siting process. Efforts must be made to understand attitudes to the prospect of new nuclear power in local communities. A new power station should not be imposed on an unwilling community.
The sites most likely to be nominated are located on the coast or estuaries in southern England. These are all in areas liable to erosion or inundation especially as climate change affects sea levels and storm surges are liable to become more frequent. Any proposals to site new power stations in such vulnerable locations should be rejected.
An equitable siting process involving local communities is likely to take longer. Even the accelerated and centralised process proposed by the government is unlikely to yield any operational power stations before 2020. The problems with the energy gap are likely to emerge well before then. Nuclear’s contribution to future energy needs and carbon reduction is likely to be small and, therefore, it makes sense to deploy resources into those areas likely to make the greatest contribution, namely energy efficiency and renewables.
This point is reinforced by concerns about intergenerational equity, the principle of fairness over time, that the present generation should not impose unfair or undue burdens on future generations. The new power stations are likely to operate for up to sixty years and decommissioning may well take several decades longer. It is unlikely that sites will be cleared before 100 years from the start of operations. This time-scale stretches into future generations imposing burdens of risk, effort and cost that should be avoided if at all possible.
Do you agree that the overall SSA process provides an appropriate mechanism for identifying and assessing those sites which are strategically suitable for the deployment of new nuclear power stations by the end of 2025? If not, how should the process be changed?
We do not agree that the process is appropriate. We consider it to be centralised, accelerated and unfair for the reasons outlined in our Preliminary Observations.
The process appears to be designed to give the greatest possible advantage to the nuclear industry to deliver new nuclear power stations at existing sites as fast as possible. We would make the following observations:
The SSA process does not take fully into account the need to consider the interests of affected communities nor to involve them in an adequate process of decision making.
It is not clear how it is intended to take social and ethical concerns into account. There appears to be no provision for discussions of public perceptions and attitudes at the local level. There has been little or no engagement of local communities or even of local authorities in the process. There appears to have been little or no input into the development of criteria from local communities, environmental NGOs or other interested groups at local level. This is made clear in the list of those whose views were taken account of as listed on pp. 37 – 40 of the consultation document.
By contrast, nuclear interests enjoy privileged access to government and it is likely they have, directly or indirectly, assisted in the development of criteria. It would be interesting to have government’s confirmation of this. Certainly, the criteria have drawn heavily on the work of professional technical consultants, notably the report by Jackson Consulting (UK) on Siting New Nuclear Power Stations: availability and options for government (2006). We would urge the Government to reveal the provenance of the criteria that are put forward in this consultation and to indicate why the process of criteria selection and development was not open for a wider debate. Consultation once the criteria have been identified places those excluded from the process at a disadvantage and greatly assists the adoption of the criteria.
We consider the absence of any ethical criteria a serious defect in the SSA process. In particular consideration of the potential impacts on future generations from the operation of power stations and the storage of wastes should be considered as strategic issues and applied to specific sites.
Do you have any other comments on the practicalities of the proposed SSA process, such as the timetable for nominations and the duration of the nomination period?
We have offered our views on the inadequacy and unfairness of the process in our comments above and have emphasised its lack of engagement with local communities and interests. As to timing, we consider the process far too accelerated from the point of effective local engagement. During Stage 1 the public are being consulted on draft criteria; they have not been invited to contribute to the drafting process itself. According to Table 1 on p.11, Stage 2 is confined to interaction between the CNPO and the government. While the CNPO must demonstrate they have taken steps to engage local communities, the form this engagement takes need be little more than informing and publicising their intentions. During Stage 3 there will be public consultation on a draft list of sites as part of a consultation on the draft Nuclear Policy Statement (NPS). Again, there is unlikely to be any public or local community input into the drafting process; rather comment will be sought on the drafts themselves. Local communities will be confronted with nominated sites on which they have not previously commented. Once again, this reduces the level of local and community involvement. It may be seen as a means of pre-empting opposition.
The consultation document states that ‘The Government is committed to ensuring transparency and openness throughout this process’ (p.15). We make two comments here. One is that openness and transparency implies that the public are fully informed of proposals and decisions being made in respect of the development of nuclear sites. There is little evidence that this is being achieved, at least in the case of the Bradwell site. The other comment is that openness, while welcome, needs to be combined with a commitment to ensuring proper engagement and participation. It is not enough simply to inform the public; the public need to be able to act on information they are given.
Finally, effort should be made to reach the widest possible audience. Local authorities and subordinate elected councils, relevant NGOs and CBOs in affected areas should be urged to respond. It should not be assumed that site stakeholder groups constitute the only appropriate local vehicle for response. It may be argued that such groups are too close to the nuclear industry. In any case their remit may not extend to new nuclear power. For instance, the Bradwell LCLC’s remit is confined to the decommissioning of the site. By making CNPOs responsible for local community engagement during Stage 2 the government runs the risk of the process being perceived as partisan and thereby discredited. In order to generate an effective and representative response from local communities there must be an effort on the part of government to ensure a disinterested engagement based on deliberation within local communities. This engagement should utilise independent researchers and facilitators.
Do you agree that the proposed exclusionary and discretionary criteria are appropriate for the assessment of a site’s suitability at a strategic level? If not, how should the criteria be changed to achieve this objective and, specifically, are there any additional criteria that should also be used? Should the classifications of any of the exclusionary criteria, discretionary criteria, or issues for local consideration be changed?
We consider the criteria cover a wide range of the issues relating to siting new nuclear power stations. However, we have three major reservations about the criteria as they stand. These relate to,
Classification. We do not think the classification of the criteria is appropriate in all cases.
Definition. The definitions of some criteria are too broad while others are too narrow.
Application. We consider there are other criteria, notably social and ethical criteria, that should be applied in a strategic siting assessment.
These reservations will be illustrated in the comments on individual criteria which follow.
Criterion 1.1 Seismic risk (exclusionary)
It will be noted that the Bradwell site is close to the epicentre of the biggest earthquake experienced in recent history on mainland UK. This was the so-called Colchester earthquake in 1884 which registered an estimated 4.7 on the Richter scale and caused considerable damage over a wide area. However, this appears to be well within the limits proposed by the criterion. Para. 2.27 states that ‘we do not expect that any areas of the UK will be excluded from consideration at a strategic level on the basis of this exclusionary criterion’. That being so the introduction of the criterion would seem gratuitous. As it stands the criterion of a 1 in 10,000 year risk of incurring greater than 0.25g ground acceleration will prove difficult to comprehend and is unlikely to prove reassuring to communities living near Bradwell. The perception of seismic risk is important and must be taken into account at the local level.
Criterion 1.2 Capable Faulting (exclusionary)
We have no comment on this criterion beyond asking why it has been included if it is unlikely that it would exclude any area in the UK
Criterion 1.3 Non-seismic ground conditions (local)
Criterion 1.4 Flooding (discretionary)
We are most concerned about this criterion. First, we consider this criterion should be exclusionary and redefined. Where a site is liable to be inundated within the period that the power station is operating or being decommissioned then, in our view, it must be excluded. The time-scale should extend well over a hundred years. We estimate the possibilities as follows. A new power station may operate for up to sixty years. Following operation large volumes and radioactivity of stored spent fuel will be moved to a national repository; this process could take at least ten years. The full decommissioning process is likely to last well beyond operation, perhaps up to a hundred years, if experience of existing power stations like Bradwell is anything to go by. So, a most optimistic time-scale suggests a period from operation in say, 2020 to final clearance in the latter half of the 22nd century, around year 2180.
It is conceivable that this time-scale will not be met. Operation may begin later than 2020, there may be long delays or bottlenecks at the repository and it may not even materialise. There may be further (daughter) power stations developed at some sites thereby lengthening the time-scales still further. It is, perhaps, realistic to conclude that these sites will remain as nuclear waste stores and decommissioning facilities for the indefinite future. That being so it would be folly to commit to building new power stations at locations where the probability of flooding and inundation increases over time and, in many cases, becomes a serious risk beyond a hundred years.
The criterion requires that developers ‘confirm that they can protect the site against flood-risk throughout the lifetime of the site’ as well as ‘take into account the wider impacts of their flood protection countermeasures on areas surrounding potential power station sites’. Predictions of sea level rise resulting from climate change and consequential storm surges will make low-lying coastal sites increasingly vulnerable. In the case of Bradwell, Nirex (2005) reported that over 100 years plus, inundation will become progressively more common, especially from storm surge. Another report indicated that Bradwell was vulnerable to subsidence, rising sea level and rollover of the Blackwater estuary (Thorne and Associates, 2005). The Environment Agency’s Flood Map indicates the area subject to inundation . The evidence strongly suggests that Bradwell is highly vulnerable to flooding especially beyond 100 years but within the period when the site will still be operational for the purposes of waste management. Other sites in coastal areas may well be similarly vulnerable to flooding.
We conclude that the flooding criterion is inadequate as it stands. There can be no case for developing sites which are subject to flooding. We suggest there should be an exclusionary criterion that excludes sites which are vulnerable to inundation. It should also be made clear that it is unacceptable that flood countermeasures should have deleterious impacts on surrounding areas.
Criterion 1.5 Tsunami, storm surge and coastal processes (discretionary)
Our concerns here are similar to those for criterion 1.4. A Meteorological Office survey quoted in Appendix C, p.153 of the consultation documents concludes that ‘the main risk to the coastal sites would be from storm surges that are caused by low atmospheric pressure and strong winds and can be further exacerbated by the funnelling effect created at estuaries and river mouths’. It will be noted that the East Coast experienced a very severe storm surge combined with high tides on the night of 31 Jan/1 Feb. 1953 (Grieve, 1959). This caused great damage, extensive flooding and considerable loss of life. The possibility of such damaging storm surges increases with climate change and sea level rise and coastal nuclear power stations and surrounding areas are clearly vulnerable. A survey of potential storm surge and sea level rise under different climate change scenarios undertaken for Greenpeace (Flood Hazard Research Centre, 2007) and also cited in Appendix C indicated that, under certain scenarios, Dungeness would be at risk of flooding by 2080 and Bradwell and Hinkley Point would be at risk in the short- and long-term. Research has also indicated that Sizewell is on a coast subject to rapid erosion which would increase with higher sea levels and more frequent and powerful storm surges. The east coast of England, and notably East Anglia, is an area threatened by potentially severe inundation as a result of coastal processes arising from storm surges and sea level rise. Several stretches of the East Coast demonstrate the vulnerability and impermanence of what might once have seemed impregnable, hard sea defences. Necessary mitigation to protect nuclear power stations on coastal sites may well have serious, if not devastating, consequences for surrounding areas. More detailed, independent research on individual sites will be necessary to determine the possible outcomes under worst case scenarios of climate change. Meanwhile, we urge that the most recent forecasts and future scenarios of sea level rise and coastal change are used in any publicity materials issued by or on behalf of the proponents of new power stations on existing coastal sites.
We conclude that criterion 1.5 is inadequate and that the threat to coastlines in and around potential NPS sites requires an exclusionary criterion. The criterion needs to recognise the increasing probability of inundation at vulnerable sites and the length of time decommissioning and clean up is likely to take. While it is likely (see above) that nuclear activity will remain on sites beyond 100 years, the chances of inundation increase considerably beyond that period. Therefore, the exclusionary criterion should seek to rule out development of a nuclear power plant in circumstances where maximum predicted sea level rise within, say, the next 300 years, combined with storm surges would cause inundation to the plant and surrounding areas.
Criterion 1.6 Meteorological Conditions (local)
Criterion 1.7 Proximity to hazardous industrial facilities and operations (discretionary)
We note that the planning advice on development near hazardous installations (PADHI) does not apply to nuclear installations. Nuclear activities are, of course, subject to their own regulatory procedures. The consultation document is silent on whether existing nuclear activities – operating plants or plants being decommissioned – are regarded as hazardous facilities and operations. Intuitively they would appear to be so. The fact that daughter stations have been built on sites with operating stations (e.g. Sizewell) should not be regarded as a precedent. If existing facilities are regarded as hazardous then new power stations at existing sites might be automatically ruled out.
We consider further guidance is needed on this criterion and, in particular, a determination as to whether nuclear activities are, in principle, hazardous industrial facilities.
Criterion 1.8 Proximity to civil aircraft movements (discretionary)
This criterion is vaguely defined. The potential dangers from aircraft attacking nuclear facilities have been well publicised and are matters of public anxiety. While we regard the danger as low probability, the consequences could be very high. We consider this criterion should be discretionary but we would advocate a clearer expression of the circumstances in which it might be applied. By way of illustration, Bradwell is under flight paths to London airports and within the proposed stacking area for London City Airport. Aircraft are frequently routed via the Clacton Beacon on a flight path which goes straight up the Blackwater estuary. In such circumstances it might be imprudent to develop a dangerous facility such as a nuclear power station in such proximity to extremely busy flight paths.
Criterion 1.9 Proximity to mining, drilling and other underground activities (local)
Criterion 1.10 Demographics (exclusionary)
We find the demographics criterion confusing. On the one hand, there is the intention to locate nuclear power stations in places where the radiological consequences of a serious nuclear accident would be limited (Remote Siting criterion). On the other, it is claimed that modern designs are proven to be sufficiently safe to enable relaxation of the criterion ‘such that a precautionary policy does not need to be applied for future siting of international modern designs’ (p.58). Consequently, it is considered prudent to apply ‘semi-urban’ demographic criteria. It should be noted, in passing, that the high burn-up used in the prospective designs creates potential safety issues according to some observers (Richards, 2008). However, that is a matter for the regulators undertaking the Generic Design Assessment (GDA).
The confusion arises because it appears that, with the adoption of a semi-urban criterion, remoteness is no longer necessary (i.e. distance from large population concentrations) but it is unclear why urban criteria would be unacceptable. It seems to us that either nuclear power stations are regarded as a potential threat to local populations and, therefore, should be in remote places, or they are no longer deemed to be so threatening and, therefore, may be sited close to populations where the demand for electricity is strong. The semi-urban criterion may be a compromise but does not seem to make any sense.
The table of weighted population provided on p.57 simply adds to the confusion. This appears to be a case of drafting a criterion to fit the circumstances of existing locations, a point we made in our Preliminary Observations. It is evident that the populations are sufficiently large so that no existing sites would be ruled out. Conversely, some areas, notably those close to large populations would not be ruled in. It would be interesting to see these criteria applied cartographically.
It is unclear how the distances, weighting factors and cumulative weighted population criteria in Table 1 have been derived. Why, in particular, have distances of 0-2 km., 2-3 km etc. been applied? How are they related to the putative impacts of a major accident? It is not clear that the risk reduces evenly in relation to distance from the plant or that it disappears beyond a distance of 8 km. It is noted that the weighted population criteria relate only to Magnox and AGR. We should not assume that they can apply to the new designs which may, as indicated above, carry higher safety risks. The regulators will need to provide data that relate to the designs being appraised in the GDA process.
Let us put the demographics into the empirical context of Bradwell. Although the population immediately surrounding the plant is small, within 4km. and downwind of Bradwell there is the substantial town of West Mersea (8000 and doubling in summer) and within the 8km. zone are other substantial settlements at Brightlingsea and Tollesbury and a number of villages. Not far beyond this zone is the large town of Colchester (over 100,000) and other towns such as Clacton-on-Sea and Maldon. Moreover, this is an area of rapid population growth.
We consider the demographic criteria are unclear. If remoteness is considered desirable, then a semi-urban demographic criterion is unacceptable. If remoteness is not required then the demographic criterion should be permissive and not exclude locations close to urban populations. In the case of Bradwell ‘remote’ siting would rule out a new station on grounds of its proximity to substantial populations.
We suggest the demographic criterion be revised to apply to new reactor designs. There should be clarity as to whether remoteness is a necessary condition and, if so, what level of population would be tolerable within 8km of the site. Further population growth should be avoided within this zone. If remoteness is not regarded as necessary then the demographic criterion should permit development close to urban populations. We consider the compromise expressed in the draft exclusionary criterion to be confusing, unclear and unacceptable.
Criterion 1.11 Emergency planning (local)
We fully support the Government’s view that nominators should give ‘a high-level description of the practicality of developing appropriate emergency planning arrangements at any site that they nominate for the SSA’. We are surprised and very concerned at the lack of information or knowledge of emergency planning procedures in the areas surrounding existing nuclear stations.
We recognise that emergency planning procedures must be applied in detail to each site but we also feel some general points should be made as part of the SSA. In particular we are concerned that the public living in proximity to nuclear power stations be given appropriate information about emergency planning procedures that are in place. They should understand what warnings will be given, what precautions should be taken and what actions they should take in the event of an emergency. In particular it should be made clear how evacuation should proceed. For example, what procedures will be in place to provide warning and directions for evacuation of Mersea Island in the event the only access road is flooded at high tide?
We consider there should be a general criterion that makes explicit a requirement that appropriate and practicable procedures can be put in place and that the affected public will be fully informed and understand what actions they should take in the event of an emergency. It should be emphasised that operators must be open, timely and precise in providing warnings and taking necessary actions.
Criterion 1.12 Proximity to military activities – exclusionary and discretionary criteria
We support a criterion on proximity to military activities. We consider that the term ‘proximity’ may require tighter definition in some cases. We note the point concerning military ranges and training areas listed in Table 8 and would observe that Fingringhoe Ranges near Colchester and the Foulness bombing range in south Essex are within 10 – 15km. of the Bradwell site. It would be helpful to have an indication what distances from a nuclear power station would be considered acceptable as exclusionary and as discretionary.
Criterion 2.1 Internationally designated sites of ecological importance (discretionary)
Criterion 2.2 Nationally designated sites of ecological importance (discretionary)
We take these two criteria together as our comments are relevant to both. It may be argued that a precedent has already been set through the location of existing nuclear power stations in or close to designated areas. We support criteria designed to minimise impacts and to provide countermeasures. However, we would go further and suggest there should be a presumption against siting new nuclear power stations within or close to designated areas. Many of the designations have been introduced since the earlier stations were built. Over the past few decades environmental conservation has achieved much higher priority and the protection of natural resources, habitats and coastal areas has become especially significant.
Nuclear power stations may pose risks to species and to marine habitats. Much of the Blackwater estuary is under national or international designation and there are concerns about potential impacts on the fishing and oyster industries and the risks should be clearly identified and quantified through independent research. The presence of a new station would increase the risks especially with spent fuel remaining on site.
We conclude that new nuclear power stations should not be built in or close to designated sites of ecological importance.
Criterion 3.1 Areas of amenity, cultural heritage and landscape value (discretionary)
Nuclear power stations impose a considerable presence in an area and may adversely impact on landscape, tranquillity and cultural heritage. On existing sites, no matter how much mitigation of impact is achieved, new reactor buildings and waste stores will be added to existing operations. It is highly unlikely they will improve the scene; rather they will increase the visible scale and operational activity (transport, noise, emissions, light pollution). In the case of Bradwell a new power station would stand beside the hulk of the previous one creating a substantial industrial complex in a rural area on an estuary used for fishing, sailing and passive recreation. The complex would be close to the 7th century St. Peter’s Chapel, one of the oldest and most important Christian buildings in the country. A survey by Ipsos-Mori found that the population in the area overwhelmingly favoured returning the site to its natural state.
We consider there should be a presumption against development which would adversely affect the existing land and water uses and cultural heritage of the surrounding area.
Criterion 3.2 Significant infrastructure resources (local)
Criterion 4.1 Size of site to accommodate construction, operation and decommissioning (discretionary)
The new nuclear plant will be accompanied by spent fuel and other waste stores. A recent report has suggested that the new designs with their higher fuel burn-up produce lower waste volumes but these are hotter requiring longer cooling times and more storage space and shielding (Richards, 2008). Consequently, waste will spend longer on site and present a large footprint. The size of site required for a 1.6MW reactor should be determined and be included in the criterion as a site constraint on the development of new build.
Criterion 4.2 Access to suitable sources of cooling (discretionary)
A major reason for coastal locations is the need for cooling water. Capacity may, however, be limited. For instance at the Bradwell site Jackson Consulting reported, ‘Limited cooling water availability for twin reactor because of environmental sensitivity and limits on abstraction capacity’. The impact of increased temperatures caused by cooling water discharges on marine life may also be an issue especially in shallow estuarial locations such as the Blackwater. There is a potential conflict between a new nuclear power station and the fishing and oyster industries. Alternative methods of cooling such as cooling towers would be excessively obtrusive in coastal locations and could be ruled out by criteria 3.1 and 4.1.
In our view developers must demonstrate that there is sufficient cooling water for the scale of operation proposed and that abstraction will not have deleterious impacts on marine ecosystems. This should be an exclusionary criterion.
Criterion 4.3 Access to transmission infrastructure (local)
Transmission infrastructure and wayleaves are key considerations and their availability is a major reason for identifying existing sites. In many cases, for example Bradwell, upgrading will be necessary. We have no comment beyond noting that high level transmission lines will impose considerable amenity damage over large areas.
ADDITIONAL CRITERIA THAT SHOULD ALSO BE USED
Additional criteria are suggested related to operational requirements and to societal issues. In the case of operational requirements we suggest a criterion on proximity to demand. We consider that the strategic siting assessment relating to societal issues should cover three further criteria. These concern: human health; socio-economic impacts and public acceptability. We have not suggested classification for these additional criteria and are content to leave this as a matter for further discussion. We set out our suggestions for additional criteria below.
Additional Criterion 1: Proximity to Demand
It will be evident from our earlier comments on demographics that we observe the criterion of remoteness has been relaxed to the point where proximity to substantial population is acceptable. That being so, proximity to centres of demand will be an important consideration. It will save the costs of long-distance transmission, it will reduce the loss of energy incurred and it will also offer opportunities for using surplus heat in CHP systems.
We suggest there should be a criterion on proximity to demand which can be evaluated in relation to other criteria in an overall siting assessment.
Additional criterion 2: Health Effects
We recognise that impacts on human health are implicit in a number of the SSA criteria especially those related to nuclear safety. The safety of the operations will, of course, be a matter for the regulators. However, we note that the SEA objectives 6 and 7 seek to avoid adverse impacts on physical and mental health. We consider there should also be an SSA criterion directly relating to health. It should be phrased in terms of operators demonstrating through independent research that any new power station development will not be significantly detrimental to the mental or physical health of people living in the vicinity during the whole period of operations and subsequent clean-up. Such a criterion may have differential implications depending on the place and time to which it is applied. For instance, changing coastlines may increase the risks from operations or waste storage over time.
Additional Criterion 3: Socio-economic impacts
There are several SEA objectives that relate to socio-economic impacts. These are:
4. To create employment opportunities
5. To encourage the development of sustainable communities
10. To avoid adverse impacts on property and land values and to avoid planning blight
11. To avoid the loss of access and recreational opportunities, their quality and use convenience.
However, these important societal issues do not seem to be covered by the SSA criteria. In our view there should be a criterion or criteria covering impacts on the local economy, land values and aspects of quality of life.
On the local economy, it will be important to demonstrate the long-term employment opportunities arising from new nuclear. But it is also necessary to assess the possibly detrimental economic impacts of such a development in terms of incompatibility with existing activities or deterrence of inward investment. It must be recognised that nuclear power carries negative perceptions and connotations which may impact on other parts of the local economy. For example, in the Bradwell case, a new station with its operations, radioactive waste stores and emissions and discharges may have negative effects on the local fishing and oyster industries and diminish the area’s attractiveness for sailing, water sports and as a holiday centre. Collectively these activities are significant for the economic health of the Blackwater estuary. We suggest a criterion is established requiring an independent assessment of the overall economic implications, positive and negative, for the areas within, say, 20km of the development.
On the issue of blight, it may be that proposals for new build will have an adverse effect on property values. This effect is likely to be enhanced once construction commences and later when operations begin. Blight will remain so long as there is a presence of nuclear activity on a site, including decommissioning and cleanup. Blight is difficult to measure but its potential impact must be recognised and mitigating measures considered.
In terms of quality of life a criterion on sustainability would be appropriate. At a broader level it might be argued that new nuclear power transgresses the principle of sustainable development in that it creates a burden on future generations. However, we commend the SEAcobjective to encourage sustainable communities. It is important to be clear what this means. Sustainability is not simply an economic issue, it may also be related to notions of well-being. By this we mean those aspects of living which contribute to the community’s sense of identity, development and positive self-image. It may be argued that nuclear power plants tend to present a negative image and sense of identity (associations with threat, danger and fear). This is clearly one reason why existing sites have been identified as likely places for new stations. It is recognised by government and the nuclear industry that nuclear power plants are unlikely to be welcomed at greenfield locations. A sustainability criterion which covers both economic and social aspects should be included.
Additional Criterion 4: Public Acceptability
We believe developers must be able to demonstrate public acceptability for a new nuclear power station. It is often claimed that familiarity with nuclear activities reduces anxiety and the economic investment is welcomed. There has been considerable research on this issue and, it must be said, the evidence is conflicting. Some studies have indicated a more positive response in existing locations while others suggest that increase in knowledge results in elevated anxiety. The most recent in-depth study on Living with Nuclear Power portrays the multi-faceted, complex and sometimes ambiguous perspectives experienced by local people. Feelings of Threat, Distrust, Beneficial and Safe were all present to varying degrees in the small samples in the communities surveyed. It would be imprudent to draw conclusions on the basis of research confined to nuclear communities which which was not designed to consider attitudes towards new nuclear power and waste storage sites. There is a need for independent survey research to determine public responses to proposals for new nuclear build and the level of public acceptability likely to be achieved in both existing and alternative locations.
There should be a criterion requiring independent evidence on public acceptability. We believe this should be one element of the fairer siting strategy we have advocated at various points in this response.
Do you agree that the proposed SSA is appropriate to produce a list of strategically suitable sites for the purpose of setting the framework for the Infrastructure Planning Commission’s decisions? If not, how should the process be changed to achieve this objective?
We have already indicated our reasons in previous answers. The government has clearly indicated that it considers existing nuclear sites to be the most favourable for early development. It follows that these will be the list of strategically suitable sites arising from the proposed SSA. This would provide a very restricted framework for the Infrastructure Planning Commission.
The whole exercise would appear to be a predetermined effort to identify and legitimate through the IPC a strategy for new nuclear build based on existing locations only. As we have said this looks very like a reinvention of the discredited Decide Announce Defend (DAD) approach. The draft criteria appear to have been drawn up so as not to exclude existing sites. Given current ownerships it seems unlikely that any non-nuclear sites will be put forward by a CNPO.
We have indicated that the classification of the criteria should be reviewed, that the definitions of some criteria should be clarified and that some new criteria should be added to the list. If this is done it might well be that the list of sites would be very different from that likely to emerge from the criteria as currently drafted. In other words the list of sites is critically dependent on the way the criteria are framed, drafted and applied.
In response to the second part of the question, we consider the process should be changed to achieve an equitable siting process. Such a process would need engagement and debate with a much wider range of interests in the setting of criteria. At present the process of drafting, consultation and producing SSA criteria is confined and closed with privileged access to the process offered to very few participants. Strategic siting criteria ultimately have local implications and local communities need to be engaged in establishing the generic criteria that will be used to determine local sites. We consider that Stage 2 of the SSA process should be opened up for a wide ranging debate before any firm conclusions are reached. Participants should include local communities and elected bodies. Effort should be made to ensure the consultation reaches the widest possible audience. The debate should consider the range of issues presented in this and other responses.
Public acceptability should, as suggested above, be an SSA criterion. Consequently, Stage 2 should incorporate a process of seeking to understand the issues of importance and concern to stakeholders and the wider public. It is not sufficient for site owners or CNPOs to undertake public information campaigns around local sites. The information is inevitably controlled by nuclear interests in an effort to promote the case for new build at existing sites. Consultation must be seen to be an open and disinterested process, undertaken independently of nuclear or other interests.
Similarly, Stage 3 should seek to ensure that the consultation on a draft list of sites is widened and deepened to ensure that all interests are engaged and involved in deciding on the final list of sites. It is important that the government clarifies what it intends by the statement, ‘It will also consult with local communities in the vicinity of those sites’ (para. 1.11). Will the consultation be merely informative or will it provide involvement in decision making on the final list?
The existing siting process is, in our view, hurried and undemocratic. There is insufficient time for adequate deliberation and representative and participative democratic processes are being sidelined under the new planning legislation and in the SSA process.
As indicated earlier we believe the process of DAD which underlies the consultation process will lead to unfair and unacceptable outcomes. We do not think that the choice of sites should be left to CNPOs. Rather, we believe that the Government should take responsibility for developing a fair, acceptable and optimal siting strategy. We believe a voluntary process based on participation and partnership to be the acceptable approach to siting what will be, in effect, long-term waste management facilities. Given that the proposals include the interim management of high level wastes for an indefinite period the CoRWM approach to siting would appear to be the appropriate way forward.
The site selection process currently being undertaken will do nothing to hinder the imposition of large new nuclear power stations and associated waste management facilities on existing sites. Communities in the areas around these sites are given little effective say in a decision making process which is largely centralised and closed providing access only to certain privileged interests. We strongly urge government to review and redevelop the siting process along the lines we have suggested.
C STRATEGIC ENVIRONMENTAL ASSESSMENT
Question: Do you agree with the findings of the potential environmental and sustainability effects of applying the proposed SSA criteria? If not, what additional environmental and sustainability effects, if any, should be considered and how should these issues be reflected in the SSA criteria?
We find that the sections of the consultation document relating to the SEA are extremely difficult to comprehend. The sections in question include: p. 17, paras. 56 -7; pp. 33 – 6 paras. 1.41 to 1.50; and pp.72 – 3, paras.2.142 – 2.151. From these sections it is difficult to understand the precise relationship between SSA criteria and SEA objectives. We suggest that this aspect of consultation is more clearly set out and comprehensible in subsequent consultation documents. The supporting document, Applying the proposed Strategic Siting Assessment Criteria: a study of the potential environmental and sustainability effects, is also inaccessible to the general reader consisting of a set of appendices set out in columns with no supporting commentaries. This is an important document covering a wide range of issues and it would be helpful if it were made more user friendly. In particular it would be helpful if the expanded and additional SSA criteria were clearly identified in the main consultation document. This would stimulate a response on alternatives to be considered.
In our response to question 4 we have already indicated the environmental objectives and sustainability principles which we think should be incorporated in the SSA criteria. We do, however, have some closing observations to make on the environmental aspects of the consultation.
D OBSERVATIONS ON THE ENVIRONMENTAL ASPECTS OF THE CONSULTATION
SEA objectives and research. A number of the objectives, if they are to be fulfilled, require evidence based research. For example, as we have observed, objective 4 ‘To create employment opportunities’ needs to be evaluated in terms of net job creation, long term job prospects and overall economic benefit or detriment to the sub-region surrounding a site. Similarly, objective 14, ‘To avoid increased flood risk (including coastal flood risk) and seek to reduce risks where possible’ requires research demonstrating potential flooding under different scenarios and time-scales. Research undertaken to support objectives must be independent, peer reviewed and both generic and capable of specific application to sites.
Inappropriate classification of certain criteria. The consultation document concedes (para. 2.148) that ‘certain features of the criteria, including the discretionary nature of some of the criteria, mean that adverse environmental and sustainability impacts cannot be ruled out’. This statement applies to criteria 1.4 and 1.5 as indicated on pp.75 – 6. We have already argued that these criteria covering flooding, storm surge and coastal processes must be re-designated as exclusionary.
Achieving sustainability. Para. 2.149 claims that the application of the proposed SSA criteria ‘is likely to lead to outcomes which are, on balance, broadly in line with the principles of sustainability and environmental protection’. We regard this as an untestable assertion. The principle of sustainability is hard to define and depends on time-scale. It could equally be argued that, over the longer term, sites may become completely inundated and, consequently, quite unsustainable. We suggest the statement on sustainability is either carefully qualified or withdrawn.
Balance between environmental protection and new nuclear power. It is suggested that ‘the proposed SSA criteria strike the right balance between the need for environmental protection and the pressing challenges of delivering the UK’s energy policy objectives’ (para. 2.150). We are most concerned that this balance has not been struck. We are not convinced of the need for nuclear energy. But, even if it is considered desirable to build new nuclear power stations, the SSA criteria could lead to outcomes that are wholly inconsistent with the need for environmental protection. It is quite conceivable that these stations will be developed at existing sites in southern England, all of which are subject to problems of flooding and coastal erosion arising from climate change. In the effort to protect the environment around the power stations, areas in close proximity may have to be abandoned. There is the danger that the SSA criteria may facilitate an outcome which promotes building of new power stations on vulnerable coasts at the expense of environmental protection. We urge that the criteria are redrafted to achieve a balance that offers greater prominence and priority to environmental protection over the longer term.
E FINAL COMMENT
We consider this consultation to be very important and consequently we have offered a detailed and critical response. We trust that our comments along with others will be carefully and openly considered and that a commentary will be published indicating how our views have been taken into account. More than that we would welcome the opportunity to engage in discussion in developing the final criteria. We look forward to the debate.
Blackwater Against New Nuclear Group
November 9th. 2008
BERR (Department of Business Enterprise and Regulatory Reform)(2008) Meeting the Energy Challenge: a White Paper on Nuclear Power, TSO, January
CoRWM (Committee on Radioactive Waste Management)(2006) Managing our Radioactive Waste Safely: CoRWM’s Recommendations to Government, CoRWM, November
CoRWM (Committee on Radioactive Waste Management)(2007) Moving Forward: CoRWM’s Proposals for Implementation, CoRWM document 1703, February
Defra (Department of Environment, Food and Rural Affairs)(2008) Managing Radioactive Waste Safely: A Framework for Implementing Geological Disposal, White Paper by Defra, BERR and the Devolved Administrations for Wales and Northern Ireland, Cm 3786, London, TSO, June
Flood Hazard Research Centre (2007) ‘The impacts of climate change on nuclear power station sites: a review of four proposed new build sites on the UK coastline’, Middlesex University, Greenpeace
Grieve, H. (1959) The Great Tide: the Story of the 1953 Flood Disaster in Essex, County Council of Essex
Nirex (2005) ‘The impact of rising sea levels on coastal sites with radioactive waste stores’ UK Nirex Ltd., Technical Note 484385, September
Richards, H. (2008) Too Hot to Handle, April
Thorne and Associates (2005) ‘Understanding of Climate and Landscape Change to support Optioneering at NDA Sites: Phase 2’, March
p. 20/…. Appendix A/
Blackwater Against New Nuclear Group (BANNG)
Aims and Strategy
Aims and Purpose
The purpose of the Group is to seek to protect the people and environment of the River Blackwater estuary and its surrounding area, now and in the future, from the risks and dangers of radioactivity by preventing the further development of nuclear activity in the estuary.
To this end the Group has five broad aims:
to raise public awareness among the Blackwater communities of the potential consequences for health, environment and safety of proposals for new nuclear development;
to identify key issues of concern and to gather credible and responsible research and information to pursue the case against nuclear development;
to challenge any proposals for future nuclear power at the Bradwell site by presenting robust evidence and arguments to local and national decision makers, regulatory bodies, the nuclear industry, non government organisations, the media and the general public;
to support the early and successful decommissioning and clean up of the existing Bradwell nuclear site as an integral element of the long-term protection and conservation of the Blackwater estuary;
to call for an open, transparent and deliberative decision making process in which local communities are afforded full access to all information and involvement in key decisions affecting them.
In pursuit of these aims the Group will develop a strategy with the following components:
1. Information and research
Gathering all available relevant research and evidence on key issues and disseminating it throughout the local communities. This may involve developing a data bank and associated web site.
Liaison and communication with national expert groups (e. g. Nuclear Consultation Working Group, Nuclear Waste Advisory Associates) to ensure relevant expertise is readily available.
Identifying uncertainties and gaps in knowledge and initiating or urging further research.
Encouraging accessible and intelligible information on monitoring of air, water and soil quality in the Blackwater estuary.
2. Raising Public Awareness
Deepening awareness by reaching out to the whole community through leaflets, posters, local media and key local organisations.
Broadening awareness by reaching neighbouring communities around the Blackwater estuary and the surrounding areas including major centres such as Colchester, Maldon and Clacton.
Involving local people through public meetings, petitions, lobbying and other activities.
3. Decision Making
Communicating community concerns to decision makers at local and national levels, including, government ministers, local MPs, County, Borough and Town/Parish Councils.
Ensuring community concerns are fully considered at every stage in decision making, including, environmental appraisal, impact assessment, reactor design, waste management proposals, planning considerations and application.
Ensuring regulatory authorities fully consider those issues specifically relating to health and environmental impacts of a power station at the Bradwell site.
Urging the full implementation of all plans, policies, directives and other programmes that are aimed at the protection and enhancement of the Blackwater estuary.
Working in an open and transparent manner and encouraging other decision makers to act in the same way.
Organisation, Administration and Finance
The Group will be participative and democratic in principle and practice.
Key decisions on strategy will be taken by supporters at open meetings.
A small core group (executive) will be responsible for day-to-day organisation and decision making, referring key decisions to the open meeting.
Sub-groups will undertake specific tasks and functions.
There is a Chair, Secretary, Treasurer, Media Relations Officer, Community Awareness Co-ordinator and Strategy Co-ordinator.
Fund-raising will be undertaken.