CONSULTATION ON DRAFT NATIONAL POLICY STATEMENTS FOR ENERGY INFRASTRUCTURE
DRAFT OVERARCHING NATIONAL POLICY STATEMENT FOR ENERGY (EN-1)
DRAFT NATIONAL POLICY STATEMENT FOR NUCLEAR POWER GENERATION (EN-6) AND ASSOCIATED DOCUMENTS
RESPONSE OF THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)
The Blackwater Against New Nuclear Group (BANNG) is a Citizens’ Based Organisation formed in early 2008 to oppose the proposed development of a new nuclear power station at Bradwell. The Group comprises a wide support base focused on the Blackwater estuary in Essex and has participated in a series of meetings with DECC, national and local political representatives, local councils, regulators and government advisory bodies, other NGOs and local community groups. The Aims and Purpose of the Group together with more information can be found on the website www.banng.org.uk This document constitutes BANNG’s formal response to the Consultations on the draft energy National Policy Statements particularly those relating to nuclear energy.
BANNG has already submitted detailed, substantive and informed responses to earlier consultations. These are: Consultation on the Strategic Siting Assessment Process and Siting Criteria for New Nuclear Power Stations in the UK; Consultation on the Nuclear Industry’s Application to Justify New Nuclear Power Stations; Consultation on the Nomination of Sites for New Nuclear Power Stations; and House of Commons Energy and Climate Change Committee Inquiry into National Energy Policy Statements (BANNG, 2008, 2009a, 2009b, 2009c). For ease of reference all these responses are attached. BANNG wishes all its responses to be taken into account as integral components in the evidence and argument it is presenting against the possible proposal to develop a new nuclear power station at Bradwell.
In presenting its response BANNG wishes to challenge the approach and tone adopted in the Consultation document (DECC, 2009a). On p.12 it is suggested that responses focus on a series of predetermined questions although respondents are free to make other comments which will be considered where appropriate. BANNG feels this is a restrictive approach designed to lead and limit discussion by establishing the Government’s agenda for response. It is highly probable that the Government’s response to this consultation will be organised around the questions thereby privileging those who conform to the suggested approach. BANNG will endeavour to answer the questions but finds it difficult to marshal all its comments and evidence under specific headings without the danger of either repetition or omission. We invite Government to accept that this consultation should be a dialogue and discussion, not a
question and answer session. In such a context it is not for government unilaterally to ignore comments which it deems inappropriate.
It is also stated that Government will give greater weight to responses that are based on argument and evidence rather than simple expressions of support or opposition. BANNG would question what is meant by ‘evidence’ in this context. Much of the Government’s presentation is based on predictions, assumptions, even assertions in the face of uncertainties and contradictions. In an area such as future energy policy where the science is in conflict and society has differing views and values, empirical evidence is highly contestable. BANNG urges the Government to recognise that its own policies as embraced in these documents are as vulnerable to criticisms about the nature of the evidence as is the evidence put forward with those holding opposing views. BANNG is concerned that the consultation is designed in such a way as to constrain and limit responses to an agenda that is intended to endorse the government’s policy to promote nuclear energy.
BANNG is also concerned with the emphasis on speed of decision making that is present throughout the documentation. For example, in the Consultation Document the role of the NPSs is stated to be ‘to speed up the transition to a low carbon economy’, to ‘help in terms of removing planning barriers’ and ‘to deliver faster and more transparent decisions on energy infrastructure’ (2009a p.5). Nowhere is this counterbalanced by an equivalent emphasis on the requirement for measured engagement with stakeholders and the public, especially those communities most affected by the proposals for new nuclear power stations. If public support and confidence in proposals is to be achieved it must be built on trust, involvement and responsiveness. In BANNG’s view the NPSs for nuclear energy reflect a determination to push through a process of decision making as rapidly as possible without an effective counterbalance of public and stakeholder engagement and participation.
The first part of this response will focus on the questions posed for EN-1 in particular on the inadequacy of the consultation and siting process for new nuclear energy. The second part will consider the questions related to EN-6 and will bring evidence to bear to demonstrate why the Bradwell site is unsuitable for a new nuclear power station. BANNG’s response will provide a reasoned argument to support the overall conclusion on the NPSs stated below:
BANNG considers the draft NPSs relating to nuclear energy confusing, tendentious, vague and poorly integrated. They do not encourage effective and democratic participation and engagement. They appear to be a highly elaborate exercise to achieve premature legitimation for a predetermined policy, namely, the rapid deployment of new nuclear power stations on a limited number of existing sites. BANNG is concerned at the unsuitability of selected sites and, as a group concerned with a particular site, has demonstrated why Bradwell should not be considered further. BANNG concludes that the NPSs do not provide a coherent and practical framework for the IPC to assess planning applications and are, consequently, not fit for the purpose for which they are designed.
Part 1 Draft Overarching Energy NPS (EN-1)
Question 1 Do you think that the Government should formally approve the draft
Overarching Energy National Policy Statement?
In BANNG’s view the answer to this question is ‘No’. Our general reasons are indicated in the Preamble to this response. In the rest of this response we set out in more detail why the NPSs should not be designated. There are two overarching reasons why the NPSs EN-1 and EN-6 should not be designated. First is that the process of decision making, including this consultation, is, in our view, inadequate, unfair and undemocratic. Second, these problems are reflected in the substance of the NPSs and related documents which are based, in part, on selective interpretation, unsupported speculation and partial or biased information.
Question 2 Does the draft Overarching National Policy Statement provide the
Infrastructure Planning Commission with the information it needs to
reach a decision on whether or not to grant development consent?
Question 3 Does the draft Overarching National Policy Statement provide suitable
information to the Infrastructure Planning Commission on the
Government’s energy and climate policy?
Taking these two questions together BANNG intends to comment on the process rather than the substance whereby information is assembled and conveyed in the draft NPSs. We shall comment on substantive aspects elsewhere in our submission and we are aware that many respondents will tackle the question of the adequacy of information on energy and climate policy. Our concern is that nowhere in the questions provided or in the documentation is the adequacy of the consultation process itself considered. Yet, the consultation is intended to test the robustness and fitness for purpose of the documents. If the consultation is inadequate, then it follows the NPSs also are inadequate. In BANNG’s view the consultation is hurried, burdensome, constrained, limited and pre-emptive and, in what follows, we provide evidence for this view. A more detailed perspective on consultation relating to the Bradwell site will be presented in part 2.
Consultation Process too Burdensome
As indicated in the Preamble there have been several consultations within the last year to which BANNG, along with many other NGOs and community groups, has responded. In the current round, this consultation and the consultation on the proposed decision on Justification are running in parallel with a closing date of February 22nd. In addition BANNG and others have already presented detailed written and oral evidence to the House of Commons Energy and Climate Change Committee’s inquiry into the Energy NPSs. Meanwhile there are other related processes which also require attention, in particular the Generic Design Assessment (GDA) conducted by the regulators of the proposed power station designs. For part-time and voluntary groups like BANNG it is clearly unreasonable to expect sufficient attention to be paid to simultaneous yet separate consultations each requiring a particular approach, knowledge and expertise.
This problem is compounded by the sheer weight of material that relates to the consultation. Apart from the substantial documents on the Energy NPSs (EN-1 and EN-6 for nuclear but four other volumes for the full suite) and the Consultation document, there are further large documents on Habitats Regulations Assessment, Appraisal of Sustainability, Alternative Sites study together with a formidable array of technical appendices, site reports, summary and consultation comments. The documents associated with the Nuclear NPS are listed on pp. 40-42 of the Consultation document (DECC 2009a). Of course, a fully informed appraisal would need to refer to a range of other documents, including the White Paper Low Carbon Transition Plan (TSO. 2009), policy documents on radioactive waste management (from, for example, the Committee on Radioactive Waste management (CoRWM) and the Nuclear Decommissioning Authority (NDA) and possibly technical reports from agencies such as the Environment Agency (EA), Natural England, etc and from the regulators. One estimate suggests that a respondent focusing on a specific site would still need to read 1674 pages of text to be reasonably informed about the proposals and issues (Roche, P. 2009). Another estimate suggests a figure of 3000 pages associated with the NPSs (Environmental Law Foundation, 2010).
Although some of the documents can be supplied in hard copy on application, some of the technical material is only available online. For those with poor computing and printing facilities for downloading or with no computer, mere access to material is at best time-consuming and at worst access is effectively denied. Even when access is achieved, it is quite difficult to be sufficiently selective in perusing technical material. These documents are not the most accessible or entertaining reading, more usually written in a laboured, turgid form of technical prose that requires intense concentration and takes time to assimilate. Given that the consultation period lasts for only fifteen weeks, including the Christmas/New Year break, the demands put upon an assiduous respondent are burdensome indeed.
Consultation Process too Fast and Fragmented
The consultation process is fast, leading through site selection, justification, NPS, GDA and planning permission within the space of less than four years (2008-11) with the first new stations commissioned by 2018. Given previous UK experience, if achieved, this would be astonishingly fast. The rapid and sometimes simultaneous consultative exercises together with the accelerated infrastructure planning process are the means to legitimate the policy.
The decision making process is sequential and cumulative. For respondents the process appears quite fragmented. There is a sequence of decision points which, once taken, cannot be revisited. Thus the Strategic Siting Assessment criteria are now fixed and the NPSs once adopted will be applied by the IPC. This narrows the scope for deliberation as the process moves from the generic to the site specific. The problem for local communities is that key decisions will have been taken before they become involved. For example, policy on radioactive waste management will be settled and local communities may not have the opportunity to challenge its application at site specific level. By the time decision making reaches the individual site the scope for challenge and change will be severely limited.
The consultation process itself is not participative
Very little effort has been made to engage the public and local stakeholder groups beyond thinly attended public meetings and exhibitions. The mode of consultation is formal, requiring answers to preconceived questions or written comments. Typically the publicity for consultation events is low-key and attendances and response levels are low with the vast majority of the local population unaware that a consultation is taking place. The responses are published but rarely is any analysis performed and no attempt is made to seek representative information on the values and views of the local population. The transcripts of the public meetings provided by DECC are revealing and give voice and vent to the pent up frustration felt by many at the inadequacy of the whole process. The objective seems more geared towards satisfying minimum requirements than undertaking a genuinely interactive engagement. Certainly, these consultations are often regarded by local communities as having little real importance or impact on the decision making process as our later comments on the experience of the Bradwell consultation demonstrate.
The consultation process is biased and unfair
The various aspects of the consultation process outlined above leave local communities at a considerable disadvantage. It is difficult for them to cope with the speed, volume and complexity of material and the method of consultation. Citizen Based Groups (CBOs), NGOs, individual citizens and even local councils find it difficult or impossible to make the time, commitment, experience and knowledge to achieve effective involvement let alone impact on the decision making process itself. In addition they tend to come into the process during the latter, local stages by which time the scope for influence has been considerably narrowed. By comparison the nuclear industry and government officials have considerable capacity in terms of resources, skills and privileged access to ensure input on all aspects and at all stages.
BANNG considers the consultation process is markedly skewed in favour of those interests promoting nuclear development. The documentation draws almost exclusively on sources prepared by the nuclear community or those associated with it. There is an entire absence of more sceptical literature, notably from the social sciences which is rich in sources and evidence to counter the claims of nuclear advocates. By contrast to the well resourced nuclear industry, local communities and citizens are far less able to influence the approach, content and recommendations of the nuclear NPS and associated documents.
In response to questions 2 and 3 (EN-1) BANNG concludes that the consultation process is unfair and does not support an equitable framework within which the IPC can take decisions on new nuclear power plants.
· It is impossible for NGOs, CBOs and ordinary citizens to cope with simultaneous consultations within a short space of time
· The volume of material is unmanageable and much of it difficult to access and assimilate
· Little attempt has been made to engage local stakeholders and the public in a more participative process enabling them to influence the content of the NPSs
· The speed, timing and format of the consultation process advantages the nuclear industry and government bodies which have time, resources, expertise and access to make an effective response
Consequently BANNG believes the consultation process on nuclear energy is seriously flawed and does not provide a balanced evidential basis for decision making by the IPC. BANNG urges that a new and more participative process should be undertaken in an effort to ensure public confidence in Government decision making.
Question 4 Does the draft Overarching Energy National Policy Statement provide
suitable direction to the Infrastructure Planning Commission on the
need and urgency for new energy infrastructure?
For the reasons indicated above BANNG does not consider the information provided suitable and, consequently, it does not provide suitable direction for the IPC. We strongly believe the documentation requires comprehensive review based on a new and participative consultation as recommended above. We believe the whole process is too hasty and ill-considered placing the government’s desire for ‘urgency’ far above other equally important considerations. As a result there is the danger of cutting corners and narrowing the options and scope of decision making. We believe this directive tendency to be pronounced in the NPS (EN-6) on nuclear which is the only NPS that is site specific.
Siting – a pragmatic not a rational approach
In terms of siting options the NPS on nuclear energy (EN-6) limit the IPC to considering only the ten sites that are listed. The NPSs are unequivocal that nuclear power stations should be built on these sites since ‘need has been demonstrated’ (TSO. 2009, p. 14). Whichever and whether these sites will be developed depends on the investment decisions of the market. Consequently, the actual number, timing and location of new nuclear power stations is unclear. Unlike the target of 30% renewable capacity by 2020 (EN-1), new nuclear capacity is undefined and unrestrained. The NPS states that ‘it is essential that this NPS has sufficient sites to allow nuclear to contribute as much as possible towards meeting the need for 25GW of new capacity’ (EN-6, DECC, 2009c, p. 13). Thus, the NPS for nuclear energy is specific in terms of sites but fails to give any guidance in terms of which sites will be developed in what order and in what sequence. As a framework for the IPC the nuclear NPS is remarkably innocent of any strategic planning.
It has been clear from the outset of the strategy for developing new nuclear power that, in the main, the choice of sites for new nuclear stations would be likely ‘to focus on areas in the vicinity of existing nuclear facilities’ (Ibid, p.33). The reasons were purely pragmatic – these are sites where land is available, infrastructure exists and they are in places where some familiarity with the industry might be expected to reduce resistance from local communities. This latter claim is constantly reiterated in various documents. For instance, the Appraisal of Sustainability for the Bradwell site argues that ‘people living and working nearby have had a long time to get used to there being an adjacent nuclear plant so this is unlikely to be a problem at this location’ (DECC, 2009c, p.42). It must be said this latter point is an assertion that, in our view, is not supported by empirical evidence. Indeed, people living near Bradwell have had seven years to become familiar with a shut down power station and, both polling evidence (IPSOS-MORI) and that collected by BANNG (petition) are highly suggestive that a majority of people prefer it that way.
The ten sites have all been assessed through the Strategic Siting Assessment criteria that were adopted after consultations in early 2009 (BERR, 2008, DECC, 2009b). In our response to these consultations BANNG indicated its concerns about certain criteria in terms of their classification, definition and application (BANNG, 2008). BANNG believes that the criteria were drawn up with specific (i.e. existing) sites already in mind. Only one site, Dungeness, that was in the eleven originally nominated failed to be listed. In this case the adverse effects on the integrity of the internationally designated areas was so severe that it was ‘not considered that mitigation of impacts related to habitat loss would be possible’ (DECC, 2009a, p.79). Although this is the reason given for not listing Dungeness it is also clear that Dungeness might well have failed on other grounds. There were concerns over whether it could be protected from flood risk and coastal processes and this would have posed ‘a challenge’ if Dungeness had remained in the frame (DECC, 2009c, p.75 and p.76). The delisting of Dungeness could be construed not as an isolated case but as a precedent. Other sites, to a greater or lesser degree, manifest similar problems of potential environmental damage and flood risk; for instance, Bradwell is in a much higher flood risk zone than Dungeness. It may be questioned why they, too, were not delisted.
The reason is that the criteria were open to wide interpretation. BANNG was especially concerned about the criteria on flooding and coastal processes, which we felt should be more tightly defined and the criterion on demographics which, we considered to be unintelligible and illogical. We made other criticisms and suggested other criteria which should be used. In the event none of our criticisms were met and the criteria were adopted virtually unchanged. The adopted criteria are not open to change and therefore apply a further limitation on the discretion available to the IPC when considering planning applications. BANNG maintains its view that some of the criteria are unsatisfactory and that they should be subject to further discussion by the IPC when considering applications from developers for new nuclear power stations.
The IPC is further constrained by the lack of alternative sites. The documents make it clear that there are no alternative sites to the ten listed. The IPC ‘should be guided in considering alternative sites by whether they are in the locations identified in the NPS’ (2009d, p.37). In an elaborate exercise of masterful rationalisation, the Alternative Sites Study uses historic studies, views of energy companies and a complex screening exercise to identify around 270 sites, rejecting all but three as ‘Not worthy of further consideration’ (Atkins, 2009, pp. 43-63). Analysis of the three sites, at Druridge Bay, Owston Ferry and Kingsnorth indicates a number of constraints which would make deployability by 2025 problematic. Of the initial eleven sites nominated, one, Dungeness, was not listed and there are reservations about the practicability of deployment of the two listed ‘greenfield ‘ sites at Braystones and Kirksanton (DECC, 2009a, p.49).
Finally, on siting, EN-1 makes it abundantly clear that any alternative siting proposals beyond those listed should receive short shrift from the IPC. It states, ‘it should be reasonable for the IPC to conclude that alternative proposals which are vague or inchoate may be excluded on the grounds that they are not important and relevant to the decision’ (DECC, 2009d, p.37). BANNG regards such a subjective statement unacceptable as guidance to the IPC.
BANNG is also concerned that EN-1 gives far more emphasis to nuclear at the expense of support for alternative renewable sources of electricity. There is a acknowledgement of the importance of diversity in energy supply and a commitment to improving renewable energy sources (DECC, 2009d, p.21 and p.22). But, there is a neglect of other renewable sources which are fast becoming available. The potential for wave and tidal power is recognised but is effectively ignored as ‘not within the scope of this NPS’ (Ibid, p.4). By the time new nuclear generation can be deployed it is highly likely that these alternative sources will with other renewable sources be able to make a commensurate contribution thereby rendering nuclear unnecessary.
BANNG considers the lack of any alternative siting strategy to the ten listed sites too directive and restrictive. BANNG remains concerned that some of the strategic siting assessment criteria are unsuitable and should be revised
The approach to siting new nuclear stations is unplanned and vague leaving the market to decide thereby creating uncertainty on the timing, number and locations of new stations. It is unclear what level of nuclear capacity is anticipated or can realistically be deployed.
The constraints on siting imposed have ensured that no alternatives to the ten listed sites will be considered by the IPC. This imposes an unfair burden of risk on communities close to these sites
The need for new nuclear has not been convincingly demonstrated and it may prove impossible to deploy a large number of stations by 2025. Alternative strategies of investment in renewables and energy efficiency are likely to prove more effective and should be more vigorously pursued in EN-1.
In terms of siting, BANNG does not consider the Overarching Energy National Policy Statement provides suitable direction for the IPC
Question 5 Do the assessment principles in the draft Overarching Energy National
Policy Statement provide suitable direction to the Infrastructure
Planning Commission to inform its decision-making?
Question 6 Does the Draft Overarching Policy statement appropriately cover the
generic impacts of new energy infrastructure and potential options to
mitigate those impacts?
We take these two questions together since they are interrelated. We intend to focus on three key assessment and impact issues at a generic level. These are: flooding and coastal processes; environment and ecology; and demographics and emergency planning. More site specific comments relating to the Bradwell site will be presented in Part 2 of this response.
Flooding and Coastal Processes – Assessment Principles and Impacts
The ten sites listed are all on or close to the coast where there is availability of cooling water. Some of them (e.g. Bradwell, Hartlepool) are within flood zone 3, high probability of > 0.5% annual flooding. Given the pragmatic reasons for site selection discussed in the previous section it is unlikely that the ten sites are the only or the best possible sites for new nuclear power stations. The Strategic Siting Assessment (BERR, 2008; DECC, 2009b) and the Alternative Sites Report (Atkins, 2009) must be seen as means of post hoc rationalisation in limiting and justifying the choice of sites. Equally, it may be concluded that, apart from Braystones and Kirksanton, such vulnerable sites would not have been selected were it not for the presence of nuclear facilities (Blowers, 2009).
Two of the discretionary SSA criteria relate to the coastal location of sites. These are flooding, storm surge and tsunami and coastal processes. Both EN-1 and EN-6 recognise that these coastal sites are ‘at greater risk of flooding’ (DECC, 2009c, p.32) without mitigation and that mitigation measures may have consequential impacts on coastal change. We detect a difference in the assessment of flood risk between EN-1 and EN-6. The aims of policy according to EN-1 are ‘to direct development away from areas at highest risk’ and, where new energy infrastructure is ‘exceptionally, necessary in such areas, policy aims to make it safe without increasing flood risk elsewhere and where possible, reducing flood risk overall’ (DECC, 2009d, p.67). EN-6 which is confined to new nuclear plants appears less cautious and stresses the potential of mitigation concluding that ‘at the strategic level the risks are considered to be manageable’ (DECC, 2009c, p.32).
EN-6 instructs the IPC to ‘take account of the credible maximum scenario in the most recent marine and coastal flood projections’ and to ensure that mitigation would ‘be achievable at the site for the duration of the life of the station and the interim spent fuel stores’ (DECC, 2009c, pp. 33-4). However, it is recognised that ‘predictions of climate change impacts ‘become less certain the further into the future the assessments are for, and it is not practicable to consider beyond 2100 at this stage’ (Ibid, p.51). It is quite possible that interim stores of highly active wastes will still be present on site in 160 years from the start of generation of a new power station (60 years operation plus 100 years for cooling of fuel). In other words, nuclear activity of some kind is likely to be present on sites until towards the end of the next century.
The Environment Agency’s pronouncements on the matter of flooding and mitigation are, to say the least, highly qualified and tentative, concluding for the Bradwell site as follows,
‘The Environment Agency has advised that it is potentially reasonable to conclude that a nuclear power station within the nominated site could potentially be protected against flood risks throughout its lifetime, including the potential effects of climate change, storm surge and tsunami, taking into account possible countermeasures’ (our emphasis)(DECC, 2009c, p.66).
Nonetheless, the Government considers this feeble assessment is sufficient to conclude that the Bradwell site passes the flood risk criterion. In reality, beyond 100 years where prediction of sea level rise and coastal change becomes frankly speculative, it is impossible to give any useful guidance at all. It appears to us incredible that coastal areas where flooding and coastal changes are likely to occur within the next 200 years should be considered for inclusion in the list of sites for new nuclear power stations.
On the issue of flooding and coastal processes BANNG considers that:
The criteria relating to flooding and coastal processes should be exclusionary
Sites which are clearly vulnerable to inundation over the next 200 years should be excluded
Mitigation measures should not be contemplated where serious damage is likely to affect neighbouring coastlines or the marine environment.
We conclude that the assessment principles relating to flooding and coastal processes provided in the NPSs are too flexible and open to interpretation and do not provide suitable direction to the IPC. We believe stringent and unambiguous criteria on flooding and coastal processes should be applied to exclude the location of power stations on inappropriate sites.
Environment and Ecology – Assessment Principles and Impacts
The Nuclear NPS and associated Habitats Regulations Assessment (HRA) and Assessment of Sustainability (AoS) reports refer to a range of issues and criteria relating to environment and ecology. These embrace international and national designated sites of ecological importance, and areas of amenity, cultural heritage and landscape value. Although it is recognised that there will be adverse impacts, it is considered that disruption and disturbance to important habitats and ecosystems can be potentially ameliorated or lessened through mitigation measures. No matter what the impacts, the need for nuclear power as determined by government policy, is seen as sufficient in itself to override the desirability of conserving environment and ecology. In the case of Bradwell, for instance, the ‘Government has concluded that there is an Imperative Reason of Overriding Public Interest that favours the inclusion of this site in the Nuclear NPS despite the inability to rule out adverse effects on European sites at this stage’ (DECC, 2009c, p.71). Given the readiness evident in the NPS to invoke IROPI it appears that, in the urgency to achieve nuclear power stations at ten listed sites, (almost) anything goes.
As we indicated earlier only Dungeness of the nominated sites was not listed. We pointed out that the reasons for not listing Dungeness might be seen as a precedent for not carrying forward other sites such as Bradwell where similar adverse impacts were present. The assessment criteria relating to environment and ecology are vague, unspecific and constrained thereby encouraging the retention of the ten listed sites. They are vague in that adverse effects cannot be ruled out and detailed studies are needed on mitigation measures. They are unspecific in that no guidance is given on the degree of environmental impact that would rule out a site or the level of mitigation that would be needed to retain a site. For example, the Bradwell HRA lamely concludes that, ‘Only at the project level HRA can a conclusion of “no adverse effect on site integrity” be made with any confidence’ (DECC 2009e, p.43). And they are constrained in that it is made abundantly clear that, only in the most exceptional circumstances, should a site be rejected, so imperative is the overriding national interest for the development of nuclear power. On this point the Government is quite clear; the ten sites should be made available even though ‘potential adverse impacts on Natura 2000 sites cannot be ruled out’ (DECC, 2009c, p. 276).
The strong line on IROPI, which suffuses EN-6, is at some variance with the approach stated in EN-1 where the IPC is given a stronger steer on matters of climate change and impact. For example,
‘The IPC should not normally consent new development in areas of dynamic shorelines where the proposal could inhibit sediment flow or have an adverse impact on coastal processes at other locations’ (DECC, 2009d, p.63).
By contrast, in EN-6 guidance is at once both permissive, leaving the IPC some discretion on the basis of evidence at the local level, but also highly restrictive in its emphasis on the need to approve sites for new nuclear energy. This tension between discretion and restriction pervades the whole document and reinforces BANNG’s view that the NPS has the implicit function of ensuring sufficient existing sites to fulfil the Government’s commitment to nuclear energy regardless of the serious environmental consequences that may ensue both now and in the future.
On the issues of environment and ecology BANNG considers the NPSs on nuclear energy do not provide suitable direction to the IPC for the following reasons:
The guidance on environmental impacts is too permissive. There needs to be a presumption against consenting to a site in situations where the adverse impacts on ecosytems, habitats, landscapes and amenity would lead to irrecoverable damage
There should be stronger guidance on what measures of mitigation must achieve in order to prevent unacceptable damage to environment and ecosystems
Stronger guidance is required on the level of potential coastal change arising from climate change that would render a site unacceptable. Sites in flood zone 3 should be excluded
The principle of Imperative Reasons of Overriding Public Interest should not be routinely invoked to promote nuclear energy whatever the consequences for environment and ecology. IROPI should also be used to defend and protect environments that are unique, significant or irreplaceable
Overall, on the matter of environment and ecology, the NPS should offer clearer, unambiguous and balanced guidance to the IPC
BANNG concludes that the guidance on environment and ecology is inadequate and too weighted in favour of granting consent rather than inviting a more balanced assessment of the needs of development and environment.
Demographics and Emergency Planning –Assessment and Impacts
The demographics criterion is one of only two that are exclusionary though it is assessed again at development consent stage to take into account any changes (for example, in reactor design or population) that may have altered the acceptability of the risks to the local population. The demographics criterion has been so constructed that all ten sites pass the criterion and the criterion cannot be revisited by the IPC.
The objective is ‘to limit the radiological consequences to the public in the unlikely event of a serious nuclear accident’ (DECC, 2009c, p.43). The criterion adopted is ‘semi-urban’, derived from a complicated and (as presented in the SSA criteria) unintelligible formulation that weights distance from the plant with population to produce a cumulative weighted population within the vicinity up to a distance of 8km. It is unclear how the parameters are derived and justified (see the critique we made in our responses to the consultation on Strategic Siting Assessment criteria, BANNG, 2008, 2009). Be that as it may, the outcome is neither fish nor fowl. On the one hand, the criterion indicates that ‘remoteness’ is no longer necessary; on the other ‘urban’ locations are ruled out on grounds that a substantial population might be endangered. But this makes little sense. It seems to BANNG that nuclear power stations are regarded either 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 based and where they avoid long distance transmission and can take advantage of the potential for CHP. We note that the NPS EN-1 while recognising the feasibility of CHP from nuclear stations indicates it would only be viable if the station was located close to industrial or domestic consumers with heat demands (2009d, pp. 38-39). A semi-urban location is, therefore, likely to reduce the overall viability of nuclear energy.
By adopting a semi-urban criterion the Government has recognised the potential risk to local populations from an incident or accident. What has not been recognised is that substantial populations may be at risk, particularly if a more realistic notion of the area that might be affected were used. To take Bradwell as an example, within 10 km there are substantial settlements including West Mersea (8000) only 4km away. Not far beyond, the 20km range encompasses the large towns of Colchester (100,000) and Clacton (see AoS Bradwell site maps) and within 25-30km the population is around a third of a million. On this basis the semi-urban criterion can hardly be said to minimise the risk to population but it serves the purpose of ensuring that the ten listed sites are not excluded on grounds of population density. A more satisfactory, comprehensible and logical approach would be to state what levels of population within specific zones were acceptable in terms of radiological risk from accidents or other incidents.
A related issue is the protection of the public in the event of an accident. The scale of an accident will vary but it is necessary to plan for the biggest credible scenario which might involve a very large population within a wide area of the plant (as, for example, was the case at Three Mile Island in 1979). Preparedness involves the following steps: clear and realistic identification of emergency planning zones; adequate provision of information to the public; planning for eventualities including the possible evacuation of large populations. Present planning is deficient on all counts. Emergency Planning Zones are too tightly drawn to the immediate vicinity of power stations; the public are unaware of the warnings, procedures and precautions that are needed in the event of an accident; and evacuation of large populations is likely to prove impossible.
In the NPSs, emergency planning is a matter for local consideration relying on existing regulations and guidelines to be drawn up and implemented by nuclear operators and emergency services. The Government ‘does not generally believe that it is possible to determine the ability of a site to meet emergency planning obligations at a national level..’(DECC, 2009cp.42). BANNG finds this quite inadequate and unreasonable and unlikely to reassure the public put at risk. The NPSs are incredibly vague and insubstantial on the matter of emergency planning. Ultimately, it may prove impossible to protect the population in the event of a major emergency. In BANNG’s view it would be more prudent to adopt a cautious approach by defining more clearly the nature of the potential risks and setting out some clear, detailed and generic guidelines on what procedures, plans and policies must be in place. It is surely not reasonable to leave these matters entirely to local determination on a site specific basis.
On the issues of demographics and emergency planning BANNG has the following observations,
The NPS should ensure that guidance to the IPC is firmly based on the Government’s objective ‘to limit the radiological consequences to the public in the unlikely event of a serious nuclear accident’. This means limiting the numbers potentially exposed and ensuring a swift and effective response in an emergency
In BANNG’s view the exclusionary ‘semi-urban’ demographic criterion does not meet the Government’s objective. The NPS should apply a ‘remote’ criterion indicating what levels of population within specific zones are deemed to be acceptable in terms of radiological risk in the event of a major accident
The NPS should give strong and detailed indicative generic guidance on emergency planning policy and procedures. This guidance should require from the developer the provision of adequate and intelligible information for the general public and from the relevant authorities a plan of coordinated rapid response together with an implementation plan.
BANNG finds the generic guidance in the NPSs relating to demographics and emergency planning confusing, contradictory and lacking in depth or sufficient detail. The Government should consider reviewing these issues in order to provide the IPC with suitable and implementable guidance.
Question 7 Do you have any comments on any aspect of the draft Overarching
National Energy Policy Statement not covered by the previous questions?
In this first part of our submission we have identified some of the key reasons why we feel the draft NPSs relating to nuclear energy should not be designated. There are a number of other generic matters, for example, socio-economic issues where we feel the guidance is partial reflecting the general bias towards nuclear energy that is evident throughout the documentation. There are also some more technical issues, for example, the need for cooling water, where we feel the guidance is inadequate and needs to be strengthened. We shall look at these and other issues in the specific context of the Bradwell site in Part 2.
It will be clear that BANNG does not regard the NPSs as providing a sufficiently coherent or practical framework for the IPC to assess planning applications for nuclear power stations. We consider the consultation process leading up to and including the NPSs was deeply flawed, biased and unfair. Local communities, groups and citizens who wish to participate are disadvantaged in the time, expertise and resources they are able to devote to responding to the consultation. This imbalance is reflected in the overly pro-nuclear bias in the documentation. In substance the NPSs reflect a process that is hurried, incoherent and unintegrated. The nuclear NPSs have limited the decision to ten sites with a requirement on the part of the IPC to deliver as many of these sites as possible. The NPSs provide a post hoc rationalisation of choices already made for pragmatic reasons. They are flawed documents reflecting a flawed process.
BANNG concludes that the draft NPSs on nuclear energy provide a passport for the nuclear industry to build new power stations on existing sites. As a framework for guiding the IPC the NPSs must be regarded as unfit for the purpose of taking fair, balanced and measured decisions on the location of new nuclear power stations.
Part 2 Draft National Policy Statement for Nuclear Power
In this second part of BANNG’s response the focus is on EN-6 and particularly the Bradwell site. In our earlier consultation responses we have provided evidence and arguments covering a range of issues which, in our judgement, indicate that new nuclear development at Bradwell would be irresponsible and unacceptable. We request that these earlier responses are considered as part of a cumulative set of arguments against the Bradwell proposal. This response is intended to demonstrate why EN-6 does not provide an appropriate framework to guide or direct the IPC in deciding planning proposals for new nuclear stations. In particular it argues why the Bradwell site is unsuitable.
Question 16 Do you think that the Government should formally approve
(‘designate’) the draft Nuclear National Policy Statement?
No, we do not think EN-6 should be designated for reasons similar to those expressed in relation to EN-1 in answer to Question 1. In the context of Bradwell there are reasons both of process and of substance why designation should not proceed. We consider the inadequacies of the consultation process in answer to the next question. Below we summarise the substantive reasons why approval should be withheld using the Bradwell example to support our views.
· High level radioactive waste could be stored on site for 160 years or more. DECC hopes that by then a national repository will have been built elsewhere to accommodate this. This cannot be guaranteed.
A new, more powerful nuclear power station would require far more cooling water from the relatively narrow, shallow Blackwater estuary than the previous station. This would result in serious damage to marine ecology and impact on important fishing and oyster industries.
There may not be sufficient cooling water for one station let alone for the two or three which have been suggested by one nuclear operator. Cooling towers would be necessary.
The location for this massive nuclear complex, next to the old, partly decommissioned power station, is a vulnerable low lying site which must be securely protected for 160 years against increasing threats which include rising sea levels, flooding, storm surges and tsunami.
The Bradwell site is close to considerable population including Mersea Island (8000 rising to 15,000 in the holiday season) only 4km downwind. Within 25km is a very substantial population including the large towns of Colchester and Clacton. In the event of a major emergency it would prove impossible to evacuate people, particularly those living on Mersea Island with only one access road.
Any economic benefits arising from employment in construction and operation of a new nuclear power station at Bradwell would be restricted to the southern part of the estuary. Elsewhere, a prominent nuclear complex, oppressive and dangerous, would create disbenefits resulting from a decline in major employment in the valuable tourism, holiday, sailing, fishing and oyster cultivation industries around the Blackwater estuary. We consider it is that research should be undertaken to quantify the economic and social impacts of a new nuclear power station on communities throughout the estuary
These and other reasons for not approving Bradwell are discussed in greater detail later.
We maintain that the Draft NPS EN-6 and associated reports for nuclear power justifying the Bradwell site are superficial and biased. They omit relevant facts which would have been known to competent authors and make claims of reasoned judgement when none is evident. This leads us to the view that there is a bias intended to guide the IPC to accept a site which should not have been assessed as suitable for inclusion.
BANNG considers that EN-6 should not be designated and that the Bradwell site should not be listed.
Question 17 Does the draft Nuclear National Policy Statement provide the
Infrastructure Planning Commission with the information it needs to
reach a decision on whether or not to grant development consent?
No. As should be clear from our answers to Questions 1-4, BANNG is concerned that the information presented does not reflect a balanced, comprehensive or fair appraisal of the evidence on the need for new nuclear or the imperative for locating new stations on highly vulnerable sites. Moreover, BANNG is concerned that the Government has not sought to legitimate its decisions through a proper, searching and democratic engagement with those populations most affected by its proposals. The Government’s process of consultation on the Draft Nuclear NPS cannot by any standard be deemed to be open and effective. It has failed to identify the main differences between the operation of new nuclear power stations and the operation of existing nuclear facilities and it has failed to draw sufficient attention to the proposal to store highly radioactive wastes on sites for a period far exceeding the lifetime of the power stations.
In the first part of this response we described the consultation process as ‘unfair’ and ‘seriously flawed’. We concluded it does not support an equitable framework within which the IPC can take decisions on new nuclear power plants. In this part we reaffirm this conclusion by presenting a perspective on the consultation process as experienced at the local level for the Bradwell site.
The process has been flawed at every stage. Most importantly, the focus has been on the new power station for generating electricity. There has been no effort to distinguish or emphasise the accompanying proposal to store highly radioactive spent fuel and intermediate wastes on site at Bradwell for around 160 years. The failure to consult separately on this should itself render the consultation process invalid. When the issue of on-site storage of radioactive wastes was discussed at meetings, it was members of the public who raised it, not the representatives of British Energy or the Department for Energy and Climate Change.
The consultations on the Bradwell proposal have, so far, been through five stages, each of which is examined below.
Stage 1 British Energy ‘Roadshow’
During November, 2008, British Energy took a ‘Roadshow’ to communities around the Blackwater estuary. The aim was to inform people about proposals for a new nuclear power station at Bradwell and to consult them on the proposals. Attendance at these meetings was low due to lack of awareness, inconvenient timing and the apparent requirement for pre-registration. The large towns of Colchester, Chelmsford and Clacton were not included although they have a legitimate interest in what happens at Bradwell. Audiences at Tollesbury and West Mersea expressed a great deal both of hostility to the idea of a new power station and of scepticism at British Energy’s claim that the chances of an accident were ‘vanishingly small’. Other concerns included the storage of spent fuel well into the next century on such a vulnerable site; evacuating Mersea Island in the event of an accident; the deleterious effects on the Colchester Native Oyster industry and the marine ecology; and health issues. Those attending clearly did not trust the nuclear industry. Local communities had been led to believe that the old nuclear power station would be decommissioned and the site returned to greenfield within 25 years and were now being informed that not only would decommissioning take around a hundred years but that the site would be occupied by new nuclear activities, including radioactive waste management, for an indefinite period.
Stage 2 Consultation on Strategic Siting Assessment criteria
BANNG made a substantial and well informed response to the SSA consultation. The response drew attention to many problems with the criteria, particularly demographics, flooding and coastal processes. In the Government’s response to the consultation (DECC, 2009a) scant attention appears to have been paid to these criticisms and none at all to the critique of the demographics criterion (see answer to Questions 5 and 6 above). This stage of consultation was experienced as ‘top down’ with little attempt at any interaction with respondents. It was neither open nor transparent.
Stage 3 Consultation on Justification
Athough little effort was made by Government to draw attention to this very important issue BANNG made a substantial and well informed response to the Justification consultation and, along with several other groups, called for a Public Inquiry into whether the health detriments from new nuclear practices in the form of new designs of nuclear power stations could be justified in term of benefits. We are repeating this call in our response to the consultation on the Draft Decision on Justification. Unfortunately, the Secretary of State’s Draft Decision indicates that little attention has been made to the call for a full and open debate. Once again, the experience was of a top down, uncommunicative, closed and non transparent process. BANNG is concerned on two counts. One is the lack of effort to engage stakeholders and the public in discussion of Justification. Instead it has been portrayed as a technical and inaccessible process confined to the realm of expertise. The other is the separation of Justification from the siting assessment and NPS processes. In BANNG’s view the separation diverts attention from Justification which is integral to the process of new nuclear development (see Environmental Law Society, 2010, on this point).
Stage 4 Consultation on Nomination of Sites
The ‘Have Your Say’ consultation on the nominated sites lasted only one month during April/May 2009. Again, BANNG made a substantial and well informed response, reminding government of its responses to the SSA and Justification consultations. Once again, scant attention was paid to this. The tight time frame for response, the restrictive structure of the template for responses and the depth of knowledge assumed or required and the lack of time available are known to have been a major deterrent for many people.
Stage 5 Consultation on the NPSs
We present here the local experience of the consultation events in the form of a travelling exhibition and public meetings for each nuclear site which are part of the current NPS consultation. ‘The Government wants to hear your views’ was the claim for these events, but few members of the population knew about them, resulting in low attendances. There were 52 members of the public at the meeting in West Mersea and only 28 at Maldon. Residents at Bradwell have complained in the press that they were denied a consultation meeting even though they would be most affected. There was no exhibition or public meeting at other arge entres such as Colchester which is closer to Bradwell than Maldon. A show of hands at the West Mersea meeting showed that only 3 people out of the 52 attending had received a DECC leaflet advertising the exhibitions and meetings. DECC claim 11,000 of these were distributed door to door. Concerned about the lack of publicity, the Mersea Island Courier (4 December, 2009) included an article by BANNG informing readers of the exhibition and public meetings and the Editor took it upon himself to publish a DECC leaflet. While petitioning outside the exhibition in Maldon on 11 December, the Secretary of BANNG discovered almost everyone she spoke to knew nothing about the event or the public meeting. She directed members of the public to the exhibition, otherwise there would have been very few attending.
Despite the inconvenient timing (a weekday lunchtime), those who attended the meeting in West Mersea were keen to press home their objections to the proposed new power station. Among the points made by those attending, were that a massive nuclear power station, and possibly up to three, would create a major industrial complex that would totally transform the landscape, ecology, economy and amenity of the Blackwater estuary. More than that, such a project imposed high risks and potential dangers threatening the security and safety of many thousands of people within a short distance of the power station. In the event of a major incident, it was doubted that emergency planning procedures would be able to cope with evacuation of the population. The shallow Blackwater estuary could hardly cope with providing cooling water for one of these giants, let alone two or three, for which cooling towers would be necessary. The threat to fishing, oysters, the tourist trade and, indeed, the well-being of the Blackwater community would persist over many generations. Bradwell was among the most vulnerable sites and the idea of highly radioactive waste being safely managed 160 years hence was frankly incredible. Athough the meeting was ably chaired, questioners were not generally given an opportunity to query the response given to them with the result that few of their questions were satisfactorily answered.
Similar questions were raised at the meeting in Maldon and again virtually none were satisfactorily answered. Several pointed out that without the approach from BANNG outside the previous day’s exhibition they would not have known about the meeting. Once again this could hardly be described as a satisfactory consultation.
As we observed earlier in part 1, the brief period for consultation on the NPS, the quantity of the material needing to be read and understood, and the difficulty in obtaining the material, has made it extremely difficult for many people to participate. We are most concerned that people will not have realised the importance of the NPS becoming designated until it is too late to influence the decision.
BANNG reaffirms its answers to Questions 2 and 3 that the consultation process is seriously flawed and unfair presenting considerable obstacles to effective participation by local communities and citizens. As a result the NPSs present an imbalanced, partial and biased view of the evidence for new nuclear power stations on specific sites. They do not provide the information the IPC needs to reach decisions on whether or not to grant planning consent.
In order to achieve greater public confidence in the consultation process, BANNG urges the Government to undertake the following actions:
A new consultation process that effectively engages with the community in an open, transparent, equal and interactive way
Integration of the consultation processes for the NPSs and Justification
A separate consultation on the proposals for on-site long-term storage of radioactive wastes
Question 18 Does the draft National Nuclear Policy Statement provide suitable
direction to the Infrastructure Planning Commission on the need and
urgency for new nuclear power stations?
No. Please refer here to our answer to the similar Question 4. We wish to make two further observations here. The first concerns Justification. While BANNG takes no position on the issue of need for nuclear energy it is very concerned that far too much emphasis is given to the urgency for nuclear energy at the expense of other important social and environmental considerations. In our response to the consultation on Justification we presented evidence on economic and social detriments, on environmental impacts and on risks of radioactive releases in conditions of rising sea levels which indicated that proposals for new nuclear power stations on vulnerable coastal sites could not be justified (BANNG, 2009a). We stand by that view and urge a more measured decision making process that provides a more balanced assessment of the benefits and detriments.
Our second observation relates to siting strategy. In our answer to Question 4 we drew attention to a siting strategy which is both vague and specific. It is vague in the sense that the number, timing, and siting preferences are left to the market so that there is no idea what contribution, if any, nuclear will make to the future generation of electricity. It is specific in that the IPC is directed to consider only ten sites allowing no scope for consideration of alternatives either in terms of assessing sites elsewhere or evaluating alternative means of providing electricity. We consider the approach is too directive.
BANNG reiterates its view that the NPSs place too much stress on the urgency for new nuclear energy at the expense of measured consideration of the important adverse impacts and other detriments that may be inflicted on particular environments. Consequently the NPSs do not provide suitable direction to the IPC.
Question 19 Do you agree with the Government’s preliminary conclusion that
effective arrangements will exist to manage and dispose of the waste
that will be produced by new nuclear power stations in the UK?
BANNG categorically disagrees with this statement. We consider it emanates from a wilfully misleading interpretation of policy and is, at best, speculative. Along with others we have reiterated this point but the NPSs continue to assert the view that the problem of radioactive waste will be solved.
A feature of the new nuclear power stations is that spent fuel will remain in storage on site and is likely to remain there a hundred years or so after shut down. Although radioactive wastes are covered in EN-1 (including Appendix G), EN-6 and elsewhere in the documentation (DECC, 2009 c and d) the emphasis is on the positive benefits of power generation rather than the negative disbenefits of the waste that inevitably accompanies it. As we have shown earlier, from experience of the consultation so far, it is evident that the public, local communities and some politicians, including MPs, are unaware that the proposals are as much for long term management of highly active wastes as for a nuclear power station.
In the NPSs it is conceded that wastes may be stored on site for a period of around 160 years (DECC, 2009c. p.24). In its earlier responses BANNG pointed out that if a series of reactors were built at a location the period of storage would be further extended. In the absence of a long-term solution, the wastes could be stored on site indefinitely. It may be argued that the sites for new nuclear power stations are, de facto, also long terms nuclear waste management facilities persisting for at least eight generations. To put this in the context of Bradwell, the site becomes by default both that of a nuclear power station and a high level radioactive waste store, upon which no evaluation of risks or local consultation or acceptance has taken place, and wastes therefore, may well have to be stored indefinitely on a coastal site increasingly liable to inundation.
The Government claims that it ‘is satisfied that effective arrangements will exist to manage and dispose of the waste that will be produced from new nuclear power stations’ (DECC, 2006c, p. 25) and that the IPC will not need to consider this question. The statement is misleading for three reasons. First, the long-term solution of disposal recommended by the Committee on Radioactive Waste Management (CoRWM, 2006) and accepted by government (Defra, 2008) required an intensified programme of research and development before disposal could be implemented. This programme has not yet been undertaken. Second, a suitable site for a repository would need to be found using the principle of voluntarism, that is an expressed willingness of a community to participate in a site selection process. Although some interest has been shown, no community has, as yet, agreed to such participation. Third, the recommendations applied only to legacy not to new build wastes. New build would create more wastes over an indefinite time period and raise different issues to legacy wastes which already exist and, therefore, are unavoidable. Among these issues are technical aspects such as the methods of storage and the management of high burn-up fuel which are not addressed in the NPSs. CoRWM was clear that any proposals for new build wastes would require a new process which ‘will need to consider a range of issues including the social, political and ethical issues of a deliberate decision to create new nuclear waste’ (CoRWM, 2006, p.14). Yet, in the NPS, new build has been conflated with legacy wastes in terms of meeting scientific and social requirements and, moreover, it appears that no separate process will be required to test and validate its proposals for managing waste from new build.
As for the communities near the ten potential sites selected for new build, they are having highly radioactive waste stores imposed on them for an indefinite period without being able to challenge the government’s interpretation of policy. CoRWM was clear that its recommendations on voluntarism ‘must be applied to new central or major regional stores at new locations if they are to inspire public confidence’ (CoRWM, 2007, p.10). As it stands, communities hosting spent fuel stores will be given no opportunity to consider whether they wish to volunteer to host a long term radioactive waste facility. In the absence of an acceptable method or site for disposal, these wastes may remain in store indefinitely on sites that by the end of the next century are increasingly likely to be inundated by rising sea levels and storm surges.
While public support in general for nuclear power changes over time, there is consistently a large majority concerned about the risks associated with all nuclear wastes. It is fair to say that local communities’ opposition to new nuclear power stations is considerably strengthened and reinforced by proposals for on-site nuclear waste storage facilities. It is recognised that risks continue into the far future and will impose burdens of cost, effort and risk on many future generations. The lack of concern about intergenerational equity issues in the NPS proposals is very striking. In the urge to create power stations for the present, the interests of the future are neglected.
On the issue of radioactive wastes, BANNG considers the NPSs flawed for the following reasons,
· There is little emphasis given to the fact that new nuclear power stations will be accompanied by long term on-site storage of highly active nuclear wastes which is a matter for public concern
· Long term on-site storage of wastes from new build raises distinctive technical (including handling high burn up fuel), social and ethical issues that are not addressed in the NPSs
· Despite the Government’s assertion, satisfactory arrangements for the effective long term management of new nuclear wastes do not yet exist and there is no evidence that they will do so in the near future
· Local communities around the listed sites have not been offered the opportunity to consider whether they wish to volunteer to host a long term highly active waste storage facility
· Little consideration has been given to the risks imposed on the far future which will be exacerbated by locating waste stores on sites vulnerable to inundation and coastal change
For these reasons BANNG does not agree that effective arrangements will exist to manage and dispose of the radioactive wastes from new nuclear power stations. Therefore,
We urge the Government
a) to undertake a separate consultation process on the management of new build wastes
b) to apply the principle of voluntarism thereby enabling communities to decide whether they are willing to host long term radioactive waste management facilities
Question 20 Does the draft National Nuclear Policy Statement appropriately cover
the impacts of new nuclear power stations and potential options to
mitigate those impacts?
No. Please see the extensive answer given to Question 6 which applies also to this question. In sum, BANNG has two major concerns in relation to impacts and mitigation. One is that we do not feel impacts are appropriately covered. This partly results from the vagueness of definitions inherent in the SSA criteria which we have covered earlier. We also feel that coverage of impacts is inappropriate or poorly defined. Much is left for later determination during the consenting process. As we have pointed out this is far too late. Some matters such as flooding, emergency planning and adverse impacts on ecosystems require clearer and more detailed definition applicable to all sites prior to adoption of the NPSs.
Our other major concern is the inadequacy of the NPSs in respect of mitigation measures. The NPSs provide little guidance as to what may be acceptable and what is not. Mitigation may be required beyond 100 years in conditions of increasing environmental uncertainty at many of the coastal sites. Moreover, the use of IROPI blatantly favours development over conservation and assumes that mitigation will either cope with or compensate adverse impacts in all cases. BANNG considers the NPSs will encourage irresponsible and unethical decision making in facilitating nuclear development whatever the uncertainty and whatever the cost or risk imposed on future generations.
BANNG considers that impacts and potential mitigation measures are not adequately covered in the NPSs and that much clearer and more detailed guidance on what conditions would rule out development of new nuclear power stations is required before the statements are adopted
The application of Imperative Reasons of Overriding Public Interest (IROPI) should not be used as a means to justify new nuclear power stations at all cost. It should also be invoked to ensure protection of strategically significant environments.
Question 21 Do you agree with the Government’s preliminary conclusion on the
potential suitability of sites nominated into the Strategic Siting
We refer here to sub-sections, a), b) and l) of this question.
a) General comments
Our comments relating to site selection have been expressed under Question 4. Throughout our response so far we have made comments relating to the potential suitability of sites. For the reasons we have already given,
BANNG does not agree with the preliminary conclusion that the sites nominated under the SSA are potentially suitable for new nuclear power stations.
In response to earlier questions we have already indicated a series of key reasons why we consider Bradwell to be a totally unsuitable site. In particular we would emphasise vulnerability to flooding, long term (indefinite) storage of highly radioactive wastes on site, impact on marine ecology, proximity to substantial population and problems of emergency planning. We have covered these in depth in earlier submissions to consultations and earlier in this submission. Here we provide a detailed analysis of reasons why, in our view, Bradwell must be rejected.
We set out our reasons under the criteria presented in relation to Bradwell in section 5.6 (pp. 62-81) of EN-6. Given the way in which the consultation has been set up it is necessary to cross refer to other parts of this response in order to gain the full impression of our objections to Bradwell.
Please refer also to our comments on demographics and emergency planning under Questions 5 and 6. The demographics assessment suggests the site meets semi-urban criteria but fails to take account of the transient holiday populations, such as the large numbers in the caravan and camping sites on Mersea Island and around the estuary during the summer. There is also no consideration of the potential risks posed to substantial urban populations within 30 km, including Southend, Chelmsford, Colchester and Clacton.
As EN-6 recognises (p.62) it will be difficult to evacuate Mersea Island in the event of an incident at a future power station. Evacuating the 8,000 residents of Mersea Island only 2 miles downwind could be impossible, since there is only one access road to the Island and this is blocked for several hours at periods of high tide levels. In addition the transient but substantial summer population of day visitors and longer term tourists in caravans and tents would need immediate evacuation under nuclear emergency planning, as in the Sizewell off-site emergency plan. This applies to people without the shelter of permanent buildings in the event of an incident. Consequently, it is difficult to understand how a planned evacuation of the island could be arranged safely. If the public was advised to remain on the island during an emergency it is possible many would attempt to leave in anticipation of an incident worsening or of being cut off by the tide.
Other communities around the estuary such as Tollesbury also have restricted access roads which could make evacuation very difficult.
Another concern, as outlined following exercises by the Government Nuclear Emergency Planning & Liaison Group, which simulated the crash of an aircraft on the old Bradwell site, is that site emergency plans refer only to credible accidents, and not to outcomes of deliberate acts such as those of terrorism. As we indicated earlier we consider the guidance on emergency planning provided in EN-6 to be totally inadequate. It is not good enough to leave this entirely for later consideration (DECC, 2009cp.63).
BANNG considers that emergency planning procedures must cover all possible eventualities including terrorist attack. Local populations have a right to expect plans for their safe evacuation to be a prerequisite for site acceptability, not merely a subject for later consideration by an applicant.
D1 Flooding Storm Surge and Tsunami and D2 Coastal Processes
Please refer to earlier answers to Questions 5 and 6. The majority of the Bradwell site is in flood zone 3, high probability . Earlier we quoted the Environment Agency’s tentative conclusions on flood protection and mitigation given on p. 66 of EN-6. In our view the EA needs to explain what it means when it says that ‘it is potentially reasonable to conclude that a nuclear power station [and, we would add, waste storage facility]……..could potentially be protected against flood risks throughout its lifetime’ (our emphasis). Potentially reasonable is not yet reasonable. It is, therefore, unreasonable to make this claim.
BANNG totally rejects the subsequent interpretation of this view expressed on p.67 that makes the unsubstantiated jump to ‘it is reasonable to conclude that a nuclear power station could potentially be protected against flood risks through its lifetime, including the potential effects of climate change, storm surge and tsunami’ (our emphasis). Given that it is clearly impossible to predict with any confidence the effects of coastal change over such a long timescale, or the ability of agencies to reliably protect the site over such long timescales, we find these claims unreliable.
BANNG demands that any site approved for nuclear power or a nuclear waste operation be guaranteed safe for life prior to site approval.
At the West Mersea DECC presentation on Dec 10 2009, Peter McDonald of DECC advised that climate change projections up to 2100 have been used and that assessments beyond this would be dependent on a regular cycle of reassessments, probably every 10 years, throughout the life of the station. This is most unsatisfactory since the Government accept that there may well be operations continuing on site well beyond 2100, up to and beyond 160 years, possibly up to the end of the 22nd century. Given current uncertainty on climate change effects and the consequent lack of 160 year projections, it is therefore possible that the Bradwell site may become unsustainable far earlier than its potential projected lifetime.
BANNG considers it unethical to proceed with the Bradwell site under these circumstances.
D6 and D7 Internationally and Nationally designated sites of ecological importance
Please also refer to answers to Questions 5 and 6 and to later response on access to cooling water. The whole of the Blackwater estuary neighbouring the site, except for the pleasure beaches of Mersea Island, is designated SAC, and all the intertidal mudflats, with the above exception, are designated SPA, RAMSAR and SSSI sites. A large proportion of the intertidal mudflats are also designated NNR. The proposed complex is surrounded by these sites. Cooling water would be obtained from and returned to these areas.
The industrialisation of this area of international ecological importance with reactors, radioactive waste stores, cooling towers and pylons will prejudice those designations. RAMSAR sites in England are protected as European sites, as set out in the Conservation (Natural Habitats, &c.) Regulations 1994 (as amended). The proposed site and adjoining RAMSAR wetlands are important habitats for birdlife which may be affected. These sites are an important example of natural or near-natural wetland type found within the bio-geographic region.
BANNG notes that the Statement says is not possible ‘to rule out adverse impacts on sites of European Nature Conservation Importance’ (p.71). BANNG does not believe that, ‘there is an imperative reason of overriding public interest that favours the inclusion of this site…..despite the inability to rule out adverse effects on European sites at this stage’ (p.71). On the contrary, BANNG considers there is an IROPI why these important international designations should be protected against the degradation that will inevitably arise from the construction of an intrusive, disruptive and disturbing nuclear complex. We consider that the reasons which rule out Dungeness from further consideration should also apply to Bradwell.
BANNG considers this issue alone is enough to warrant the site being excluded from further consideration.
D8 Areas of amenity, cultural heritage and landscape value
A new nuclear power station or stations at Bradwell 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’ (BANNG, 2008, p.12).
It is worth reiterating that Bradwell is not an operational site and that it was intended to clear the site within a relatively short period. Instead, financial constraints and technical reasons have been given as reasons for the site not being finally cleared for around a hundred years. In addition it is proposed to build one or more new power stations on the site thereby increasing the scale of visual and environmental impact and lengthening the period of occupation of the site. In addition to the reactor buildings and facilities for radioactive waste, new and bigger transmission towers will be required and, depending on the number of reactors and limitations on water abstraction, it may be necessary to erect cooling towers.
BANNG is very concerned about the overall impact of the proposed new power station and associated infrastructures on the amenity of the Blackwater estuary. This is an area of passive recreation and attracts large numbers of campers and caravanners during the holiday season. BANNG believes that the noise from construction and the visual intrusion during construction, operation and decommissioning of any new build station, together with the presence of the old station will destroy the amenity of the tranquil and beautiful Blackwater estuary. Accordingly,
There should be a presumption against the development of new nuclear facilities at Bradwell on the grounds that they will adversely affect the existing land and water uses, amenity and cultural heritage of the Blackwater estuary.
D10 Access to suitable sources of cooling
Many fish, larvae, eggs, spawn and other forms of marine life are killed by the intake of power station cooling water. Larger fish are trapped and killed on filter screens which are designed to prevent them passing through the cooling system, while larvae, eggs, spawn and smaller fish pass on through the system and the sudden heating of the water during this process kills them also (Henderson).
The DECC round of displays and consultations have totally failed to inform the population of the major differences in the negative effects from a new power station’s cooling system when compared to the old one. The Blackwater is a relatively shallow and narrow estuary and this limits the availability of the huge amounts of cooling water required by a nuclear power station. The old Bradwell power station of 242 MW required an average of 1.88 million tons of cooling water per day (British Energy). At frequent intervals the cooling system also had to be treated with chlorine to prevent a build up of marine growth, thus keeping it clear of obstructions. These actions are known to have had an adverse effect on the fish and oyster numbers in the estuary. For example, West Mersea oystermen know that the foreshore and sea bed on the Bradwell side of the estuary became completely sterile and barren, with the ground very bleached, for one and a half miles either side of the cooling water inlets and outlets. At the time the nuclear operator denied responsibility for this. Colchester Native Oysters also disappeared from the northern shore of the Bradwell coastline. Six months after the closure of the power station in 2002 this coastline began to regenerate, with new growth appearing along with new oysters.
During the operating life of the old power station the cultivation of native oysters could only be maintained by importing seed oysters from elsewhere around the UK coast. Today by contrast, the oyster industry is healthy and sales are increasing, with none normally imported because stocks have been rising along with employment. The total weight of oyster sales reported by fishermen from West Mersea is now approximately 296 tons per annum and increasing, whereas15 years ago, sales were approximately 100 tons per annum. This example appears to confirm that marine life suffered during the lifetime of the old power station.
A new EPR power station of 1.65GW will require 6.22 million tons of cooling water per day, over three times the volume required by the old reactor. This volume represents 10% of the total estuary volume of exchange water each tide. Temperature rises of up to 100C are forecast on the south shore in the vicinity of the power station, with a 10C to 20C increase elsewhere. This rise in temperature in the River Blackwater is likely to have a much greater impact on its ecosystem than previously. The larger cooling system will also have to be treated with more biocides to prevent fouling of pipework. These biocides, such as chlorine, sub-react in water to form more complex and potent biocides with increased half-life. Such biocides are likely to further affect the ecosystem on a larger scale than before. The increased volumes and velocity of water will also cause greater scouring of the seabed, resulting in much larger dead areas.
It takes ten days to totally refresh the water in the estuary, a very low refresh rate when compared to the open sea. This low refresh rate, together with one tenth of the estuary daily tidal volume passing through the reactor, means that the incidence of damage from cooling water circulation would be far greater than in the open sea, and far more significant than previously experienced.
The commercial inshore fishing industry and the oyster industry are directly and indirectly important to the local economy. The eco-system of the estuary will be more seriously affected by this development which will in turn affect the local industries dependent upon it. The oystermen and fishermen fear that if a new power station is built, then the larger temperature increase in the estuary might cause a significant increase in the breeding rate of the Pacific Oyster which would not only seriously endanger the relatively fragile Native Oyster, but also threaten other marine species and marine birds in the estuary by causing a fundamental change of the fertile mudflats around the estuary into rocky shores. These mudflats support life forms at the base of the existing food chain.
The waters of the Blackwater and Colne estuaries are the only remaining oyster fishery area in the UK which cultivates the Native Oyster. In other locations they are only dredged. The Colchester Native Oysters are a heritage industry with an international reputation. The Native Oyster has been identified as a species in the UK which needs further protection.
The Blackwater also supports a unique endangered species called the Blackwater Herring which would be vulnerable to greater changes in the ecology of its habitat.
The consequences of the above serious issues do not feature prominently in the NPS, Habitats Regulations Assessment or Appraisal of Sustainability Reports for Bradwell. BANNG has little confidence risks can be mitigated as is implied in the Assessment of Sustainability Report for Bradwell (DECC, 2009e. p.57).
BANNG considers that threats to the marine ecology and therefore the fishing and oyster cultivation industries in the Blackwater Estuary rule it out as a suitable site for new nuclear power stations.
Much of the opposition to any new nuclear reactor at Bradwell, Essex, rests upon continuing anxiety about the past and future health risks to local populations, as attempts to establish the truth about such risks remains very difficult for ordinary members of the public. Many people believe that investigations in the Blackwater area have suggested excess levels of cancer and higher levels of breast cancer mortality arising from the Bradwell power station Busby and Bramhall, 2002). More recently, a reworking of the data on childhood leukaemia in the Blackwater area, following the German KiKK study, indicates a possibility of higher levels of leukaemia among people living close to nuclear power plants than in the population at large (Kaatsch et.al., 2008). BANNG recognises the theoretical and practical problems involved in establishing the nature, incidence and consequence of health risks from nuclear facilities. However, the very complexity of the issue and the suggestive nature of the results of the research indicate that there are real and valid reasons for concern on the part of the public.
There is also mistrust in the nuclear industry’s openness regarding problems and accidents. There are numerous examples. Bradwell provides a recent case. In February 2009 Magnox Southern (at that time the site operator) were found guilty of allowing a radioactive leak at Bradwell to continue for 14 years from 1990-2004 and were fined a total of £400,000 (including £150,000 costs). The leak only came to light during decommissioning work and not as a result of any routine safety inspection and, even then, was not made public for four years. Mike Weightman, Chief Inspector of the Nuclear Installations Inspectorate, said it was not possible for them to ‘check every feature of a complex plant’. Cases like this do nothing to give peace of mind to those living near nuclear installations.
The Government’s view that a nuclear power station would pose very small risks to safety, security, health and proliferation is clearly open to challenge, and therefore, BANNG believes the Precautionary Principle should apply and that any risk should be avoided by not constructing a new nuclear power station and high level waste store.
Socio-economic and Community Effects
EN-6 says that ‘a nuclear power station may also bring alternative economic benefits to a region which could have the potential to offset some disbenefits’(DECC, 2009c, p.79). This claim bears critical examination. It is unclear why the jobs would be especially valuable in a rural area than in, say, a declining industrial area. Nor, if development here is necessary at all, is it clear that nuclear is necessarily the only alternative source of employment; other energy developments, for instance the wind farms developing on and around the Essex coast, might also provide a source of continuing jobs. It might be argued that introducing new nuclear in a rural area could create an economy with an unhealthy dependence on one employer.
BANNG questions the argument that ‘the likely enhancement in employment, community wealth, housing stock and other associated neighbourhood infrastructure should improve community well-being and health generally’(DECC, 2009e, p.42). These benefits may apply in the vicinity of the Dengie Peninsula, but it is extremely unlikely they will apply elsewhere around the Blackwater. Although disbenefits to tourism are recognised in EN-6, it is argued they could well be offset. The Appraisal of Sustainability for Bradwell makes no mention of the potential adverse effects on communities relating to loss of employment in leisure, fishing, oyster cultivation and sailing related industries nor of the possible difficulty attracting new industries to the area. As we have argued in earlier responses the association of nuclear energy with radioactive risk tends to create a negative image and anxiety among the population surrounding nuclear plants. This image is likely to be compounded in the case of new build projects which include spent fuel and waste stores. This may act as a deterrent to inward investment, impact negatively on existing economic activities and create a blighting effect. We consider it is not sufficient simply to assert the benefits of job creation; it is necessary to undertake appropriate research to determine the overall potential economic benefits and detriments.
BANNG considers the detriments to the tourist, fishing and leisure economy and the negative image created by a massive nuclear complex will far outweigh any benefits from increases in employment associated with a new plant.
Bradwell is in an area of seismic risk. A major earthquake occurred in the area in 1884, the “Colchester Earthquake” or “Great British Earthquake”, the most severe reported in this country for over 400 years. Although this was centred south of Colchester near Mersea Island it also caused much structural damage in the Bradwell area. While assurances have been provided that the reactors themselves would be resistant to an earthquake, no assurance has been received about cooling systems, such as pipe-work on the seabed or cooling towers or facilities for storage of radioactive waste. It is unlikely the emergency services could successfully deal with the wide ranging radiological consequences that might occur as a result of an earthquake, especially if it were to be associated with high tide or tsunami.
BANNG is concerned that seismic risk affects the potential suitability of the site.
l) Dungeness – Our views on Dungeness and delisting of that site are presented
under Question 4.
Question 22 Do you agree with the Government’s preliminary conclusion that the
three sites identified in the Alternative Sites Study, are not potentially
suitable for the deployment of new nuclear power stations by the end
Please see answer to Question 4 which provides our criticism of the siting strategy for new nuclear power stations. In sum: the SSA criteria are, in several instances, deficient; the focus on existing locations is too constraining; the lack of viable alternatives to the ten listed sites or alternative options to nuclear is unreasonable and unfair; and the reliance on the market to provide an undefined proportion of nuclear energy results in uncertainty. The three alternative sites out of roughly 270 identified that emerged from the Atkins study as potentially suitable were each ruled out on grounds that they are not deployable by 2025. As with Dungeness, it is clear that these sites might ultimately fail on certain criteria. In the case of Kingsnorth, for example, impacts on designated areas (DECC, 2009a, p.115), problems of cooling water impacts, the low lying nature of the site, density of population and challenges for emergency planning might cause the site to fail the criteria if it were to be further considered. It is noted that these problems at Kingsnorth are not dissimilar to the problems facing the Bradwell site which we have argued should be failed. In BANNG’s view the exercise on alternative sites with its constraint on deployability has simply been a means whereby Government can attempt to demonstrate that there are no alternatives to the ten listed sites.
BANNG is of the view that the Alternative Sites Study was constrained and designed to achieve a specific objective, namely, to demonstrate that there were no alternative deployable sites to the ten listed sites. BANNG deplores this cynical siting strategy. However, we note the similarities between the listed sites and the three alternative sites which question the justification for listing the ten sites.
Question 23 Do you agree with the findings from the Appraisal of Sustainability
reports for the draft National Nuclear Policy Statement?
Question 24 Do you think that any findings from the Appraisal of Sustainability
reports for the draft National Nuclear Policy Statement have not been
taken account of properly in the draft National Nuclear Policy
We have referred to the Appraisal of Sustainability for Bradwell (DECC, 2009e) at several points in our earlier comments. In general, we find the AoS disappointing in that much of the assessment remains to be done at the project stage. This means that the Bradwell site is subject to premature legitimation since relatively little is known on which to base claims of sustainability. Mitigation proposals are entirely unclear and compensation largely undefined. The document does not provide a useful basis overall on which to inform the case for listing the Bradwell site as is repeatedly made clear by reference to further analysis and research.
However, there is much in the AoS that is disturbing and which brings into question the listing of a site that is so environmentally vulnerable. What little work has been done in the Scoping Report undertaken for the former owners, British Energy, also suggests serious problems which are likely, once verified by detailed research, to undermine the case for the site (British Energy, 2008). The general conclusion we take away from these reports is that when it comes to project appraisal Bradwell will fail crucial tests of sustainability. It would be prudent, therefore, to remove the site at this stage.
We have some specific observations on the AoS,
· The report (p.11) fails to recognise the distinction between legacy wastes for which there is a management process and new build wastes for which there is not. We have referred to this issue at various points and argued for a separate process to deal with long-term interim on-site storage under Questions 5, 6 and 19.
· Under Bradwell’s site history, the AoS mentions of a potential PWR at Bradwell (p.14) but fails to mention the proposal, fully supported by the community, to decommission the site and restore it to greenfield status within 35 years (see answer to Question 21 on amenity, cultural heritage and landscape value).
· While Chelmsford 40km from Bradwell is identified, Colchester and equally large and much closer (15km) is not.
· It is noted that the nomination of Bradwell is for ‘at least one nuclear reactor’ (p.14) though the consultation is based on only one reactor.
· It is noted that the nominator for the site ‘does not express a preference for a particular cooling process or cooling water source’ (p.29) thereby recognizing that cooling towers may be necessary.
· It is also noted that the area has ‘a very high level of biodiversity interest’ (p.20) which we have earlier suggested should be an Imperative Reason of Overriding Public Interest for refusing an application for a new nuclear power station.
· It is also noted that the coastal landscape ‘has a strong feeling of remoteness and wilderness’ (p.26) and is ‘one of the most tranquil parts of the South East of England’ (p.27), also powerful reasons for denying permission for such an intrusive and dominating industrial complex.
· It is noted that ‘There is no natural resilience to erosion at the site’ and that it ‘is at risk from tidal flooding from the Blackwater Estuary and coastal flooding from the North Sea’ (p.29), in our view sufficient reason for not proceeding further with this site.
· The AoS identifies ‘a low risk for a significant urban and rural population to be affected by any significant accidental release of radioactive emissions from the Bradwell site’ (p.32). It is also possible that there could be a deliberate release resulting from an act of terrorism. The consequences of such releases are high and could be catastrophic. The AoS makes clear (as the EN-6 does not) that Bradwell is within range of a considerable population, hardly in a ‘relatively remote’ location (p.35). The dangers of exposure to radioactivity and the difficulties of evacuation have been discussed in our answer to Questions 5 and 6 (demographics and emergency planning).
· The section on Biodiversity and Ecosystems in the AoS stresses the potential for adverse effects on sites and species but suggests that mitigation or compensation may be possible. In BANNG’s view (related in answer to Questions 4 and 5) the impacts are sufficiently severe and strategic to rule out the site for a new nuclear power station.
· As we have suggested earlier the section on Communities emphasises potential economic benefits but says nothing about the potentiadetriments.
· We disagree with the argument that people living and working nearby ‘have had a long time to get used to there being an adjacent nuclear plant so this is unlikely to be a problem at this location’ (p.42). BANNG has referred to this issue in its previous submissions and earlier in this response. It may be said that since the plant closed in 2002 people have had time to get used to there not being a nuclear plant. It is our view, supported by considerable evidence from petitioning in the Blackwater area, that the population is overwhelmingly opposed to a new nuclear power station at Bradwell.
· The AoS makes clear the problems of flooding and coastal processes at the site. The report identifies potential adverse effects on water quality, coastal processes and designated habitats arising from the development and thermal impact of cooling water (pp. 46-7). There are also adverse effects from flooding as sea levels rise ‘especially during the later stages of operation and decommissioning’ , and, we might add, the indefinite period of storage of radioactive wastes on site (p.47). In our view the extent of the risk is unknown and, for the far future, unknowable at present. BANNG believes it would be irresponsible and unethical to impose an unknown burden of risk on far future generations.
BANNG considers the Appraisal of Sustainability for Bradwell leaves a great deal of analysis to be undertaken at the project stage. However, the AoS identifies a range of pertinent reasons and risks which have not been properly taken into account in the NPS and which indicate that it would be imprudent and irresponsible to confirm Bradwell as a listed site.
Question 25 Do you have any comments on the Habitats Regulations Assessment
Reports for the draft Nuclear National Policy Statement?
As with the AoS, the HRA for Bradwell provides mainly indicative information leaving more detailed analysis to the project stage (DECC, 2009f). However, there is sufficient indication of strategic adverse effects to suggest a precautionary approach be taken. In BANNG’s view this should mean that the site is not considered further because of the severe damage that is likely to unique and irreplaceable habitats.
We have some specific comments on the Bradwell HRA,
· The site location mentions only settlements on the southern side of the Blackwater estuary. It does not mention West Mersea, the largest urbanised area within 4km of Bradwell, nor Colchester a large town of over 100,000 which is within 15km of the site.
· The report stresses the loss, fragmentation and disturbance of habitat and marine environment through coastal squeeze. Profound changes are already occurring with significant loss of some habitats, notably saltmarsh. These impacts will be exacerbated by a new nuclear power station and will affect bird assemblages of European significance.
· Adverse impacts will arise from routine and accidental discharges of radionuclides; from changes in water temperature from cooling; and alteration of flows (p.12). As the report indicates, there is already potential over-abstraction of water which will be vastly exacerbated by the demands of a new power station leading to a decline in favourable conditions of habitats and important species. BANNG considers this alone to be a key reason for not proceeding with the proposal.
· Coastal protection for a new power station could contribute to coastal squeeze ‘as well as constraining opportunities for adapting to rising sea levels as a result of climate change (such as managed realignment)’ (p.28).
BANNG considers the Habitats Regulations Assessment for Bradwell leaves much to ‘Appropriate Assessment’ at the project stage. However, the potential adverse impacts on habitats and the species they support are of such significance that a precautionary approach is indicated. In BANNG’s view this approach indicates the project for a new nuclear power station should be abandoned.
Prepared by Professor Andrew Blowers for the Blackwater Against New Nuclear Group
(with contributions from Barry Turner, Professor Barry Jones, Varrie Blowers and Charles Clark)
Date 22 February 2010
Atkins (2009) A consideration of alternative sites to those nominated as part of the Government’s Strategic Siting Assessment process for new nuclear power stations, Prepared by Atkins for DECC, November
BANNG (Blackwater Against New Nuclear Group)(2008) Consultation on the Strategic Siting Assessment Process and Siting Criteria for New Nuclear Power Stations in the UK, Response on behalf of BANNG, November
BANNG (2009a) The Justification of Practices Involving Ionising Radiation Regulations 2004, Consultation on the Nuclear Industry Association’s Application to Justify New Nuclear Power Stations, Response to the Consultation from Blackwater Against New Nuclear Group (BANNG), March
BANNG (2009b) ‘Have Your Say’ Government Consultation on Nomination of Sites for New Nuclear power Stations, Response to the Consultation by BANNG, May
BANNG (2009c) House of Commons Energy and Climate Change Committee, Inquiry into Energy National Policy Statements, Evidence on Behalf of the Blackwater Against New Nuclear Group
BERR (2008) Towards a Nuclear National Policy statement. Consultation on the Strategic Siting Assessment Process and Siting Criteria for New Nuclear Power stations in the UK, July
Blowers, A. (2009) ‘Why Dump On Us?’ Town and Country Planning, January, pp. 33-37
British Energy (2008) Proposed Nuclear Development at Bradwell: Environmental Scoping Report, Prepared by Royal Haskoning, Haskoning UK Ltd. Environment, London, November
Busby, C. and Bramhall, R. (2002) ‘Breast cancer mortality and proximity to Bradwell Nuclear Power Station in Essex 1995-1999. Correction and Update to 2001 with a commentary on Official Responses’, Green Audit: Aberystwyth, Occasional Paper 2002/6, December
CoRWM (Committee on Radioactive Waste Management)(2006) Managing our Radioactive Wastes Safely: CoRWM’s Recommendations to Government, November
CoRWM (2007) Moving Forward: CoRWM’s Proposals for Implementation, February
DECC (2009a) Consultation on Draft National Policy Statements for Energy Infrastructure, November
DECC (2009b) Towards a Nuclear National Policy Statement, Government response to consultations on the Strategic Siting Assessment process and siting criteria for new nulear power stations in the UK; and to the study on the potential environmental and sustainability effects of applying the criteria, Office for Nuclear Development, January
DECC (2009c) Draft National Policy Statement for Nuclear Power Generation (EN-6), London, TSO, November
DECC (2009d) Draft Overarching National Policy Statement for Energy (EN-1), London, TSO, November
DECC (2009e) Appraisal of Sustainability: Site Report for Bradwell, Office for Nuclear Development, November.
DECC (2009f) Habitats Regulations Assessment: Site Report for Bradwell, Office for Nuclear Development, November
Defra (2008) Managing Radioactive Waste Safely: A Framework for Implementing Geological Disposal. Defra and Devolved Administrations, CM 7386, June
Dorfman, P. (ed.) Nuclear Consultation: Public Trust in Government, Nuclear Consultation Working Group
Environmental Law Foundation (2010) Inquiry into the proposals for energy national policy statements, Submission by the Environmental Law Foundation to the Energy and Climate Change Committee, January
Henderson, P. Are coastal power stations affecting Northern European inshore fish populations? Pisces Conservation Ltd.
P. Kaatsch, C. Spix, R. Schulze-Rath, S. Schmeidel and M. Blettner (2008), ‘Leukaemia in young children living in the vicinity of German nuclear power plants’. International Journal of Cancer, Vol. 122 (4), 15 Feb., 72
NCG (Nuclear Consultation Group)(2008) 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 NCG, November
NCG (2009) Consultation on the Nuclear Industry Association’s Application to Justify New Nuclear Power Stations, Response from the NCG
Roche, P. (2009) Consultation on draft National Policy Statements for Energy Infrastructure Edinburgh Energy & Environment Consultancy, December 2009
TSO (2009) The UK Low Carbon Transition Plan, July
Consultation on draft National Policy
Statements for Energy Infrastructure
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