PLANNING FOR NEW ENERGY INFRASTRUCTURE
CONSULTATION ON REVISED DRAFT NATIONAL POLICY STATEMENTS FOR ENERGY INFRASTRUCTURE
RESPONSE OF THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)
Our Approach to this Response
This response is based on a careful reading of the voluminous documentation supporting the Government’s reconsideration of the NPSs. We have noted the changes made since the first consultation and the Government’s response to the first round of responses made by ourselves and others. We have considered the specific issues applying to Bradwell but also the wider context as it relates to the Bradwell site. Our response is not set out in terms of the three formal questions posed in the Consultation Document (DECC, 2010a, pp. 7-8) since we feel this would fragment our arguments and make them too repetitive. Rather, we have focused on the three key issue areas affecting Bradwell, namely: demographics and emergency planning; climate change and the management of radioactive wastes; and impacts on the estuary and environment. We shall also cover other relevant matters, notably socio-economic impacts and health issues which have generic as well as site-specific importance.
The Blackwater Against New Nuclear Group (BANNG) has already responded in detail to a range of Government consultations on new nuclear energy (see list at Annex A) and has presented oral and written evidence to the House of Commons Select Committee on Energy and Climate Change. We consider each of our previous responses to contain information and issues relevant to this current consultation. Our responses on site selection assessment, nomination of sites and the original consultation on the Nuclear Policy Statements carry our considerations and conclusions on the Government’s proposals especially as they impact upon the Bradwell site. We, therefore, wish our earlier responses to be taken into account. In particular our substantive response to the previous round of consultations on the NPSs contains our objections to the listing of Bradwell and constitutes our substantive response to this present consultation also. It should, therefore, be read in conjunction with this response. Therefore, this response is to be seen as additional and complementary to and not a replacement or substitute for our previous response.
BANNG Petition shows overwhelming opposition to the proposals (see also Section 2.0 below)
The BANNG Petition contains around 10,000 signatures gathered in face-to-face encounters with members of the public. The Petition reads as follows:
We, the undersigned, wish to express our strong opposition to the construction of a new nuclear power station at Bradwell and the storage of highly radioactive waste on site.
We, therefore, demand that the Government reject this proposal.
Further, we demand that the site of the former Bradwell power station be returned to greenfield status within 25 years of closure as proposed by the Nuclear Decommissioning Authority.
The majority of the petitioners come from the area surrounding the Blackwater estuary but there are also signatures from citizens living in other parts of Essex or further afield with ties to the Blackwater. This Petition is a real survey expressing their concerns the new nuclear proposals and has been gathered directly through face-to-face conversation with individual members of the public. Our experience has been that the signatories are overwhelmingly opposed to the proposals. This Petition will be presented to the Minister for Energy and we wish it to be taken into account as evidence of a widespread public opposition to the proposals for a new nuclear power station and waste stores at Bradwell as part of our submission.
1.0 Inadequate Consultation
We wish first to make follow up comment on the nature and adequacy of the consultation process and its implications for public confidence and the planning process.
The response made by the Government to the first consultation (DECC 2010f) fails fully to acknowledge and to accommodate the widespread criticisms of the initial consultation processes with the result that the re-consultation as a whole continues to be seriously flawed. Such a lack of responsiveness suggests that the re-consultation is little more than a ritual exercise.
In our response to the previous consultation on the NPSs we made a number of criticisms of the consultation process (BANNG, 2010a pp. 3-6). Our experience was that it was too burdensome, too fast and fragmented, not participative and biased and unfair. We concluded that the process was ‘seriously flawed and does not provide a balanced evidential basis for decision making by the IPC’. We urged that ‘a new and more participative process should be undertaken in an effort to ensure public confidence in Government decision making’ (p.6). In a parallel response to the Inquiry into the Energy NPSs by the House of Commons Select Committee on Energy and Climate Change we made similar points in reference to the specific Bradwell experience. ‘The brief period allowed for consultation on the National Policy Statement, the quantity of material needing to be read and understood, and the difficulty in obtaining the material, has made it once again extremely difficult for many people to participate. We are also concerned that most people will not have realised the importance of this NPS becoming accepted until it is too late to influence the decision’ (BANNG, 2010b, p.5). The Select Committee recognised the inadequacy of the process and reported as follows: ‘We recommend the Government learns from this experience and for future NPSs considers more innovative ways, particularly with regard to greenfield sites, in which it can engage the public in these important documents’ (House of Commons, 2010).
Sadly, the lessons have not been learned. From our experience as an interested but voluntary Community Based Organisation this consultation has been even less helpful, accessible and participative than the first. Our previous criticisms still stand.
Too burdensome. In introducing the consultation, the Consultation Document invites ‘interested parties to focus their responses on those aspects of the policy that have changed and on any aspects which they think should change in the light of the revised AoSs, or any relevant change in circumstances since the previous consultation’ (DECC, 2010a, p.2). Put bluntly, this is an obtuse and unhelpful suggestion. Although the most significant changes (reconsideration of alternatives, need for infrastructure, potentially suitable sites) are identified in various documents, these are complex issues which run through the documentation as a whole. It is impossible to disinter the changes that have been made – some substantial, some minor, some interpretive – without considering the whole panoply of material that has been revised and re-presented. A close inspection of each of the documents reveals considerable and sometimes significant changes, which would be missed by the light touch focus recommended in the Consultation Document.
In the case of Bradwell, the volume of material that it is necessary to sift through is formidable. The key documents include: the Consultation document (DECC 2010a, 39 pages); EN-1 (2010b, 120 pages); EN-6 (DECC, 2010c, 36 pages, plus Annex A 12 pages, Annex B 6 pages and Annex C relating to Bradwell, 31 pages); the Habitats Regulations Assessment Report for Bradwell (DECC, 2010d, 49 pages); Appraisal of Sustainability for Bradwell (DECCe, 66 pages); Government Response to the first consultation relating to Bradwell (DECC, 2010f, 14 pages), a total of 371 pages which require detailed attention. In addition there are the main reports on the Appraisal of Sustainability (DECC, 2010g), 135 pages) and the Habitats Regulations Assessment (DECC, 2010h, 81 pages) which also require attention. And this total of nearly 600 pages of heavy laden, repetitive and sometimes turgid prose does not take into account the myriad of material that has already been sifted through in previous consultations on Justification, the GDA, fixed unit pricing and decommissioning costs, strategic siting and nomination of sites.
While DECC are to be commended in their effort to provide all the information available, little effort has been made to enable respondents to navigate through the mass of material. As it stands the consultation process will put off many people from responding leaving only those with the resources, time, expertise and motivation to undertake the task. BANNG considers this is likely to limit the amount of effective response that will be made, disenfranchising many who might have important points to make. The ordinary citizen has been effectively excluded from the process.
Lack of Engagement. The deficiency in the written process referred to above might have been partly remedied by a greater effort to encourage participation through other methods of public and stakeholder engagement. In our previous response and in our evidence to the House of Commons Select Committee we referred to the poorly advertised, poorly attended and somewhat formalised public meetings and exhibitions that were held in the areas around the listed sites. At least it can be said some effort was made and resourced by DECC. On this occasion virtually no proactive effort has been made on behalf of DECC to ensure at least minimal public participation in the process. There have been three hastily arranged national stakeholder meetings and meetings in London with key stakeholders. No site meetings or exhibitions have been held by the department to draw the public’s attention to the proposed changes in the NPSs let alone an exposition of precisely what is being proposed for each site (there remains considerable ignorance on this score among the public). Departmental officials have been prepared to attend local meetings provided they are arranged by the local community.
In the case of Bradwell, BANNG, at its own expense, organised such a meeting in West Mersea on December 1st. 2010 addressed by Hergen Haye, Head of New Nuclear at DECC and Professor Andy Blowers, Chair of BANNG. Despite the severe weather the turn out was good with lively discussion. Without it, the re-consultation might have passed completely unnoticed in the local community. A record of the meeting has been compiled and is included at Annex B along with a detailed report that appeared in the Mersea Island Courier.
Biased and Unfair. We remain of the view that the consultation process is biased and unfair. The NPSs are strategic documents covering crucial policy issues. For reasons set out in our previous response we believe the process is skewed in favour of powerful interests, in Government and industry, who possess the resources and access to achieve influence over decisions. In our view the documentation reflects an obvious bias towards granting consent for new nuclear power stations at selected sites. This has been supported by promotion of the idea that new nuclear must be part of the mix if the lights are not to go out thereby creating a general attitude of inevitability and apathy about the nuclear proposals. As we said in our previous response, ‘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’ (BANNG, 2010a, p.5).
It may be argued that local communities will have ample opportunity to put their views when applications for planning consent are made at the sites. However, they are likely to be disadvantaged in three ways when the decision making moves to specific sites. In the first place, some of the key decisions and guidance affecting sites such as those on radioactive waste management, the selection of sites, the application of IROPI cannot be revisited, they will be fait accompli. Secondly, a great deal of policy making in the NPSs remains vague or equivocal and to be determined on the basis of further investigation at local level, for example, emergency planning, coastal processes, impact on habitats. Given the pressures towards permitting new nuclear power stations on the one hand and the lack of resources available to local councils and community groups on the other, it seems incredible that sufficient time or resources will be made available to ensure fully independent research and review of the many unresolved issues at local sites. Thirdly, the infrastructure planning process is deliberately fast track and allows relatively little opportunity (and certainly no guarantees) for local communities (especially groups like BANNG) to make detailed oral submissions or to question other contributors. BANNG considers the process is too compressed and selective to enable the fullest and most informed expression of views.
In previous consultations BANNG has indicated its concerns about proposals for the long-term storage of spent fuel and radioactive wastes on sites where new nuclear power stations are proposed. These wastes will remain long after the power stations have been closed. BANNG strongly believes that local communities should participate in a voluntary process whereby they can decide whether or not such waste facilities should be located at existing nuclear sites. It is our view that the process of voluntarism recommended by the first Committee on Radioactive Waste Management (CoRWM, 2006) and endorsed by Government (Defra, 2008) should apply to sites where new build wastes are proposed to be stored.
BANNG continues to regard the consultation process too burdensome, exclusive and biased and likely to result in the premature legitimation of a predetermined process. We endorse the view that a more open, accessible and participative process is required in order to reassure the public particularly those in the areas near proposed sites. We reaffirm our view that the process for siting long-term storage facilities for spent fuel and highly active radioactive wastes should be subject to the voluntary participation of communities. We urge the Government to ensure that principles of openness, voluntarism, fairness, partnership and participation inform all future consultations involving the development of new nuclear power stations and radioactive waste facilities.
2.0 Selection of Bradwell – the Public’s View
As we have pointed out in previous submissions, the selection of existing sites such as Bradwell is based primarily on pragmatic considerations. The sites have some existing infrastructure, are in friendly ownership and, according to industry and the government, are likely to have a compliant population less likely to resist new nuclear developments than communities in greenfield areas. Thus in the 2008 White Paper on nuclear energy the Government stated, ‘We expect that applications for building new power stations will focus on areas in the vicinity of existing nuclear facilities. Industry has indicated that these are the most viable sites’ (BERR, January 2008, para. 78). The elaborate site selection assessment, site nomination and selection combined with the massive NPS consultation exercise are, in effect, elaborate legitimating devices to secure new nuclear power stations in the only places that Government deems politically and socially possible. In the circumstances local communities have little option but to play their part in this process while, at the same time, recognising that they are, perversely, conspiring in a process that leads to the justification of the very thing they are opposing.
In previous consultations we have challenged the claim that familiarity with nuclear operations engenders less anxiety about the risks and, therefore, greater acceptability among local publics than would be the case at greenfield sites. Coupled with this is the claim that the jobs and investment accruing from nuclear development is a positive benefit and, therefore, welcomed by the local community. In the case of Bradwell the claim is blatant, the view that ‘people living and working nearby have had a long time to get used to there being an adjacent plant so this is unlikely to be a problem at this location’ (DECC, 2009a, p.42). Such claims must be treated with suspicion, in effect as pro-nuclear propaganda in the absence of any site-specific, in-depth research into local community attitudes, values and opinions on the case for new build. Indeed, what evidence there is on community attitudes is conflicting, with some studies indicating a positive response to nuclear energy in existing nuclear locations while others suggest that an increase in knowledge may result in elevated anxiety. The most recent study on Living with Nuclear Power (Pidgeon et al, 2008) including some field work in the Bradwell area portrays the multi-faceted, complex and sometimes ambiguous perspectives experienced by local people. The survey was carried out before new build proposals were made and so did not consider how perceptions might be affected once new reactors became a tangible prospect in the vicinity. In passing, it should be noted that Bradwell is different from most of the other sites in that the power station there has been shut down since 2002. People living near Bradwell have now had more than eight years to become familiar with no active power station and the evidence from an IPSOS-MORI poll and our own work suggests that a majority of people prefer it that way.
As stated in our response to the nomination of sites, we have detected a high degree of ignorance about the proposals, a condition of deep anxiety and a sense of fatalism about the inevitability of new nuclear power (BANNG, 2009a, p.2). We believe it is impossible to conclude, on the basis of the inadequate Government consultation undertaken so far, that there is public acceptability for a new nuclear power station and radioactive waste storage facilities at Bradwell. Indeed, we have strong reasons for suggesting the contrary. The BANNG Petition referred to above is, perhaps, the only extensive face-to-face evidence of community attitudes. We must stress that this Petition has been conducted face-to-face. Unlike on-line petitions it does not rely on a remote, brief and perhaps superficial encounter with the issues. Rather it requires an informed response, based, if necessary, on discussion of the issues. The Petition has gathered widespread support across the community and while we cannot claim the Petition is statistically representative, it does indicate a very strong opposition expressed by the thousands of people who have signed. The refusal rate was low, no more than one in five of those approached, lower in some areas most affected such as Mersea Island and higher in Bradwell itself where employment benefits are likely to be greatest but, even there, fifty per cent of those approached supported the Petition. The Petition provides, at present, the most extensive and solid evidence based on direct personal contact that the proposals for Bradwell are unwelcome and opposed by the majority of the community. We would welcome both extensive as well as in-depth analysis of public attitudes and believe this should be undertaken as a necessary input to the decision making process.
BANNG regrets the untested assumptions that opposition to a new nuclear power station and waste facilities would not be a problem at Bradwell. This is entirely contrary to the strongly expressed views of the majority of people as revealed in the BANNG Petition. We believe these views must be taken into account before any further decisions are made on the suitability of the Bradwell site. We would urge the Government to support independent extensive and in-depth surveys and analysis of public attitudes to the Bradwell proposals as an integral input to decision making.
3.0 An Uncertain and Incoherent Strategy
The revised NPSs provide more detail on the need for nuclear energy as part of the mix. BANNG’s previously stated view, along with that of many others, is that nuclear is not necessary even with higher demand for electricity through greater electrification of the economy. Nuclear is a costly and dangerous diversion with high opportunity costs prone to delays and cost overruns as has been shown in both the uncompleted Olkiluoto (Finland) and Flamanville (France) projects. As time passes it becomes more likely that alternative low carbon sources will plug the energy gap and that experience with nuclear will be shown to fall short of its advertised targets.
In terms of future energy supplies it is becoming increasingly obvious that there will be no need for nuclear. In the short to medium term supplies will be provided by gas- fired stations that are already planned. Beyond that it is likely that the established providers will be overtaken by the availability of a variety of new energy sources removing any need for nuclear power.
One of the problems is that the target for nuclear is unclear. According to EN-1 the UK might need 59GW of new electricity generating capacity by 2025 of which 33GW would come from renewables leaving 26GW remaining. Nuclear is expected to fill some of this but it is unclear how much, except that, according to EN-6, ‘nuclear should be free to contribute as much as possible’ (2010c, Annex A, p.7). It is noted that a single reactor at each of the eight listed sites could result in 10-14GW of nuclear capacity (DECC, 2010b, p.27). However, while all eight sites are said to be needed ‘to allow sufficient flexibility’ (p.8) in the event of refusal of planning consent at one or more sites it is unclear how many sites and how many reactors at each site will be developed. Given that the deployment of new nuclear power stations will be driven by market forces, it is wholly unclear how many, where and when new nuclear stations, if any, will be commissioned within the Government’s time-scale of 2025. Delays and setbacks in the programme preventing deployment at some or all of the listed sites could presumably bring other potential sites deployable after 2025 into the picture thereby removing the pressure to develop at the extremely vulnerable sites that have been listed. In any case by that time nuclear may well be a technology that is diminishing as far safer, less costly low carbon alternatives make greater headway. The nuclear strategy up to 2025 is inadequate and that beyond is non-existent. Thus, the whole new nuclear enterprise amounts to not so much a strategy as a fantasy.
The absence of any credible strategy for the deployment of new nuclear power leads to great uncertainty in terms of its potential contribution. This uncertainty increases in the period beyond 2025. In addition, the risks in terms of costs, delays and radiological impacts indicate that embarking on a new programme of nuclear energy would be a foolish and irresponsible enterprise. For these reasons BANNG believes the new nuclear power programme as outlined in the Energy NPSs should be abandoned.
4.0 Bradwell – A Major Industrial and Waste
Management Complex
In our previous submission BANNG criticised the siting strategy as too directive and restrictive. We will not repeat our arguments here but direct attention to our previous evidence (BANNG, 2010a, pp. 6-8). Briefly, we consider the constraints applied and the lack of alternatives places an unfair and unacceptable risk on a few sites. The situation has been further constrained by the reduction of deployable sites from 10 to 8. For these sites considerable uncertainties persist. In the case of Bradwell an agreement with EDF means that the site cannot be deployed until permission to develop two reactors at Sizewell is given. If EDF are successful at Sizewell they must transfer the Bradwell site to another potential developer. So far as we are aware, the site is up for sale but remains in EDF ownership thus creating uncertainty over the future of nuclear energy at Bradwell. The apparent lack of interest in the site indicates an awareness of the serious drawbacks of the site and a lack of confidence on the part of potential developers that the site is deployable. In this respect the nuclear industry and BANNG appear to be in agreement.
The sheer magnitude and scale of the proposals has never been made explicit to local communities. In the Bradwell context there is no comparison between the former Magnox station and what might be developed in future. Within the community both among the public but also among decision makers (MPs and Councillors) there is widespread misconception. For example, it is widely believed the new station is broadly comparable with the previous one, that spent fuel will be removed from the site as was the case in the past and there is little recognition of just how long the wastes are likely to remain on site.
There is no indication of how many reactors might be developed at the site. During the site nomination process one potential developer, Iberdrola indicated that two or three might be built with accompanying tall cooling towers. ‘We consider that the Bradwell Land, as described in the draft nomination we have seen, is sufficient for at least two or three nuclear power generating units (depending on their size) together with any cooling towers which might be required either instead of, or in order to supplement any direct cooling’ (letter to DECC, 23 March, 2009, see BANNG, 2009a). At the meeting at West Mersea on December 1st. 2010, Hergen Haye, Head of New Nuclear at DECC confirmed this: ‘no decision had yet been taken over whether cooling towers would be built on the site since it was not yet known how many power stations there would be, but if more than one was proposed, it was certainly the case that cooling towers would be necessary’ (Mersea Island Courier, December, 17 December, 2010).
No models or representations have been provided showing the extent of the potential new nuclear developments at Bradwell. For the first time these are spelled out in the Habitats Regulations Assessment for Bradwell (DECC, 2010d). The total project will comprise: at least one nuclear power station; construction areas and offloading facilities; infrastructure facilities including transmission towers higher than at present; flood defence and coastal protection measures; cooling water infrastructure (intake and outfall) and possibly cooling towers; radioactive waste management facilities for storage and encapsulation; road and rail infrastructures. This amounts to a massive industrial complex which would, if realised, totally transform the Blackwater estuary. It might, in the course of time, attract further industrial facilities using surplus heat and power and some of the infrastructures such as road, rail and shipping terminals. Over time the tranquil and beautiful Blackwater estuary would have less in common with the Stour and Constable’s country to the north and resemble, more and more, the industrialised Thames estuary to the south.
The uncertainties and lack of clarity surrounding the proposals for Bradwell result in public ignorance and mistrust. The lack of interest in the site on the part of potential developers indicates serious doubts about Bradwell’s viability. There is insufficient knowledge or information on the issues of land ownership, the prospects of cooling towers, the extent and nature of the radioactive waste facilities or the length of time they will remain on site. The scale and magnitude of the total complex of nuclear operations at Bradwell has not been presented to the public as a key element in the consultation process. BANNG demands that the Government consults the public on the potential impact of the full complex that might be proposed for Bradwell before proceeding to consider confirming the listing of the site.
5.0 Bradwell – the Key Issues
In this section of our response we focus on the three key issues which, we believe, identify the site as unacceptable for new nuclear powers stations and associated waste facilities and other infrastructures. They are:
1. Demographics and the problem of protecting the population in the event of an incident involving the accidental release of radioactivity.
2. The problem consigned to future generations of managing the long-term storage of highly active radioactive wastes in deteriorating conditions of rising sea levels, storm surges and inundation.
3. The deleterious impacts on the habitats and marine ecology and landscape and amenity of the estuary arising from development of the reactors and other nuclear facilities and the need for the abstraction of cooling water.
5.1 Demographics and Emergency Planning – A Neglected Issue
Throughout the various consultation processes BANNG has consistently drawn attention to inadequacies in the demographic calculations and emergency planning procedures outlined in various documents. In responding to our questions and criticism the Government has either provided a vague response, deferred the issue for subsequent consideration or ignored our points altogether. We do not consider this approach either helpful or considerate especially as these are matters of the utmost significance in terms of public protection.
We raised questions about the calculation and implications of the demographics criterion during the first consultation on SSA criteria (BANNG, 2008) and subsequently on the site nomination consultation (BANNG 2009a) and were disappointed when no attempt at all was made to provide any explanation or justification for the designation of the Bradwell site as ‘semi-urban’. We repeated our critique in the first round of NPS consultations (BANNG, 2010a, p.12) and concluded that the semi-urban criterion does not meet the objective ‘to limit the radiological consequences to the public in the unlikely event of a nuclear accident’ arguing, instead, that the government should explicitly state what levels of population within specific zones are deemed to be acceptable in terms of radiological risk in the event of an accident. Needless to say, there has been no response on this issue and it appears the Government prefer to shelter behind an incomprehensible and, to the public, meaningless criterion of ‘semi-urban’.
What is clear is that, in the case of Bradwell and doubtless other sites, the Government deems it acceptable that quite substantial populations in the vicinity of power stations could be put at risk. In our previous submissions we indicated the potential size of the population at risk from a potential release at Bradwell, up to a third of a million within 25-30km. In its commentary on demographics the Government recognises concerns about proximity to large populations centres but refers only to the HSE’s calculations taking into account population within a radius of 30km. The figure is not revealed and the purpose of this is not clear except that it is presumably an input into the arcane calculation which results in Bradwell being designated ‘semi-urban’. At a more empirical level the Habitats Regulations Assessment for Bradwell reveals a stunning ignorance of local demographic characteristics. It states the site is 15km. east of Maldon and ‘The nearest built up areas are Bradwell-on-Sea, Tillingham, Southminster and Burnham-on-Crouch.’ (DECC 2010d. p.8). Presumably these are nearest distances by road. If radial distances are calculated then it is clear the calculation omits the largest built up area, West Mersea, 2.5km. away, with a resident population of 8000 as well as Tollesbury (3000) and Brightlingsea at about 12km. distance. It might also be noted that the town of Colchester with a population of over 100,000 lies about 15km. north of Bradwell with Clacton a similar distance away and another large town, Chelmsford, within 25km. radial distance. It might be claimed that there is a very substantial ‘urban’ population within a relatively short distance of Bradwell that might well be exposed in the event of a radioactive release.
In earlier submissions it was pointed out that there is a substantial and growing transient population, notably in camps and caravan parks on Mersea Island and various other villages surrounding the Blackwater and Colne estuaries such as Heybridge, Maylandsea, St Lawrence, Brightlingsea, Point Clear and St. Osyth which dramatically increase numbers during the tourist season. These populations are excluded from the demographics assessment which is based on permanent night time residents. Transient populations would only be factored into consideration of emergency planning ‘if they were considered to be in relevant areas’ (DECC 2010c, Annex C, p.21). In some respects these transient populations may be at greater risk if they are unfamiliar with the area or if they are living under canvas or in caravans. We consider such populations should be treated as part of the population that must be considered for any emergency planning procedures.
In our previous submissions we have argued that the NPSs provide insufficient guidance or requirements for emergency planning. We described the provisions in the NPSs for emergency planning as ‘incredibly vague and insubstantial’ and we remain of this view. Far too much is left for later consideration and the coordinating role of the local emergency planning authorities. There are two aspects which remain of particular concern. One is the delimitation of the Detailed Emergency Planning Zone (DEPZ). We previously raised our concerns that the DEPZ for Bradwell might omit Mersea Island which has only one link to the mainland which is intermittently flooded at some high tides. We have not been fully reassured by the statements in the Bradwell assessment. It reasserts that the delineation is a matter for the local emergency planning authority. Further it comments on the ‘extendibility scenario’ which considers various emergency arrangements up to 15km. including evacuation out to 4km. which would include Mersea Island (not entirely). The purpose of the extendibility scenario ‘is to make the local authority and others involved in emergency planning aware of factors which may influence the choice and timing of emergency countermeasures’ (Ibid, p.22). This statement provides no useful information or reassurance about precisely what factors or countermeasures are envisaged. Moreover, there is no information provided on the nature and potential consequences of a release of radioactivity for which countermeasures are needed. In terms of public information it should be made clear under what circumstances and over what distance survival is possible. It should also be stated that there will be situations in which there is little or no chance of survival. This is not intended to alarm the population but to recognise the common public perception of the low probability but high consequence of a major nuclear emergency.
A further issue is how the public will be informed about what to do in case of an emergency. According to the site assessment for Bradwell the public will be provided with specific information which will include information on ‘the behaviour which members of the public should adopt’ (Ibid, p.22). It is scarcely credible that in conditions of emergency the public will behave in an orderly, disciplined and rational way; there may be panic, bewilderment and misunderstanding. Furthermore, within the DEPZ the public will be informed by an automated telephone messaging system while in the extendibility zone they ‘will be alerted by the local media’. It cannot be assumed that everyone will have immediate access to these warning systems or that they will operate with efficiency and swift timing or that they will be fully comprehended in conditions of elevated anxiety. The warning system suggested seems to be supremely inadequate. Again, in the interests of openness it would be more reasonable if it was conceded that the warning system, though helpful, was unlikely to be successful in every conceivable circumstance.
In conclusion, we refer to and reiterate the recommendations on demographics and emergency planning on this issue presented in our first response on the NPSs (BANNG, 2010a, pp.13-14). In addition,
· we consider that the demographics assessment should set out clearly the population levels at various distances from the Bradwell site up to, say, 30km. This assessment should include estimated transient populations who would be at equal (if not greater) risk than the night time population.
· there needs to be much more detailed information and guidance in the NPS on the nature and probabilities of major emergencies arising from releases of radioactivity. There needs to be more explicit information on the nature and effectiveness of possible countermeasures.
· more reliable and effective means of informing and warning the public in the case of an emergency are required
· it cannot be assumed that the public as a whole will be sufficiently informed and be willing or able to act in prescribed ways in a state of emergency. Evacuation may be impossible in certain circumstances. Emergency planning procedures should be honest about the risks and sufficiently flexible to react capably in changing circumstances.
In BANNG’s view, the lack of detail, direction and realism at the generic level on emergency planning is a serious omission precluding any realistic discussions or debate about the probability and feasibility of public protection in the event of an emergency. We urge the government to produce a more credible and useful statement on demographics and emergency planning before proceeding to designation of the NPSs.
5.2 Radioactive Wastes – problems of policy and on-site storage
Since the first round of consultation the Government have made some amendments to the process but not the substance of policy for the management of radioactive wastes. Previously it was unequivocally stated that the IPC need not consider the issue of wastes on the grounds that effective arrangements will exist to manage and dispose of the wastes (DECC, 2009b, p.25). In its revised version there is the important qualification: ‘However there may be planning issues relating to the on-site management of radioactive waste which it is appropriate for the IPC to consider as part of the development consent application’ (DECC, 2010c Appendix B p. 18). Clearly the idea that waste management arrangements could not be discussed at site level was preposterous and we are pleased that ‘planning issues’ may be subject to further consideration. However, our primary concern has been the core policy for waste management and this has not changed. We maintain our objection that it cannot be said that ‘effective arrangements will exist’ for all the reasons stated in our previous responses on the NPSs (BANNG, 2010a, pp. 20-22), the GDA (BANNG, 2010c, pp. 4-7) and our Evidence to the House of Commons Select Committee Inquiry (BANNG, 2010b, pp. 9-10 and Annex). The Government claims in EN-6 that geological disposal is technically achievable, a suitable site can be identified and safe, secure and environmentally acceptable interim storage arrangements will be available (DECC, 2010c, p.14). These are assertions, not established facts. There is, as yet, neither an agreed safety case nor agreed design nor an identified or approved site for a geological repository. And, as we shall show later, it cannot be claimed that wastes will be managed safely and securely on the sites listed for an indefinite period. We remain strongly of the view that while there exists a process which may ultimately lead to effective long-term arrangements for legacy wastes, there is not yet an effective permanent solution in place for the management of legacy, let alone new build wastes.
Through successive consultations on siting, Justification and on the GDA there has been a patent lack of clarity over what kind of radioactive wastes facilities may or may not be present at new build sites and for how long they are likely to remain there. We have commented at length on the radioactive waste issue and refer to our previous submissions on the subject (BANNG, 2008, 2009a, 2009b, 2010 a, 2010b, 2010c, 2010d, 2010e). In various documents it has been established that it is intended that spent fuel and highly active intermediate level wastes will be stored on site until a permanent solution is available, in the form of a deep geological repository. We, and others, have pointed out that it is unknowable whether such a facility will exist or need exist and that, consequently, wastes may be stored on site indefinitely. In the first round of consultation it was conceded that these wastes might remain on site for a period of around 160 years (DECC, 2009b) to enable sufficient cooling. The present consultation has provided another interpretation of the possible time-scales arguing that the availability of the putative repository is the crucial factor and that disposal of new build wastes could begin around 2130 once the disposal of legacy wastes is completed. To compound the vagueness the Government says it has ‘not set a fixed delivery timetable’ but ‘is developing a clear timeline for the implementation of geological disposal’ (DECC 2010c, Annex B, p. 16, 17). The re-consultation seems further to have obfuscated the time-scale of waste management on site. The best that can be said is that wastes will remain on site into the far future, at least until towards the end of the next century.
There are further complications in terms of what facilities will be needed and where. Facilities are likely to consist of waste stores, encapsulation plants and transfer and transport infrastructures. There is virtually no information on this either in the NPSs or in the GDA consultation documents. The NPS also floats the vague idea of ‘a central storage facility, if a site can be identified and the necessary regulatory and planning permissions obtained’ (Ibid, p. 17). All in all there is a disappointing lack of clarity or detail on the timing and facilities for radioactive waste management. It appears that the Government is making up its policy as it goes along.
We also remain concerned that there is no process for any public involvement in the long-term management of new build wastes. As we have previously stated we believe there should be a separate consultation process on the issue of new build wastes alone as indicated by CoRWM1 in its recommendations and in its implementation report (see CoRWM, 2006, 2007). It appears to us unfair that communities should be invited to consider whether they are interested in the possibility of hosting a repository for legacy wastes while communities around new build sites are having spent fuel and waste stores thrust upon them possibly for the indefinite future.
Most of the Bradwell site is in flood zone 3 and the sequential and exception tests have demonstrated this is the only available site. It is highly vulnerable to flooding and especially to changes in sea level, storm surges and coastal processes consequent on climate change. According to the NPS assessment for Bradwell climate change effects are only modeled up to 2100. ‘Predictions of potential climate change effects become increasingly less certain the further into the future they extend’ (DECC, 2010c, Annex C p. 17). It is indicated that projections will be refined as time passes and will give sufficient time ‘for appropriate actions to be taken to address those impacts’ (Ibid, p.17).
We have little confidence that the potential situation on the coast beyond 2100 has been thoughtfully considered. In the first place predictions (which, as the Government indicates, are really speculations) of sea level rise vary considerably. The Bradwell assessment (DECC, 2010c, Annex C) quotes the report from the Middlesex University Flood Hazard Centre which suggests a worst case scenario of a 5-6 metre rise in sea level. However, the Environment Agency consider that a rise of approximately 2 metres is a better prediction (p. 29). In our view the most pessimistic forecasts should be taken into account, though even a 2 metre rise would have devastating consequences on such a low-lying coast as the Dengie peninsula. Elsewhere in the documentation, there is clear recognition of the potentially catastrophic consequences in coastal conditions consequent on climate change. In EN-1 revised it is argued that the increase in global temperatures must be kept to no more than 20C. Continuation of global carbon emissions at current levels (which, surely, must be included as a worst case scenario) could lead to a rise of 60C by the end of the century. ‘This would make extreme weather events like floods and droughts more frequent and increase global instability, conflict, public health-related deaths and migration of people to levels beyond any recent experience. Heat waves, droughts and floods would affect the UK’ (DECC, 2010b, pp. 9-10). There seems to be a contradiction between the language of impending disaster in EN-1 and the reassuring notion that it will all be alright on the night which is the impression given in EN-6.
Despite the uncertainty about climatic conditions and their consequences in terms of sea level rise, storm surge and coastal processes beyond 2100, the Government continues to argue that Bradwell is a potentially suitable site for the storage of radioactive wastes which could be there until near the end of the next century and beyond. The Environment Agency provides the highly qualified but complacent advice that ‘it is 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’ (DECC, 2010c, Annex , p. 27). Moreover, it is unclear just how the wastes will be managed, in what kind of facilities and how much operational effort will be needed. There is an implied expectation that there will be the resources, the skilled workforce, the commitment and resolution that will be needed to manage the wastes safely and securely on site in what may be almost intolerable conditions of inundation and storm surges. This puts a blind faith in institutional continuity and social stability which is at odds with the chaotic possibilities envisioned in EN-1. The point is that the future state of the coast and of society in the far future is unknowable and, therefore, we should proceed cautiously on the basis that the worst might happen and plan for that rather than casually allow the future to look after itself. It is morally outrageous and irresponsible to consider leaving spent fuel and other highly dangerous radioactive wastes on a site such as Bradwell which might prove impossible to defend from natural forces.
On the issue of storing radioactive wastes, BANNG reaffirms all its previous comments and conclusions (see BANNG, 2010a, pp. 20-22). We consider the proposals for radioactive waste management are inadequate, irresponsible and unfair for the following reasons:
· it is not the case that effective arrangements will necessarily exist to manage highly radioactive wastes in the long-term
· arrangements for the long-term storage of wastes on site are unclear
· the time-scale for the long-term management of wastes on site is unknown
· local communities need first to be informed about the proposal to store spent fuel on the site and then to be given the opportunity to consider whether they are willing to host their long-term management
· predictions of the impacts of climate change beyond 2100 are increasingly speculative and worst case scenarios indicate the possibility of catastrophic changes to vulnerable coastal areas such as Bradwell
· it is unrealistic and irresponsible to assume institutional continuity and social stability will persist into the far future
· it is unethical to place burdens of cost, effort and risk on future generations to cope with the continuing management of wastes in deteriorating conditions
For all these reasons BANNG believes that it is not possible to claim that indefinite storage of radioactive wastes at the Bradwell site can be managed safely and securely. Consequently, we believe that Bradwell is not a suitable site for a new nuclear power station and waste facilities and should not be listed in the NPS.
5.3 The environment of an estuary – impacts on habitats, marine ecology and
visual amenity in the Blackwater
Bradwell is situated on the shallow Blackwater estuary. It is one of only two estuarial sites under consideration. The estuarial environment is especially complex and fragile and merits extremely careful conservation (inherent in the fifteen designations that cover most of the estuary)(for a discussion of the Blackwater environment see Blowers and Smith, 2003). We note that the consultation on the GDA (Environment Agency, 2010) omitted estuarial locations in its discussion of impacts, a point we have made in our response to that consultation (BANNG, 2010c).
In previous submissions we have focused on the deleterious impacts on the environment and ecology of the Blackwater estuary that will be brought about if new nuclear reactors, cooling water infrastructure and radioactive waste facilities are permitted at the Bradwell site. We believe these impacts to be damaging and irreversible and consider that efforts at adaptation or mitigation would have no more than marginal and, over time, diminishing impact. The destructive impacts on habitats, marine life and visual amenity would be of such magnitude that it would be a matter of Imperative Reasons Of Public Interest to avoid them. For that reason we believe the Bradwell site should be excluded from further consideration. Our conclusions and recommendations on environmental impacts will be found on pp. 10-12 and 25-27 (BANNG, 2010a) of our previous submission which accompanies this response.
The environmental impacts can be broadly divided into three categories, each relating to a specific causal process. First there are impacts on habitats, primarily brought about by coastal processes. Second, are the impacts on marine ecology especially caused by the need to abstract cooling waster from the estuary. And, third, there are impacts on landscape and visual amenity created by the size and shape of the reactor building and other infrastructures including possibly tall cooling towers.
5.3.1 Habitats and coastal change
Throughout the documentation it is confirmed that new nuclear power stations are likely to have significant impacts on coastal areas. Despite this ‘the Government has determined that all of the listed sites are required to be listed as being potentially suitable for new nuclear development in spite of some being located in higher flood risk zones because of the lack of alternative sites and the need for new nuclear development’ (DECC, 2010c, p.21). Bradwell is one of the sites in flood zone 3 and the Habitats Regulations Assessment concludes there could be ‘significant effects’ on the internationally and nationally designated sites (DECC, 2010 d, p. 13). We have previously referred to the impacts on mudflats, salt marsh, grazing marsh, sand and shingle and reed beds and the disruptive effects on feeding grounds and migration for a wide variety of bird species. (BANNG, 2009. P.11). The damage to these sites in terms of fragmentation or loss of important habitats could be caused by coastal processes including ‘coastal squeeze’, sediment movement, erosion, flooding and other processes exacerbated by the intrusive impact of development of the power station and associated facilities.
It is accepted by the Government that development consent should not normally be given ‘in areas of dynamic shorelines where the proposal could inhibit sediment flow or have an adverse impact on coastal processes..’ (DECC, 2010b. p.82). Nonetheless, it is argued that the need for nuclear energy and its benefits are so great that IROPI should be invoked in favour of development. This may be justified in terms of efforts at mitigation or adaptation. The onus is placed on the developer to demonstrate ‘that future adaptation/flood mitigation would be achievable at the site, after any power station is built, to allow for any future credible predictions that might arise during the life of the station and the interim spent fuel stores’ (DECC, 2010c p.22). In the case of Bradwell it is difficult to see how any form of mitigation or adaptation could compensate for the destruction or diminution of habitats that is likely to occur on a very low lying coastline in the southern part of the country where coastal sinking through isostatic re-adjustments and sea level rise through climate change are likely to have significant consequences. The development of a series of nuclear power stations will further exacerbate a deteriorating situation.
It is clear that the impact of developing a new power station complex on the Blackwater coast is unknown. The research reflected in the Habitats Regulations Assessment and elsewhere indicates there could be serious harm but the extent and distribution of impacts is unclear pending further research. The NPSs suggest that these impacts can only be determined at the project level and that, therefore, consideration should be undertaken as part of the planning consent process. In our view the NPSs should provide greater clarity and direction as to the levels of harm that are unacceptable, IROPI notwithstanding. Far too much has been left for determination at a later stage. We underline the points on this made previously in BANNG, 2010a, p.22.
On the issue of impacts on habitats, BANNG reaffirms the conclusions presented on pp. 10-12 of our previous submission. Bradwell is in flood zone 3 and in a coastal area where significant impacts on habitats from coastal processes are to be expected. Development of new nuclear stations is likely to exacerbate the problems and we do not consider mitigation or adaptation measures are likely to compensate for destruction of habitats. We consider the impacts on habitats in such a sensitive and fragile coastline likely to be created are unacceptable and that, for this reason, the site should not be listed.
5.3.2 The impact of cooling water abstraction on marine ecology
BANNG regards the impacts on the marine ecology of the Blackwater estuary from cooling waster abstraction as a defining issue; this alone is, in our judgement, sufficient reason for the Bradwell site to be removed from the list of potentially available sites for new nuclear power stations. We have set out our concerns in detail and at length in previous submissions – in our evidence on the first consultation on the NPSs (BANNG, 2010a, pp. 26-27) on the GDA (BANNG, 2010c, pp. 8-9), in oral and written evidence to the House of Commons Select Committee Inquiry (BANNG, 2010b) and in our response on the nomination of sites (BANNG, 2009a, pp. 10-11). These comments still stand as part of this submission. We would also draw attention to the research evidence on harm to the marine ecology of the estuary presented by Colchester Borough Council in its response to the first NPS consultation. We pointed to the vastly increased direct cooling water intake that will be needed compared to that for the former Magnox station amounting to 10% of the total estuary volume of exchange water at each tide. We note that the HRA assessment for Bradwell comments, ‘The River Blackwater is over-abstracted..’ (DECC, 2010d, p.26). It is also noted that the Shellfish Waters Directive covers the Blackwater estuary and requires that a discharge must not cause an increase in water temperature higher than 20C above ambient temperature. A rise in water temperature of up to 20C in the estuary as a whole and possibly 100C in the vicinity of the plant would have potentially devastating consequences on the cultivation of the celebrated and economically significant Colchester Native Oyster and on fishing in the estuary. Fish stocks, many of them commercially significant, would also be harmed by biocides, chlorination, impingement and entrainment.
We have been most disappointed by the Government’s response to these concerns. It is patently clear that the potential damage is fully appreciated by the Government (see the assessment on Bradwell, DECC 2010a, Annex C, p.42) and it is recognised that ‘There may remain cases where, even with the application of best practice, residual impacts would be unacceptable’ (p.43). Even so the Government falls back on some specious special pleading commenting that in the winter of 1962-3 ‘oyster survival was aided by the proximity of thermal discharge’ (p.42). We find such a statement deplorable in that it seeks to claim the possibility of enhancement of marine ecology through elevated temperature. We consider potential detriments from increased temperature must be the focus of attention when a permit for cooling water abstraction is being considered. For instance, it was pointed out at the December 1st meeting in West Mersea that in 1963 the power station had an emergency shutdown because of the icing of the estuary. During the operation of the former station local fishermen and oystermen noted an extensive ‘dead area’ in the vicinity of the water outfall, an area that is now regenerating since the closure of the plant.
In terms of possible mitigation through design of works there is some brief and vague discussion about the location of inlet and outfall pipes. The Environment Agency in its GDA completely fails to take into account the issue of cooling water abstraction in estuarial locations basing its conclusions on abstraction from the open sea. It appears that there is lack of knowledge or evidence on the impacts of cooling water abstraction on which to base any conclusion that a new nuclear power station on the Blackwater could, in the circumstances, be acceptable. In the absence of evidence the NPS statement relies on the evasive advice of the Environment Agency which is ‘unable to make detailed consideration at this stage because suitable modeling of cooling water discharges cannot be done until there is a detailed proposal accurately stating discharge locations and volumes’ (DECC, 2010c, Annex C, p.43). BANNG finds this unacceptable. There is no reason why such an assessment cannot be made using a variety of assumptions based on potential power station designs and cooling water technology. If the Environment Agency is prepared to sanction proposed designs under the GDA (albeit based only on cooling from the open sea) we see no reason why it cannot pronounce on the potential risks from cooling water abstraction for a mega power station in a shallow estuary. Certainly, we feel such a detailed assessment ought to be made before the site is listed as potentially suitable.
On the issue of cooling water abstraction BANNG believes the rise in sea water temperature is likely to infringe the EU Shellfish Waters Directive and threaten fish species and the cultivation of Colchester Native eysters. The volumes of sea water required are unlikely to be achieved without significant damage to marine ecology in the Blackwater estuary. We consider a detailed assessment of ecological harm and commercial consequences arising from direct cooling in the estuary must be undertaken before there is any further consideration of the site.
5.3.3 Impacts of developments on landscape and visual amenity
In previous responses to consultations we have expressed our concern about the potential impacts on the landscape value, cultural heritage and amenity of the site and its surroundings. We have drawn attention to the site’s isolation in a flat and treeless landscape where visibility is uninterrupted for miles around. With the existing station there are some differences between different parts of the estuary. On the northern side the views across the estuary are open, completely unobstructed and the former station poses a significant visual intrusion. To the south waterside villages towards Maldon (for example Stone, St Lawrence Bay and Maylansea) have views of the former station. Bradwell, the village closest to the site, is not visually impacted, the former station being obscured from view. At the end of the Dengie peninsula and close to the old station and the site for any future stations is the small 7th. century St Peter’s Chapel, a significant element of the cultural heritage of the area. Thus, the hulk of the former magnox station is still prominent but it is now being decommissioned and the landscape and the estuary is gradually reverting to a tranquil haven for passive recreation and wildlife. An Ipsos-Mori poll revealed that the local population overwhelmingly favoured the site being returned to its natural state.
Our earlier responses were largely confined to the impacts that would be created by the deployment of one reactor with assumed direct cooling from the Blackwater estuary. In our submission on site nomination (BANNG, 2009a) we drew attention to a letter from a potential nominator indicating that the site was capable of accommodating two or three units ‘together with any cooling towers which might be required’ (letter from Iberdrola to DECC, 23 March, 2009). At the time we urged that the Government openly declare what was intended. Subsequently the Appraisal of Sustainability for Bradwell (DECC, 2009a) accompanying the first round of consultation on the NPSs recognised that more than one reactor might be envisaged and that cooling towers might be necessary, whether for one or more reactors was unclear. But, the assessment was still based on one reactor with the Government claiming that the differing impacts of a second station, if it were proposed, would need to be taken into account. However, the original EN-6 went on, confusingly, to say the Government would not expect to re-assess a site, nor to re-run the relevant Appraisal of Sustainability and Habitats Regulations Assessment assessments, should proposals for more than one reactor be submitted..’ (DECC, 2009b, p. 46).
The issue of cooling towers has been largely understated in previous consultations and it is clear that their impact on the ecology and amenity of the Blackwater estuary is an issue that the Government intends to leave until an application for development is made. We find this approach deceptive. The NPS consultations have been, at best, ambivalent on the issue of the number of reactors and hence the need for cooling towers at Bradwell. The commentary on prospective impacts has focused on the implications of one reactor with direct cooling. For Bradwell, it makes a very big deal of difference whether or not there are cooling towers. In its response to the first round of consultation the Government indicated that, in the event of cooling towers, it would be necessary ‘to judge whether the visual effects on sensitive receptors….outweigh the benefits of the project’, noting that, ‘this area is flat and predominantly undeveloped’ (DECC, 2010f, pp.156-7; also in DECC 2010c, p.41). EN-1 states: ‘The scale of such projects means that they will often be visible within many miles of the proposed infrastructure’ (DECC, 2010b, p.100). We find these observations on the amenity damage likely to be caused rather contradicts the view expressed in the assessment of Bradwell that ‘it is not possible at this stage to accurately assess whether a new nuclear power station would impact on tourism in the area’ (DECC, 2010c, Annex C, p.48).
No comment is offered on overhead power lines crossing open countryside close to villages to the south of Bradwell. It must be anticipated that the present, both ageing and undersized, lines will require replacement with a significantly larger infrastructure to cope with the potential capacity of any new nuclear power stations at Bradwell. This infrastructure will have a significantly larger visual impact on surroundings and possible health risks to immediate communities for a considerable portion of south east Essex.
Our photomontage (figure 1) provides an impression of how dominating would be the impact of two or three reactors with accompanying tall natural draught cooling towers (which we are informed would be 200m in height, equivalent to building higher than the Gherkin in London). Given the flat surrounding area they would be visible for miles around in every direction. The cultural landscape and visual amenity of the estuary would be utterly transformed. We do not believe this is a matter that should be left until an application for development is made. As with so many other aspects of new nuclear development the guidance provided in the NPSs is much too vague and indeterminate.
In terms of visual amenity and landscape of the Blackwater estuary the focus has been on the impact of one new reactor with direct cooling. It has become increasingly clear that there could be two or even three reactors proposed for the site cooled by tall natural draught cooling towers. While the visual impact of one station would be very damaging, two or more would have a devastating effect, transforming the estuary. BANNG considers this issue has not been properly consulted on and that further consideration and consultation is necessary before proceeding to list Bradwell as a possible site for a new nuclear power station. We further consider that the existing closed magnox power station should be fully decommissioned and the site returned to its natural state as soon as possible.
6.0 Other Issues
6.1 Socio-economic impacts
In our previous responses to various consultations we have focused attention on the potentially detrimental economic and social effects of new nuclear development in the Blackwater estuary. The Government Response to the first Consultation states ‘New nuclear development would result in the creation of a significant number of jobs and would have a very positive effect on the local economy’ (DECC, 2010, p.127). Such an assertion is critically dependent on the definition of the local economy and is, hence, inapplicable to the diverse economies surrounding the Blackwater estuary.
No attention is given in the Consultation to the possibly negative effects on the commercial prosperity of local village communities as a result of new nuclear development. There is a real danger that the negative image of nuclear together with impacts on amenity (material and visual) could impact on the recreational sporting activity and accessibility for which the area is currently well known.
The initial impact may be that the amenities of the area surrounding the Blackwater estuary are likely to become less popular as a holiday destination resulting in commercial decline in the affected villages. For villages to the north and distant by road from Bradwell, there are no compensating economic benefits to offset such costs at all. Moreover, even for the communities to the south side of the Blackwater estuary any advantages in terms of jobs in the nuclear industry must be discounted against the deterrent effect on other commercial activities and developments. It is possible that the immediate area could become a monocultural nuclear economy providing fewer opportunities than might be gained by a more diversified effort at regeneration. The problem is that current claims for economic benefits are simply speculations.
The question of impact on property prices is difficult to assess. BANNG is unaware of the availability of any statistics to support arguments either way on the effects of the historic power station on local residential property. It is possible if Bradwell were to become a significant nuclear employment hub that residential property values close to Bradwell might be stabilised compared with elsewhere in Essex or might even increase with a shortage of property. However, to the north side of the Estuary with the visual intrusion of any new stations there is a strong argument that these locations could become less favoured resulting in a significant lowering in values. The negative effect on prices would be likely to persist so long as the possibility of a permission to develop at Bradwell remains.
On the question of socio-economic impacts we repeat our earlier recommendation that:
Before any decision is made for new nuclear development at Bradwell an independent study and assessment should be undertaken of the social and economic impact as it affects the communities surrounding the Blackwater estuary as a whole. It is too late if this is left to be decided at the planning application stage.
In addition to this,
On the matter of property prices, uncertainty will persist so long as the possibility of nuclear development at Bradwell persists. Given that Bradwell is unlikely to be considered in the short term, if at all, it should be de-listed to avoid long term uncertainty about the future of the site.
6.2 Nuclear Radiation and Health Risks
In previous submissions we have commented extensively on health impacts both in generic terms as well as specifically applying to the Bradwell site. We refer you especially to our responses to the consultations on Justification (BANNG, 2009b), on nomination of sites (BANNG, 2009a) and on the NPSs (BANNG, 2010a). We pointed to the problems of research, the suggestive nature of the data gathered for Bradwell and to recent research on the association between proximity to nuclear power stations and specific types of cancer. We also referred to research on genomic instability which suggest that radiation health effects are potentially far more widespread and risks arise after exposure to doses far lower than current safely limits allow (NCG, 2009). We concluded that there is a need for further investigation and that, in view of the uncertainties, it is prudent to adopt a precautionary approach, avoiding risk by not constructing a new nuclear power station and high level waste store. Here we present further evidence on health impacts which reinforce our previous concerns.
The health risks to local residents from the operation of the existing (decommissioned) nuclear power station at Bradwell continue to arouse concern and controversy. DECC continues to rely uncritically upon the orthodox view, sustained by the official Committee on the Medical Risks of Radiation in the Environment (COMARE), that the operations of nuclear installations – power stations and nuclear research establishments – have not created health risks for local populations (see DECC, 2010f; DECC, 2010e, pp 23-26).
However, COMARE’s position rests upon data that have been contested repeatedly, analytical procedures (primarily statistical) that remain controversial, and the work of a relatively small group of ‘experts’. Moreover, while COMARE remains nominally independent of Government and most of its members are able to establish a lack of ‘conflict of interests’, the criteria of ‘interest’ ignores the fact that the overwhelming proportion of the research funds for these members, and their home institutions, come from the Government – directly or indirectly via Government-funded research institutions. The Government, itself, has always had a substantial interest in the view that no adverse health effects have been generated by nuclear institutions so as to protect itself from serious moral, and substantial financial, liability.
The orthodox view that there have been no health risks from the operation of nuclear installations has been sustained in the face of continuing controversy about the data and persisting contention over the analytical techniques employed. This was the background to the establishment in 2001 of a committee explicitly directed to interrogate the orthodox view and its underlying methodology – the Committee Examining Radiation Risks of Internal Emitters (CERRIE). By 2004 CERRIE had concluded that further research into the health risks of some nuclear power stations was warranted and was, in fact, in the process of commissioning a further study of cancer clusters around the Blackwater estuary (the home waters of the Bradwell power station). The motive for this planned research was the particular concern that tidal estuaries posed a specific threat of dispersing radioactive material to local inhabitants, with ill-effects on their long term health. It was at this stage, however, that the incoming Minister of State for the Environment – Eliot Morley – abruptly dissolved CERRIE and the research was cancelled. Considerable public acrimony followed this demarche, as witnessed by articles and letters in the press in the summer of 2004. COMARE, however, was able to maintain the orthodox position with little further institutional challenge.
COMARE’s orthodoxy did not, however, remain unchallenged indefinitely. The publication of the German KiKK report in 2008 posed a frontal challenge (Kaatsch et al, 2008). This work identified increased levels of childhood leukaemia around Germany’s nuclear power stations and confronted the official UK position on nuclear health risks with a serious challenge. The apparent implications of this work for the UK were, however, dismissed in a paper by J.F. Bithell and his associates the same year. However, the work of Bithell and his associates has a long association with the orthodox position, making it highly unlikely that a speedy acceptance of such a challenge would be forthcoming (e.g. Bithell et al, 1994). Most significantly, however, COMARE itself has found the KiKK study’s findings sufficiently challenging to warrant a further study of childhood leukaemia and other cancers around nuclear installations and to schedule publication of the results in its 14th report (as reported in The Government Response to the Consultation, DECC, 2010f, p 126).
The foundations and implications of the continuing controversy about the health risks from nuclear power stations have particular resonance for those living in the vicinity of the Bradwell power station and the site of possible new installations. It is important to note that the work of CERRIE has been all but written out of the official record on health issues. There is little acknowledgement of the contested criteria for selecting those localities that should be examined for levels of cancers. There is no serious discussion of the interesting statistical procedures that have been employed to justify the downgrading of possible clusters of cancers and criticisms of those who claim to have identified such clusters (the contentious argument, in the latter case, is that such identification rests upon a procedure in which localities are only defined, retrospectively, to ‘fit’ any unevenness in incidences of cancers). Most serious of all, is a Catch 22 procedure, which deploys an a priori presumption that only exposure to very high levels of radiation (through proximity to nuclear explosions or major nuclear accidents) can cause cancerous consequences (the Hiroshima criterion). This presumption has been employed, critically, in the attempt to discount cases where higher-than-normal levels of some cancers have had to be acknowledged in the vicinity of some nuclear power stations (NRPB, 2004, pp. 24-6).
The determined defence of a convenient view that nuclear power stations have posed no health risks to local populations in the face of continuing controversy, and the German KiKK study, has done little to reassure those living in the vicinity of such installations and underlies much of the opposition to new constructions. The maintenance of the orthodox position has all the hallmarks of past, protracted efforts to deny the significance of lead in petrol, to denigrate claims of damage from cigarette smoking, and to claim that there was ‘no scientific evidence’ that BSE in cattle could have any connection to its human correlate. Longitudinal studies of discrete populations in the vicinity of power stations could go some way towards establishing the existence, or otherwise, of cancer clusters (without conclusively explaining their occurrence) and avoid the shortcoming of complex statistical manipulation of aggregate data. The new science of DNA profiling might also offer considerable insight into the actual causes of such cancers as have arisen (raising the intriguing possibility that, even where aggregate levels appear to be ‘normal’, nuclear power stations might still have exerted a causal influence in areas where alternative causes of some cancers might be lower than ‘normal’).
BANNG contends that, given the uncertainties that must lie behind COMARE’s decision to commission further research of the implications of the KIKK study then no new nuclear power stations should be approved in areas of particular sensitivity, like tidal estuaries such as the Blackwater estuary, until more discriminating studies – longitudinal and DNA based – have been completed into those cancers that have been contracted in the vicinity of existing (or past) installations.
At a minimum, sufficient time and opportunity must be allowed for a thoroughgoing and critical examination of COMARE’s forthcoming 14th report on cancers relating to nuclear power stations.
Prepared by Professor Andrew Blowers, OBE, with Professor Barry Jones, Charles Clark, Barry Turner and Varrie Blowers
On behalf of the Blackwater Against New Nuclear Group (BANNG)
24 January, 2011
[Note: Accompanying this document is the BANNG Response to the Consultation on the 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, dated February, 2010. The two documents together provide the substantive response by BANNG to the Draft National Policy Statements on Nuclear Power Generation.]
References/
References
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 Paper No.1)
BANNG (2009a) ‘Have Your Say’ Government Consultation on Nomination of Sites for New Nuclear Power Stations, Response to the Consultation by BANNG, May
(BANNG Paper No.2)
BANNG (2009b) 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 Paper No.3)
BANNG (2010a) 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), February (BANNG Paper No.4)
BANNG (2010b) House of Commons Energy and Climate Change Committee, Inquiry into Energy National Policy Statements, Evidence on Behalf of the Blackwater Against New Nuclear Group, January (BANNG Paper No.5)
BANNG (2010c) Environment Agency Generic Design Assessment AP1000 Nuclear Power Plant Design by Westinghouse Electric Company LLC: UK EPR Nuclear Power Plant Design by Areva NP SAS EDF; Consultation Document, Response by Blackwater Against New Nuclear Group (BANNG), October (BANNG Paper No.6)
BANNG (2010d) The Justification of Practices Involving Ionising Radiation Regulations 2004. Consultation on the Secretary of State’s Proposed Decisions as Justifying Authority on the Regulatory Justification of the New Nuclear Power Station Designs Currently Known as the AP1000 and the EPR, response to the Consultation by the Blackwater Against New Nuclear Group (BANNG)
(BANNG Paper No.7)
BANNG (2010e) The Energy Act 2008, Consultation on the Financing of Nuclear Decommissioning and Waste Handling Regulations, Consultation on a Methodology to Determine a Fixed Unit Price for Waste Disposal and Updated Cost Estimates for Nuclear Decommissioning, Waste Management and Waste Disposal, Response of the Blackwater Against New Nuclear Group, June (BANNG Paper No.8)
BERR (2008) Meeting the Energy Challenge, A White Paper on Nuclear Power. CM 7296, London, TSO, January
Bithell, J., Dutton, S., Draper, G., Neary, N. (1994) ‘Distribution of childhood leukaemias and non-Hodgkin’s lymphomas near nuclear installations in England and Wales’, BMJ, 20 August.
Bithell, J. et al (2008) ‘Childhood leukaemia near British nuclear installations: methodological issues and recent results’, Radiation Protection Dosiometry, 2008, vol. 132 (2), pp. 191-197
Blowers, A. and Smith, S (2003) Introducing Environmental Issues: the environment of an estuary, in Hinchliffe, S., Blowers, A., and Freeland, J. (Eds.) Understanding Environmental Issues,Wiley and The Open University, pp. 3-48
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, Appraisal of Sustainability: Site Report for Bradwell, November
DECC (2010a) Planning for New Energy Infrastructure: consultation on revised draft National Policy Statements for Energy Infrastructure, October
DECC (2010b) Revised Draft Overarching National Policy Statement for Energy (EN-1), London, TSO, October
DECC (2010c) Revised Draft National Policy Statement for Nuclear Power Generation (EN-6),Vol. 1, Vol. II Annexes A, B, C London, TSO, October
DECC (2010d) Habitats Regulations Assessment: Site Report for Bradwell, October
DECC (2010e) Appraisal of Sustainability: Site Report for Bradwell, October
DECC (2010f) The Government Response to the Consultation on the Draft National Policy Statements for Energy Infrastructure, October
DECC (2010g) Appraisal of Sustainability of the revised draft Nuclear National Policy Statement: Main Report. October
DECC (2010h) Habitats Regulations Assessment of the revised draft Nuclear National Policy Statement: Main Report, October
Defra (2008) Managing Radioactive Waste Safely: A Framework for Implementing Geological Disposal. Defra and Devolved Administrations, CM 7386, June
Environment Agency (2010) Environment Agency Generic Design Assessment: AP1000 Nuclear Power Plant Design by Westinghouse Electric Company LLC: UK EPR Nuclear Power Plant Design by Areva NP SAS EDF; Consultation Documents, June
House of Commons (2010) The proposals for national policy statements on energy, Energy and Climate Change Committee, Third Report of Session 1009-1-, Volume 1, HC 231-1, March
Kaatsch, P., Spix, C., Schulze-Rath, S., Schmeidel, S. and Blettner, M. (2008), ‘Leukaemia in young children living in the vicinity of German nuclear power plants’. International Journal of Cancer, Vol. 122 (4), 15 Feb., 72
NRPB (National Radiological Protection Board), (2004), 9th report of the COMARE
Nuclear Consultation Group (2009) Consultation on the Nuclear Industry Association’s Application to Justify New Nuclear Power Stations: Response from the Nuclear Consultation Group (NCG)
Pidgeon, N., Henwood, K., Parkhill, K., Venables, D. and Simmons, P. (2008) Living with Nuclear Power in Britain: A Mixed-methods Study, Cardiff University and University of East Anglia. ESRC Social Contexts and Responses to Risk (SCARR) Research Report, School of Psychology, Cardiff
ANNEXES/
ANNEX A
LIST OF PREVIOUS RESPONSES FROM THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG) TO GOVERNMENT CONSULTATIONS ON NEW NUCLEAR BUILD
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 Paper No.1)
BANNG (2009a) ‘Have Your Say’ Government Consultation on Nomination of Sites for New Nuclear Power Stations, Response to the Consultation by BANNG, May
(BANNG Paper No.2)
BANNG (2009b) 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 Paper No.3)
BANNG (2010a) 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), February (BANNG Paper No.4)
BANNG (2010b) House of Commons Energy and Climate Change Committee, Inquiry into Energy National Policy Statements, Evidence on Behalf of the Blackwater Against New Nuclear Group, January (BANNG Paper No.5)
BANNG (2010c) Environment Agency Generic Design Assessment AP1000 Nuclear Power Plant Design by Westinghouse Electric Company LLC: UK EPR Nuclear Power Plant Design by Areva NP SAS EDF; Consultation Document, Response by Blackwater Against New Nuclear Group (BANNG), October (BANNG Paper No.6)
BANNG (2010d) The Justification of Practices Involving Ionising Radiation Regulations 2004. Consultation on the Secretary of State’s Proposed Decisions as Justifying Authority on the Regulatory Justification of the New Nuclear Power Station Designs Currently Known as the AP1000 and the EPR, response to the Consultation by the Blackwater Against New Nuclear Group (BANNG)
(BANNG Paper No.7)
BANNG (2010e) The Energy Act 2008, Consultation on the Financing of Nuclear Decommissioning and Waste Handling Regulations, Consultation on a Methodology to Determine a Fixed Unit Price for Waste Disposal and Updated Cost Estimates for Nuclear Decommissioning, Waste Management and Waste Disposal, Response of the Blackwater Against New Nuclear Group, June (BANNG Paper No.8)
ANNEX B/
ANNEX B
1. Transcription of the proceedings of the Public Meeting, held on
1 December, 2010 at West Mersea at which the Speakers were Hergen Haye, Head of New Nuclear Development and Professor Andrew Blowers, OBE, Chair of the Blackwater Against New Nuclear Group (BANNG).
A DVD is being dispatched separately in the post. It is not possible to send the information electronically as it is too long. DECC will shortly transcribe the Question and Answer part of the proceedings and BANNG will transcribe the whole of the proceedings in due course.
2. Report on the Public Meeting, held on 1 December, 2010 from the Mersea
Island Courier, dated 17 December, 2010.
Bradwell new nuclear ‘untenable and unnecessarily hazardous’
Last public consultation on controversial plan
Seventy-five people struggled through ice and snow on the evening of 1 December to attend a public meeting at the MICA centre in West Mersea to discuss proposals for a new nuclear power station at Bradwell. Hergen Haye, the government’s head of new nuclear development, gave the official position and was opposed by Professor Andy Blowers, chair of the Blackwater Against New Nuclear Group (BANNG).
According to Professor Blowers, this was the last chance for local people to express their views on the proposal, although Hergen Haye claimed that if a formal application to build a power station at Bradwell were eventually received, there would be further public consultations. At the moment, the site is up for sale by its current owners, French power company EDF, and no developer has so far come forward with an offer to buy it.
Mr Haye opened the meeting by stating that he was there to listen to what people had to say and he assured the audience that their views would be taken into account when final decisions were being made. He admitted that the previous consultation process held earlier in the year had been unsatisfactory, and it was for this reason that the government was now seeking to reassure the public that decisions on new nuclear development were being considered openly and fairly.
He claimed that there was a definite and agreed need for the expansion of nuclear energy facilities to ensure that carbon emissions were reduced in line with international agreements and to provide a secure supply of energy for the foreseeable future. The government had a duty to develop a range of technologies, including nuclear power, renewables and carbon-based sources “simply to ensure that the lights stay on”.
He explained that Bradwell was one of only eight sites in the country considered “potentially suitable” for nuclear development and that the previous consultation had revealed certain key issues that needed to be addressed. These included the storage of high-level radioactive waste in an area that was liable to flooding; the impact of large volumes of cooling water on the ecology of the Backwater estuary; and the problems of evacuating the local population in an emergency.
According to previous government statements, nuclear waste was to remain on the Bradwell site for at least 160 years, but Mr Haye now claimed that this had been a conservative estimate which had now been revised down to about 100 years. He added that in the next century facilities could be in place, possibly near Sellafield in Cumbria, at which legacy waste (that which has already been created by the nuclear industry, including large amounts currently stored at Bradwell) and new radioactive waste would be deposited. He admitted that, as yet, neither the technology nor any firm agreement existed to make this possible.
The question of flooding was then addressed and it was noted that the majority of the Bradwell site lies in a Zone 3 area (high risk of flooding). The government claimed to have studied all the available estimates of future flood risk up to 2100 and had come to the decision that Bradwell could “potentially be protected”.
Professor Blowers then addressed the meeting and stated that, regardless of all the technical, commercial and political decisions that were being made, the question of whether or not there should be a new nuclear reactor at Bradwell was essentially a moral issue. The legacy of dealing with the enormous amounts of highly unstable radioactive waste that would be passed on to future generations was something that should be paramount in the minds of those whose remit it was to design a long-term national energy plan. However, like the previous government, the coalition was making up policy on nuclear waste disposal as it went along. He said “There is no fixed delivery timetable for disposal, so how can they be confident that they will find a way to develop a safe repository to hold the waste? There is no agreed location and no technology that can deal with it, so the strong likelihood is that it will have to stay on the site where it was produced.
“The government accepts that beyond 2100 predictions about global warming and the possibility of serious flooding become completely unreliable. There could easily be a temperature increase of over 6°C by the end of the century, and this would almost certainly result in calamitous flooding of the area. But they still say that the site is viable for nuclear waste storage for many years beyond 2100. The mitigation claims are simply not credible. It’s a confidence trick based on the hope that the government and the energy companies can safely manage reactors and the waste they produce. They can’t.”
He claimed that the government’s position was deliberately obfuscated and that the public had simply been told that the building of nuclear reactors was necessary and would go ahead in the eight listed sites, period. They had not said how much it would cost, when it would happen, in which sites it would begin or which companies would be involved. In Bradwell, for example, nobody could say whether there would be one, two or even three reactors. In any event, new nuclear build on the Blackwater estuary would, he said, signal the beginning of extensive industrial development in the area and all the environmental, health, transport and economic problems that would entail. It would mean the complete transformation of the estuary, turning it into something more like the Thames than the Stour.
The question of emergency evacuation was then addressed, and Professor Blowers explained that Mersea Island was not even listed in the government’s detailed emergency zone document, which mentioned only Bradwell, Tillingham, Southminster and Burnham. “It’s a grossly irresponsible document”, he continued. “The fact that it ignores a place like Mersea, where the population in the summer doubles and there is only one way in and one way out, indicates that the government has no answer to the problem of evacuating the Island. It prefers to ignore the issue completely.”
There followed many lively and thoughtful contributions from the floor, many of which echoed BANNG’s concern that the consultation process was no more than a confidence trick designed to legitimise a decision that had already been taken.
Shirley Swan asked how the government could expect people to believe that appropriate waste disposal methods would be developed in the future. “How can you predict what the world will be like in 100 years’ time?” she added. “How can we know that storage either on site or elsewhere will be safe? It’s future generations that will have to deal with our waste for thousands of years to come.”
Ian Clarke wanted to know why the government had not made it clear from the start that Bradwell was to be more than simply a nuclear power station. “You did not mention the fact that it was to be a radioactive storage facility too,” he said “and if you had you might have got more public attention from the beginning.”
Margot Bailey asked how the nuclear waste would be safely transported to a repository, possibly on the other side of the country (“By train? Wouldn’t that be a little dangerous?”), while Claire Webb wondered if there was any scientific evidence that storage of nuclear waste could ever be considered safe. Christine Benner referred to the earthquake of 1884, and asked “How can you talk with confidence about future storage of radioactive waste when there is always the possibility of another earthquake in the area?”
John Harrison observed that the government’s plan was entirely dependent on private enterprise, unlike the first tranche of nuclear power stations that were financed with public money. “If, for some reason, the private companies decide that they don’t want to build these things, the lights will go out anyway.”
In reply, Hergen Haye insisted that the storage of nuclear waste would be a paramount concern when final decisions were being made and that the relevant agencies would make a detailed assessment of the safety of all options. “We have some very robust regulations in place that licence holders must abide by”, he said. “Unfortunately, nuclear power creates waste. We wish it didn’t, but it does. Nevertheless, we must also mitigate the effects of climate change because that too is a devastating legacy for our children to deal with.
“Only when companies decide to build power stations will we be able to look in detail at the exact way they propose to deal with the issues that have been mentioned.”
He went on to confirm that the private operators of new nuclear power stations would be wholly liable for the cost of decommissioning and a share of the cost of putting waste into the depository, adding “We will say how that figure will be calculated in a few weeks’ time.”
In reply, Barry Turner, who was chairing the meeting, asked how the government would be able to calculate any costs when they did not yet know how or where they were going to store the waste.
Professor Blowers commented “It is a false ethical argument to claim that low-carbon nuclear energy is necessary to combat the dangers of climate change. What the government does not say is that the danger of nuclear energy is as great if not greater than the danger of climate change.”
Questioners then focused on the environmental impact that the development would have on the estuary and the corollary issue of cooling towers.
Dave Smart claimed that the warm water to be pumped into the estuary would destroy the plankton which is vital for the survival of life further up the food chain. He asked what measures would be put in place to prevent this from happening. Oysterman Alan Bird added “On Mersea we have the last native oyster farm left in the British Isles. Where’s the evidence that the site will remain safe for this to continue?”
Ian Clarke reminded the audience that in the winter of 1963, severe icing on the river caused an emergency shutdown at the old nuclear plant, a fact that was not reported for a further 25 years. “The estuary is notoriously shallow”, he said “so icing will continue to be a problem.” Sylvia Wargent added that if the estuary was too shallow for its water to be used in the cooling system of a new plant, cooling towers would have to be built instead. She asked for confirmation that these would not be pumping out toxic radionucleides.
Mr Haye replied that no decision had yet been taken over whether cooling towers would be built on the site since it was not yet known how many power stations there would be, but if more than one was proposed, it was certainly the case that cooling towers would be necessary. A single reactor would use water from the estuary, but only once detailed proposals were received could assessments be made of precisely where the input and output pipes should be located. He assured the audience that if cooling towers were to be used, they would emit only steam.
Professor Blowers said “Local industries such as fishing and tourism will be sacrificed for what is referred to as the ‘overriding public interest’, but is it really in the national interest to have large amounts of radioactive waste stored in vulnerable sites? We are not nimbys, we simply believe that nuclear development on the Blackwater estuary is untenable and unnecessarily hazardous.”
Quoting from a statement from the Environment Agency, he read “ ‘The Environment Agency has advised that it is 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 and taking into account possible countermeasures.’ That sounds like an awful lot of assumptions to be making about something as important as the protection of a nuclear power plant.”
He went on to question the validity of the consultation itself, claiming that the process was not about engaging with the public and listening to their views, but about the power relationship between the government and multinational energy companies. “Have no doubt,” he said “the chair of EDF can pick up a phone and get a meeting with secretary of state Chris Huhne tomorrow. I can’t.”
The meeting had clearly been overwhelmingly hostile to the government’s proposals, but there was also a widespread feeling that public views would count for little against the combined power of the government and the nuclear industry.
Varrie Blowers, secretary of BANNG, called the entire consultation process into question when she said “DECC believes that its previous consultations were ‘of an extensive nature’. I would contend that, BANNG has done much more than the government or the local councils to raise public awareness of the proposals for Bradwell, particularly regarding the long-term storage of highly radioactive spent fuel on the site. This issue was carefully subsumed and made little of in the government’s consultations and local MPs, local councillors, the public and even workers in the nuclear industry have had to rely on BANNG to tell them about it.
“Although it is not perfect, the BANNG petition appears to be the only large-scale, face-to-face consultation in the country on public attitudes to new nuclear development. The government has done nothing even faintly similar and has habitually asserted that nuclear communities welcome the prospect of hosting new power stations, although of course, they never make any mention of the requirement to host highly radioactive spent fuel dumps until well into the next century. I have to tell the government that the thousands of people approached by BANNG have made it abundantly clear that they do not want a new nuclear power station at Bradwell or the toxic spent fuel dump that goes with it.
“I am angry that it has been left to a small number of highly pressurised, unpaid volunteers to explain the government’s proposals. That BANNG has had to do so, speaks volumes about the inadequacy and inefficiency of the government’s cynical but, we are told, extensive consultation process.”
She went on to ask Mr Haye why the previous consultation had been restricted to the small towns of West Mersea, Maldon and the village of Bradwell, and why it had not included much larger towns such as Colchester, which with a population of around 150,000, is geographically closer to Bradwell than Maldon is.
“Given that the select committee did not consider that the previous consultation exercise had gone far enough in engaging the public and that the government should learn lessons,” she continued “can he explain why DECC is not proposing to hold public meetings at this stage? I’ve been checking and have discovered that you are only going to local meetings when you have been specifically invited.”
Mr Haye replied that the meeting had been a wonderful example of community spirit and calling it into question served only to diminish it.
Chairman Barry Turner felt that Mr Haye had not been able to answer the questions or address the concerns that had been expressed to the satisfaction of the meeting. Urging everyone to respond to the re-consultation on the national policy statements, he said “We have until 24 January to make our voices count and to try to get Bradwell taken off the list”.
Responses can be made online at: https://www.energynpsconsultation.decc.gov.uk/consultation/
by email to: nps.consultation@decc.gov.uk
or by mail to:
Energy NPS consultation
Department of Energy and Climate Change
3rd floor A
3 Whitehall Place
London
SW1A 2AW
The consultation process closes on 24 January when revised proposals will be prepared for parliamentary consideration.