March 16 2020
To: Alan Raymant, CEO, Bradwell B; Kate Stinton, Head of Communications, Bradwell B
Dear Alan and Kate,
Cancellation of public exhibition events for pre-application of Bradwell B
I am writing on behalf of the Blackwater Against New Nuclear Group (BANNG) about the cancellation of the remaining exhibition events in the pre-application consultation on account of the coronavirus epidemic.
BANNG fully understands and supports the reasons for the cancelation of the events. However, we note that the consultation otherwise continues as planned and will be open for feedback until 27 May. We are unable to understand the continuation of a partially completed process and consider the consultation process as a whole should be abandoned.
Those places which will now be excluded from the exhibitions will be denied the access to your expert team, information and available documents. Visitors will not be able to pose questions, raise issues and engage in discussion and argument. I was most impressed with the good attendance, interest and intensity of interaction that I witnessed at the Maldon exhibition on 6 March. I have been told that exhibitions were well attended elsewhere, notably that at Bradwell, where exchanges were lively and occasionally emotional.
Exhibitions encourage the interested public to visit and to provide you with face-to-face feedback. Some will also respond online or by post. It is unlikely that visitors to exhibitions will provide no feedback at all.
Those places where exhibitions have been cancelled are placed at a serious disadvantage. Potential visitors have no opportunity to meet your team and get first hand information which will enrich their knowledge of the project. Moreover, they will have to rely on information and documentation provided online or accessed at local libraries and council offices. There are substantial numbers of people who do not have ready access to online information and who may be unable to visit the places where information is provided.
Exhibitions were held at only five of the fifteen places listed. Within the remaining ten there were the only three – Mersea, Tollesbury and Brightlingsea – on the northern side of the Blackwater estuary. It is a moot point why no exhibitions were planned for such significant places as Wivenhoe, Tiptree or even Colchester which is much closer to Bradwell than Maldon. As a result of the cancellations and omissions there will be no direct feedback from those places where the public has expressed serious concerns about the impact of cooling water on the estuary, the problem of emergency planning, environmental threats to precious habitats and marine ecosystems, the storage of radioactive wastes and other matters.
Consequently, on the basis of the five exhibitions already held, you will be unable to gain an overall perspective on the concerns of the Blackwater communities. A partially completed consultation can only result in a partial understanding of issues of concern to the public.
You will already be aware of the intense feelings evoked by the project which will manifestly transform a peaceful, environmentally significant coastland into a turbulent, disruptive and dangerous industrialised region. By terminating the exhibitions the full extent of public concern will not be manifested.
We urge you to cancel the consultation as a whole and rerun it once the present public health emergency is over.
I am copying this letter to the Office for Nuclear Development, Environment Agency, Office for Nuclear Regulation, Infrastructure Planning Inspectorate and Sir Bernard Jenkin, MP.
Yours sincerely,
Prof. Andrew Blowers OBE
Chair, BANNG and Co-Chair, BEIS/NGO Nuclear Forum
c.c.
Stephen Speed, Office for Nuclear Development, BEIS
Alan McGough, Environment Agency
Mark Foy, Adriènne Kelbie, Office for Nuclear Regulation
National Infrastructure Planning Inspectorate
Sir Bernard Jenkin, MP
Reply From: Kate.S <>
Subject: RE: Postponement of part of pre-consultation consultation on Bradwell B
Date: 24 March 2020 at 17:06:49 GMTTo: Andrew.Blowers <>, Yuliya Kozak <>
Dear Andrew,
Thank you for your letter regarding the Bradwell B consultation.
As I’m sure you’ll appreciate making the decision to cancel our remaining events was a difficult one, but, given where we are today, definitely the right one. Where possible we will re-arrange events but this will depend on the situation with Covid-19 and guidance from Public Health England.
The events however are only one aspect of the consultation and there are many other ways for people to interact with the project, learn about the proposals and provide feedback. You can view the proposals online at , and you can also ask questions of our team via email or phone. People can respond to the consultation via our online form, a hardcopy of the questionnaire (which you can download from our website), and via letter or phone to our freepost address FREEPOST Bradwell B Consultation.
This is not to say that we don’t see the value of holding exhibition events, we certainly do. However we are working on introducing alternative ways for the local community to be able to engage with the proposals and ask questions which will add significant value to the consultation process.
It is also important to remember that, whilst this consultation stage is a limited time period, we fully intend to continue to engage with the local communities in detail about the proposals beyond any end date when there will be significant opportunity for people to continue to have their say and influence the proposals.
Thanks once again for your letter and I hope you and your family stay safe and well.
Regards,
Kate
Kate Stinton
Head of Bradwell B Communications
Bradwell Power Generation Company Limited
April 2 2020
To: Kate Stinton, Head of Communications, Bradwell B
Dear Kate,
Extension of deadline for pre-application of Bradwell B
Thank you for your reply to my letter of March 16 which urged you to cancel the pre-application altogether on grounds that it would only be partially completed in the absence of ten of the fifteen exhibitions that were planned.
The reply does not meet the basic points in my letter. BRB have not acknowledged the fact that, in the absence of exhibitions, citizens in several areas and notably those north of the Blackwater estuary, will be denied the opportunity of in-depth, face-to-face interaction with the BRB team. Equally BRB will not be able to receive direct and sometimes forceful and passionate feedback from people deeply affected and sometimes distressed by the proposals.
I do not wish to repeat my arguments here in full; they are clearly expressed in my original letter. But, it would be helpful if some attempt were made to answer them in order to justify the decision to continue with the consultation.
It was clearly BRB’s initial intention to continue with the original closing date for the consultation. It was indicated that events might be re-arranged if that were possible in the Covid-19 situation. Further, it was understood that alternative ways of engagement with the local community would be introduced to add significantly to the consultation process.
I have now learned from the latest post on the BRB website that it has been decided to extend the consultation period by five weeks, ending on July 1. In addition, additional ways of engaging online, by phone and through ‘a virtual version of our public exhibition events’ have been devised.
You will forgive me if I regard this as a disingenuous attempt to resurrect the consultation process by offering a plausible but unrealisable attempt to substitute virtual for real life interaction.
Your initial move to cancel the exhibitions on account of coronavirus was a step in the right direction. BANNG urged you to cancel the whole consultation and to rerun it at a time when the emergency was clearly over and a full and fair process could be undertaken. We think it unwise and irresponsible to continue with the consultation during a time of national emergency when most non essential activities are closed down and the population is suffering lockdown.
We can only conclude that BRB is more concerned to ‘ramp up’ the development at a time when the vast majority of the population is distracted. In a situation of lockdown it is hardly to be expected that people will wish to respond to a consultation, no matter how significant, at a time when their overriding concern is daily survival in the presence of coronavirus.
In short we do not consider the proposed extension of the process with additional activities can in any way substitute for the consultation process originally envisaged. Further, we deplore the opportunism implied by continuing to run an unnecessary, and premature, consultation at this time of national emergency, We, therefore, urge BRB to cancel the process and, if necessary, rerun it when the country is in a more normal situation.
Yours sincerely,
Prof Andrew Blowers OBE
Chair, BANNG
c.c.
Alan Raymant, CEO BRB
Stephen Speed, Office for Nuclear Development
Adriènne Kelbie, CEO, Office for Nuclear Regulation
Alan McGough, Environment Agency
National Infrastructure Planning Inspectorate
Sir Bernard Jenkin MP
9th April 2020
To: Prof. Andrew Blowers OBE
Chair, BANNG and Co-Chair, BEIS/NGO Nuclear Forum
Dear Andrew,
Thank you for your letter of 2 April 2020 addressed to Kate Stinton. This follows your letter of 17 March to which Kate Stinton replied on 24 March. Taking both letters together I understand your main points are:
(a) the consultation presently being carried out by BRB should stop and restart at some point in the future when the COVID crisis is over;
(b) the loss of the public exhibitions that were to take place in the consultation is preventing people making in- depth face-to-face representations;
(c) people cannot be expected to participate in this consultation when they are in lockdown, and
(d) the consultation is, in any event, unnecessary and premature.
The Bradwell scheme is a nationally significant project for which there is an urgent national need and it is in the public interest, including in light of the COVID crisis, that consideration of this proposed development is not indefinitely or even substantially delayed.
The cancellation of the public exhibitions was a necessary and proportionate response to the COVID crisis but total cessation of this round of consultation is neither necessary nor proportionate. Having prepared extensive detailed material expressly for the purpose of introducing the project to the public and seeking feedback upon it, the Bradwell B (BRB) project believes it has taken the right approach in identifying and promoting a range of alternative methods by which people can access that information, in lieu of the proposed exhibitions and public meetings.
The identified approaches include a range of ways in which individuals or groups can separately or jointly raise questions and seek direct feedback from experts within the team, as they would at public exhibitions. These initiatives have been reviewed against the legislation and guidance regulating pre-application consultation, and in particular the type of non-statutory consultation that is presently underway.
BRB is satisfied that these approaches are robust, meet the objectives of the consultation and will allow the public to fully engage. Whilst exhibitions enable people to view material without going online and to have access to expert advice, we are confident that the approaches we have identified are a fair and flexible means of dealing with the unprecedented circumstances arising from the COVID crisis that will allow people to make their views known as forcefully as they wish. BRB is also keeping under review developing proposals for alternative means of consultation which are appearing in response to the COVID crisis and is benchmarking its own proposals against those including extending the consultation period to allow further time for responses.
The alternative public consultation approaches being implemented include:
( Exhibition boards available as part of a virtual exhibition online;
( The proposals published as part of an interactive webpage, in addition to consultation documents being available online, which provides an additional route to explore the information;
( People able to ask questions in the way that they would of specialists at the exhibition via pre-booked telephone surgeries. The existing telephone and email community lines continue to remain open for enquiries outside of this initiative;
( Parish Councils being offered the opportunity for meetings that are managed virtually through dial-in by telephone or home computer accessed video conference.
Finally, to ensure that no-one misses a chance to respond we have extended the deadline for responses to our consultation by five weeks, to 1 July 2020.
The adequacy of the consultation now taking place, including its duration, are being kept under review in the light of the responses received. As with most major projects, we will be delivering a further stage of consultation on our proposals at a later date once we have taken into consideration the consultation responses received at this stage and results from our investigative works.
To conclude, you will understand that BRB does not share your expressed opinions about the site being inappropriate for new nuclear development and therefore the consultation being unnecessary and premature. BRB does not accept there should be no consultation at the present time, irrespective of the COVID crisis. In respect to this consultation being premature, on the contrary, it is extremely important that we give our stakeholders opportunity to comment on the project as early as we can practically do so. It is through this approach that they can have the most influence on the project.
I trust you will find these responses helpful but if there are any further points you would like to discuss please let me know. I shall be sharing this reply with those stakeholders you have copied into your correspondence.
Andrew Murdoch
Project Development Office Director
Bradwell Power Generation Company Limited