BRB Planning Application: FUL/MAL/20/00157: Land East of Bradwell Power Station, Downhall Beach Bradwell-on-Sea
Application to carry out ground investigations, load test and associated works in connection with a proposed Nuclear Power Station at Bradwell-on-Sea, together with the creation of two site compound areas and associated parking areas
Comments from the Blackwater Against New Nuclear Group (BANNG)
(BANNG Paper No. 42)
The Blackwater Against New Nuclear Group (BANNG) was established in 2008, ‘to seek to protect the people and environment of the River Blackwater estuary and its surrounding area, now and in the future, from the risks and dangers of radioactivity by preventing further development of nuclear activity in the estuary’. BANNG has supporters from around the estuary, including the Dengie Peninsula, Maldon District and the region to the north of the river, including Mersea Island, Tollesbury and Brightlingsea. We consider the communities within this area are potentially affected by the planning application for ground investigations.
Over the years BANNG has responded to numerous consultations, reports, planning applications and other matters from central and local government, regulators and developers (click here to see BANNG papers). Among the issues we have considered are: siting strategy for nuclear power; justification of nuclear energy; national planning policy for nuclear energy; radioactive waste management; managing the nuclear legacy, including Bradwell A; nuclear accidents; and development proposals at sites, including Hinkley Point C, Sizewell C as well as Bradwell B.
BANNG responded to the previous application for ground investigations and associated works in November 2017 (see BANNG paper No. 33, Annex). Our response at that time was summarily dismissed on the grounds that the application related only to impacts of the ground investigation works and not the principle of the development of the power station itself. We consider this interpretation is too narrow and will argue that the application is unnecessarily disruptive and potentially damaging and is undertaken in preparation for a far more damaging industrial complex that will create environmental harm and risks to safety and health throughout its operations lasting until well into the next century. Indeed, we consider it would be futile to undertake site investigations for a site that may well not be viable under the impacts of future climate change.
Our response covers similar ground to our previous response. We are, therefore, submitting our previous response as an integral part of this response (Annex). However, there are some significant changes which have occurred in the two years since our submission. Three in particular may be noted. First, the argument for nuclear energy has significantly weakened in the light of growth of renewables and nuclear’s economic and technological problems. Second, concerns and uncertainties surrounding climate change have intensified and specifically make the development of nuclear power stations on fragile and vulnerable coasts unrealistic. And, third, the developer of Bradwell has now published ideas and concepts for Bradwell B which reveal the vast scale and impact of the proposal on local communities and environments:
These changes reinforce our view, expressed in our former response.
We consider that the application must be refused on the primary grounds that the site is wholly unsuitable, unsustainable and unacceptable for the development of a nuclear power station and its associated spent fuel stores, cooling water infrastructure, port facilities and other ancillary structures. Consequently, it is concluded that the intrusive, disruptive and potentially damaging ground investigations proposed cannot be justified.
The following section examines each of the three significant changes: need for new nuclear; impacts of climate change; and scale of the development.
1.The proposal is not justified
The application for ground improvements relates to a proposed nuclear power station which, it is claimed, ‘would make a vital contribution to meeting the UK’s future need for low carbon, secure and affordable energy..’ (BRB, p.3).
There are two elements to this. First, the need for nuclear energy is a matter for government, which is currently reviewing its energy strategy to be published in a forthcoming energy white paper. Second, the National Policy Statements for Energy and Nuclear Power published in July 2011 are currently under review with implications for the Bradwell site (DECC, 2011 a and b).
In our previous submission we argued that, for various reasons, the need for nuclear energy could not be justified. However, government policy enshrined in National Policy Statements EN-1 and EN-6 asserted that nuclear energy was an essential part of the energy mix and was a necessary low carbon source of electricity to meet the carbon reduction targets. The consultation on siting criteria and process for a new National Policy Statement was published in 2017 (BEIS, 2017) but the revised NPS has not yet been published.
Although the consultation claims that the NPS on Energy EN-1 ‘remains valuable and continues to be relevant’ (DECC 2011a, p.11) it is only an interim position statement since the NPSs are only valid for the deployment of new nuclear power stations until 2025. During the period since first publication in 2011 there has been a fundamental transformation in the energy scene. Renewable energy has become increasingly competitive while nuclear’s costs have continued to increase to the point where the market alone has not been able to provide investment without government support through fixed price guarantee, potential direct subsidy or the putative regulated asset base (RAB) method. Of the eight sites deemed deployable for nuclear energy in 2011, only Hinkley Point C has proceeded to the point where it has been confirmed as a site beyond 2025. Moorside and Wylfa Newydd have fallen by the wayside as investors have withdrawn, leaving Sizewell C and Bradwell B as the only sites where active development continues. The need for nuclear is diminishing and, by the time these two plants could be operating (say, mid 2030s) nuclear energy will likely be in direct competition for energy supply with a varied mix of renewable tehnologies and supply systems. Even at that point Sizewell B and probably Hinkley Point C will be supplying 4.5GW of expensive and unnecessary electricity to the mid-century and well beyond. It must be anticipated that, sooner or later, the two projects at Bradwell B and Sizewell C will fall thereby making this current planning application irrelevant.
Moreover, the Bradwell site is only designated until 2025 and the purpose of the 2017 consultation is to establish criteria on which applications for siting new nuclear power stations above 1GW may be decided for deployment from 2025 up to 2035. The consultation states its preliminary view that the sites already nominated in EN-6 are likely to be those which can deploy the soonest and are the only sites capable of deploying a nuclear power station by 2035. This is a claim, it has not been tested and neither revised criteria nor responses to consultation have been published. In effect, then, the Bradwell site does not exist as a designated site beyond 2025 which is a date well before Bradwell B could be deployed.
Therefore, BANNG considers that:
It is would be premature to grant permission for ground investigations for a power station that is unlikely to be justified and on a site that may well not be designated. At the very least it would make sense to delay or defer this application until government policy on nuclear energy and on siting new nuclear power stations has been clarified.
2. The implications of climate change
A new nuclear power station at Bradwell, if built, would operate for around 60 years and decommissioning, including the management of spent fuel on site, would extend up to fifty or more years beyond that. In short, Bradwell would be a radioactive liablility until the second half of the next century and could remain so indefinitely.
The site is vulnerable to flooding, storm surges and coastal processes and will become unviable in the long term. The application, which applies to ground investigations lasting three years, indicates the flood risk is negligible. However, in the long term this is a site that is highly likely to experience inundation and experience the significant changes that are already being modelled and predicted for the East Anglian coast.
Since the earlier application was made in 2017, climate change impact forecasts have become increasingly uncertain and severe. If present trends continue, global warming may well be over 2°C to 4°C by the end of this century. The Met Office forecasts (UKCP18) indicate sea level continuing to rise to around 1m. by 2100 and, if warming is 5°C could lead to 2m. which would lead to severe land loss. At that level of warming, by 2200, loss of Antarctic Ice sheets and other processes could, according to one prediction, lead to a 7.5m rise. The point is the further ahead we look the more uncertain forecasting becomes until it reaches indeterminacy or the unknowable.
Nuclear developers must plan for worst case scenarios and ‘confirm that they can protect the site against flood-risk throughout the lifetime of the site, including the potential effects of climate change, storm surge and tsunami, taking into account possible counter-measures’ (DECC, 2011b, 6 p.24). The approach is to defend the site by a process of ‘managed adaptation’. In the case of Bradwell this would involve raising the nuclear island 7m. above sea level and constructing hard defences up to 10m. AOD above sea level, regarded as sufficient to withstand flooding from extreme weather events for the lifetime of the plant and taking account of climate change. It is simply not credible to assume that managed adaptation will prove technically, economically and socially sustainable in the unknowable conditions of the future when the site becomes unviable. The only safe option is mitigation, in other words, not building the plant in that location in the first place. Therefore,
The site for BRB is highly likely to become unviable and unmanageable during the indefinite lifetime of its operations, including decommissioning and radioactive waste management. Consequently, it is considered that there is no purpose in considering the application for ground investigations for development of a nuclear power station on a site that is likely to prove unviable during the course of its lifetime.
3. The scale of the project
The previous application for land investigation works was intended ‘to inform the design of a potential new nuclear power station on the [Bradwell] site’. Since that application was approved the developer, Bradwell B, has published its Stage One Pre-Application Consultation which provides details of the aims of the project together with initial proposals and options. It also shows the scale.
The present application for ground investigations, load test and associated works gives some indication of the scale of the whole project. Drilling will reach a depth of around 100m. and will pass through the London Clay beds and possibly reach the underlying Chalk layer. The load test, though relatively modest in scale, would be the prelude to a vast void for the concrete foundations of the nuclear island.
The whole complex consists of two reactors each of 1.15GW, turbines and associated works, cooling towers and tunnels into the Blackwater estuary, long-term radioactive waste stores, including for spent fuel, beach landing and ferry facilities, access roads and high voltage transmission towers. The project encompasses a substantial part of the north east Dengie Peninsular and will have a major impact on its terrestrial and marine ecology. It is no exaggeration to say that it will utterly transform the region, turning a peaceful, protected environment and communities into an intrusive, dangerous, polluting industrial complex.
The stage one plans for the Bradwell B power station indicate a project that is vast in scale, intrusive in impact and environmentally damaging in the regional context. The proposal for land investigation works should, therefore, be resisted on the grounds that it may set a precedent for an unacceptable and transformative development in this location.
4. Environmental impacts
The environmental impacts resulting from the investigative works will extend over a period of three years. It must be questioned whether these impacts, however minimised or mitigated, are sufficiently tolerable for the purpose of land investigations. Given that the ground works are unnecessary, premature and avoidable as we have argued in previous sections, the application should be denied or at the very least deferred. Seen in the context as a prelude to the development of a massive power station it would seem perverse to grant permission at this stage. Our brief comments on environmental impacts below should be read in conjunction with a rather fuller commentary in our previous response (Annex).
Noise: The noise, light pollution, disturbance and disruption created during the construction of a new nuclear power station will impact over a wide area for a period of up to twelve years. The application should be refused to ensure no further development on the site.
Heritage: The application for land investigations would attempt to mitigate adverse effects on heritage and landscape. The Dengie Peninsula has a rich heritage including St. Peter’s Chapel and the Othona Fort as well as significant archaeological remains. The landscape of the Dengie is remote, flat, modest and low lying where land, sea and sky meet in an ever changing harmony. While the land investigations will have relatively low level impact they foreshadow a project that will utterly destroy the uniqe tranquillity of the region.
Ecology: The Dengie Peninsula is rich in ecological features and habitats. Close to the site are significant international, national and locally designated areas for protecting habitats and species. The area is rich in mudflats and saltmarshes reedbeds and grazing marshes, small woodlands and hedgerows and habitats for flora and a range of avian species, notably bearded tits, hen harrier etc and especially dark-bellied brent geese which overwinter here in vast numbers. There are important assemblages of flora and the area is rich in certain mammals such as voles and owls. The Essex Wildlife Trust and the RSPB will, no doubt, make detailed observations on the ecological importance of the area.
The Ecological Appraisal and HRA indicate that the proposals will result in localised ground disturbance and that the risk to sensitive ecological receptors will be minimal. There will, no doubt, be some disturbance, however minimal and it has to be asked whether that is justifiable to prepare the way for a planning application for a project that is unnecessary and undesirable.
Again, the impact of developing, operating and ultimately decommissioning a nuclear power station over a period of at least 150 years is likely to be devastating for the environment, ecology and wildlife of this precious area.
Permission for land investigations should be refused on the grounds that it would pave the way for a potential application for a new nuclear power station that would unnecessarily utterly disturb and destroy the precious terrestrial and marine ecology of the Dengie Peninsula and Blackwater estuary.
Prepared on behalf of the Blackwater Against New Nuclear Group (BANNG) by Professor Andrew Blowers, OBE, Chair of BANNG. March 24 2020
Bradwell B Stage 1 – Consultation Summary Document
BEIS (2017) Consultation on the Siting Criteria and Process for a New National Policy Statement for Nuclear Power with Single Reactor Capacity over 1 Gigawatt beyond 2025
DECC (2011a) Overarching National Policy Statement for Energy (EN-1), June
DECC (2011) National Policy Statement for Nuclear Energy Generation (EN-6), June