INTRODUCTION – Reject the Whole Proposal
BANNG’s primary purpose is to oppose the development of new nuclear power at Bradwell in Essex. We also have an interest in generic and specific processes and proposals for new nuclear developments which may have a bearing on the Bradwell development. Our response to the Sizewell application reflects a number of common concerns. One, is that Sizewell and Bradwell are projects being developed by a partnership between EDF and CGN. Although Sizewell is based on the UK EPR while Bradwell is intended for the UK HPR1000, both comprise reactors, waste stores and other buildings which must be accommodated on coastal sites. A second feature is that the sites are hemmed in by areas of environmental significance with many designations, the most notable being the Suffolk Coast and Heaths AONB and Minsmere RSPB reserve in Suffolk and the Marine Conservation Zone in Essex. Thirdly, both are close to substantial populations with Leiston (Suffolk) and West Mersea (Essex) within two to three miles from the sites. Fourth, both sites are vulnerable to coastal processes, in the case of Sizewell, coastal erosion and at Bradwell flooding and storm surges, problems which will only get worse as climate change wreaks havoc on the fragile and low-lying east coast while the operation and decommissioning of the plants continues into the next century and beyond. And, fifth, as the UK’s nuclear strategy collapses, Sizewell and Bradwell are the two remaining sites which puts enormous pressure on government, developers, regulators and the IPC to ensure the delivery of the two new nuclear power stations. Indeed, CGN has responded to the opportunity presented by stating that, ‘In simple terms, we have ramped up. We are bringing forward [the Bradwell project]’1.
1 Statement by chief operating officer of CGN to Nuclear Industry Association Nuclear 2018 , London, December, 2018.
By any standard, the two projects represent a massive and destructive imposition on precious environments and local communities. It is not stretching the imagination to state that they will transform significant areas from rural, tranquil and low -lying landscapes into massive industrial complexes with all the attendant construction works, noise, traffic and urban development. The Sizewell project must be seen in its totality, not in terms of individual features and mitigations that commensurately are unlikely to prevent the wholesale destruction or to protect the existing environments and communities.
BANNG believes that the environmental impacts, dislocation of communities and scale of development inherent in the Sizewell C proposal are overwhelming, destructive and widespread and cannot be averted, avoided or mitigated. Therefore, we consider the project as a whole must be rejected.
BANNG’S RESPONSE TO THIS CONSULTATION
BANNG has responded to each of the preceding pre-application consultations. Our responses may be found on our website banng.info as BANNG papers 18 and 32 (BANNG, 2013; 2017). We consider most of the concerns we raised have not been fully addressed and that our responses remain relevant to the Stage 3 consultation.
In general we find the present consultation inadequate, incomplete and unconvincing.
Inadequate. The Environmental Impact Assessment is ongoing and the design is still being refined or mitigation measures developed. It is not possible to provide a fully informed response to a proposal that is, by its own recognition, inadequate.
Incomplete. A number of issues are left unresolved, most notably the transportation options. Most significantly it is clear that measures of sea defence are far from finalised. On this issue the Consultation Summary Document makes the limp statement: ‘Our continuing assessments will help us determine how best to protect Sizewell C while limiting effects on the local environment as far as practicable’ (p.12).
Unconvincing. Throughout the Consultation Summary Document it is possible to detect a lack of conviction, as if the developer recognises the enormity of the scale and impacts of the project and the failure of proposed measures to ameliorate them. For instance, on p.9 it states: ‘while our proposals have been designed to reduce the effects of the power station on the landscape and seascape character, it is likely they would still be significant’. This welcome but worrying lack of confidence in the proposals poses a serious challenge; if the developer appears uncertain and unconvinced about the ability to avoid or mitigate harmful impacts, should an application be granted?
Our response addresses strategic siting issues facing Sizewell in common with Bradwell. We shall not address the more detailed, local issues which are more a matter for those who live and know the area. We intend, first, to comment on the policy context with respect to the question of need for the development and the question of site selection. Our basic point here is that fundamental changes have occurred since the project was first put forward that are not recognised. In other words, the underlying premises on which the project is based no longer hold true.
Second, we shall focus on those changes, especially climate change, which will make it impossible to secure the safe and secure deployment of a new nuclear power station and highly radioactive waste stores over the next 200 years. Our response, therefore, intends to address the first two questions in the Consultation document.
Changing context, unchanging proposals
In response to question 1 our views are, bluntly, that there is no need for a new nuclear power station on the Sizewell site. It is stated that, ‘The principle of the need for new nuclear power stations and the choice of Sizewell as a potentially suitable site have already been determined by Parliament’. The policy for new nuclear was originally set out in the Overarching National Policy Statement for Energy (EN-1) where it was stated that ‘new nuclear power should be able to contribute as much as possible to the UK’s need for new capacity’ (DECC, 2011, p.28). It would be up to the market, not government, to determine how much nuclear would contribute but there would be no limit to its part in the energy mix. It was anticipated that its contribution would be around 16 GW coming from new stations deployable by 2025. That policy has not been reviewed or revised since it was first put forward a decade ago. Since 2011 the development of nuclear has been glacial with only Hinkley Point C under construction. By contrast renewable energy, especially offshore wind, has developed rapidly and is now highly competitive and with considerable further growth potential.
Sizewell, along with Bradwell, was one of eight sites nominated as ‘potentially suitable’ for deployment of new nuclear power by 2025. With possibly only one site achieving the 2025 deadline, the government is undertaking a review of the National Policy statement for Nuclear Generation (EN-6) with a view to renominating the remaining seven sites as potentially suitable until 2035. This exercise in legerdemain was to avoid the need to identify new sites. It must be stressed that the revision is still in process and therefore, the Sizewell site is not yet approved for development to 2035. There are good reasons for suggesting it should be delisted though only a fantasist would entertain that as a possibility. In recent months projects at three of the sites – Moorside, Wylfa and Oldbury – have, to all extent and purposes, fallen by the wayside, leaving Sizewell and Bradwell as the only sites still standing. On current planning time-scales it is questionable whether either could be operating before 2030. By then it would be too late to meet any shortfall in electricity supply which would have to be met substantially by renewables.
The National Infrastructure Commission makes the position irresistibly clear: ‘Given the balance of cost and risk, a renewables based system looks a safer bet at present than constructing multiple new nuclear power plants’ (NIC, p.38). The Commission goes on to recommend a ‘one by one’ approach to new nuclear plants which is hardly an enthusiastic endorsement for Sizewell, Bradwell or any other site.
BANNG believes the developers should withdraw their plans for new nuclear stations at Sizewell and Bradwell on the grounds that: a. they cannot be justified in terms of meeting the need for electricity in the late 2030s and beyond; and b. that they would create unnecessary environmental degradation, unacceptable disruption and continuing risk to present and future generations.
We now turn to the second question, What are your views on our proposals for the main development site? Should the project proceed, BANNG has strong reservations about the proposals with respect to strategic environmental impacts and coastal processes.
Scale of the proposals and environmental impact
It is intended to create infrastructure consisting of two reactors, spent fuel store, beach landing platform and associated buildings on the site, together with accommodation blocks, road and rail developments in the surrounding area with direct impacts being felt across a wide area of east Suffolk. It may be argued that development in this location has already been accepted in principle with the creation of Sizewell A (decommissioning) and Sizewell B (operating) which will remain in situ well into the next century. What difference would another nuclear power station make to an area already experiencing environmental devastation and risk? Conversely, it may be felt that this coastal area has already borne a disproportionate burden of destruction and risk on behalf of the wider society and that, on grounds of intergenerational equity, it would be intolerable to increase the impact on present and future generations. The question becomes, Why should the community now and in the future experience increased devastation and risk?
In terms of scale, the Sizewell C site occupies an area greater than Sizewell A and B combined. It is hemmed in by the coast to the east and neighbours an area of designated environments including the important RSPB Minsmere bird reserve to the north. Inland to the west is the sizeable town of Leiston and the whole sub-region. Sizewell occupies a prominent and highly visible central location within the coastal heaths which comprise the Suffolk Coastal and Heaths AONB. The amount of displacement, interference and wholesale destruction of precious habitats is significant but the extent and impact will not be fully clear until the EIA is completed. The developers recognise that there is potential for adverse effects on the integrity of European sites but concluded that no alternatives would be better that could deliver the nuclear power required.
This is an astonishing and absurd assertion unsupported by evidence. By invoking the Imperative Reason of Overriding Public Interest that favours the inclusion of the site in government policy, the developer makes clear that that nuclear energy must triumph over environment at whatever cost. It is conceded that while specific mitigation measures will be necessary, ‘to reduce the effects of the power station on the landscape and seascape character, it is likely they would still be significant’ (Consultation Summary, p.9). We find the statement that, ‘the sensitivities of the location do not in themselves constitute a reason to prevent the site from being considered potentially suitable’ (Development Proposals, 3.3.10, p.38) a matter of opinion, not fact. In our view the sensitivities of this area should be protected at all costs in the local, regional and national interest. The scale of the overall impact would elevate the nuclear complex to an intimidating and dominating feature in a beautiful but open coastal landscape.
BANNG concludes that the physical scale and impacts of the Sizewell C project when combined with the ongoing impacts already experienced from the decommissioning of the A station and the operations and spent fuel storage of the B station will vastly increase the damage to environments and the risk to public health. It will be impossible effectively to mitigate or eliminate these impacts during construction, operation and decommissioning of the power station and associated infrastructures over a time-scale stretching into the far future. Consequently, we urge EDF/CGN to withdraw the proposal.
Vulnerability of the site
As we have indicated earlier, the developers clearly recogniseto the profound impact that the development will make and the significant effects that will arise. The developers rely on the Government’s insistence on the need for nuclear energy to justify the deleterious impacts and effects. The Development Proposals Document makes the point: ‘the development of Sizewell C would not be expected to take place without some significant impacts. However, the assessment recognises the potential acceptability of those impacts in view of the national need for nuclear power generation and the scarcity of alternative sites’ (EDF Energy, 2019, 3.3.6 p.37). It may be argued that the scarcity of sites reflects the Government’s assertion that the eight sites chosen for deployment by 2025 were the only ones available and that these same sites are now canvassed as the only ones available for development by 2035. Meanwhile, not the slightest effort has been made to identify other potentially suitable sites so the assertion becomes a self-fulfilling prophecy. This begs the question as to whether at some point the impacts and effects become so great as to be unacceptable. What are the limits placed by risk to environments, safety and security on the development of Sizewell C?
It might be concluded that any acceptable limits have already been transgressed and that the ‘need’ for new nuclear appears to take priority over any environmental considerations. But, there may come a point when the site itself is no longer viable, no longer able to support the buildings, wastes and other facilities safely or securely. Sizewell C lies on a fragile and vulnerable coast and, as time passes, this vulnerability increases to a point where coastal processes, storm surges and flooding pose a terminal risk to the power station and the surrounding environments and communities.
On the issue of long-term viability of the site the documents have little to say. The Summary Document provides some general information on how the coastal site issues will be tackled. The construction of sea defences is briefly touched on but there is no analysis of risks in the far future (i.e. next century) and what measures are intended to maintain protection in the long term. The document on Development Proposals (EDF Energy, 2019, Vol. 1), though providing more detail on the defensive measures is scarcely more forthcoming in terms of seeking to demonstrate that measures will be put in place to ensure the continuing viability of the site in the face of potential climatic and coastal hazards during the lifetime of the plant. As a general principle,
BANNG concludes that on the issue of coastal management in the face of climate change the consultation provides insufficient and inadequate proposals. The viability of the plant into the next century and possibly beyond is of fundamental and strategic importance. The proposals for a new nuclear power station and radioactive waste storage at the Sizewell C site should not proceed unless and until a robust and credible plan for the management of the site in conditions of climate change has been put forward.
We elaborate on this conclusion below.
Lack of substantive proposals
The Stage 3 Development Proposals (Vol. 1) lacks substance on the issue of climate change impacts which, we believe, produce an existential threat to the whole project. The key issues of coastal change, flood risk and waste management are briefly discussed in a national policy context. National policy (NPS), planning policy framework and local planning are set out in terms of principles and requirements. There is no attempt to set out in specific and detailed terms how it is intended to respond to coastal and flooding issues in the long term, what methods of management and mitigation are envisaged and what levels of risk over time are calculated. The statement merely resorts to a repetitive formulaic mantra. ‘National and local policy recognise that development of a new nuclear power station will be acceptable, notwithstanding inevitable local impacts which cannot be fully mitigated, given the urgent and important national need for new nuclear generation and the established lack of alternative sites’ (3.7.2). BANNG finds it astonishing that, on these vital issues, the consultation is utterly unprepared and unwilling to vouchsafe its intended approach, if it has one.
Inadequate forecasts of climate and coastal change
Stage 3 Consultation relies on the forecasts and assumptions that were the basis of the original NPS assessment, in particular the UKCP09 sea level predictions. The volume on Preliminary Environmental Information indicates that the updated UKCP18 will provide updated allowances for sea level rise and extreme surge and that ‘some of the assessments may need to be updated based on the new projections’ (EDF 2019b, 2.12.15, p. 103). This statement is both provisional and inadequate. An assessment based on an analysis of UKCP18 forecasts for sea level rise, flood risk, erosion and storm surges is urgently required. It is imperative that proposals for coastal management of Sizewell C should take full specific account of UKCP18 and make the analysis and assessments available for public and stakeholder scrutiny.
The most recent reports by the IPCC on the rise in temperatures from global warming are truly alarming. A recent report on global warming indicates that a rise of 1.50C is likely to be reached between 2030 and 2052 and that immediate international action must be taken to avoid a continuing rise to 20C by the end of the century. Unfortunately the prospects of slowing sea level rise appear to be minimal.
If present trends continue, a rise in global temperatures of 20C and more is inevitable and the consequences for sea level rise, coastal erosion, flooding and storm surge at Sizewell C could be catastrophic. The Development Proposals indicate that the challenges will be met by a new sea defence consisting of a large embankment with rock armour to provide extra strength and help protect it from erosion (EDF, 2019a, 7.4.78, p.185). But, it also states that there have been no significant changes to the design of sea defences since the Stage 2 consultation. In view of the most recent evidence and in the absence of the most up to date forecasts and analysis of climate change and sea level rise, we believe the proposals to be completely inadequate and urge that the proposals for sea defence and coastal management are reviewed and revised.
Into the unknown
A key problem is that the further forward the predictions, the greater the uncertainty given the variables such as glacier melt, storm tracks, ocean currents and so on. For instance, ‘we don’t yet know whether storm surges will become more severe, less severe or remain the same’ (Met. Office, 2018, p.2). It is fair to say that by the end of this century there will be increasing reliance on probabilistic assessments of increasing range and uncertainty. Coastal locations for infrastructures such as new nuclear power stations, especially ‘high risk’ sites such as Sizewell and Bradwell may be difficult, if not impossible, to defend against the most extreme climatic and coastal events. UKCP18 comments, ‘Based on exploratory results to 2300, sea levels continue to increase beyond 2100 even with large reductions in greenhouse gas emission’ (Ibid, p.1). Prediction of coastal processes and extreme weather events at coastal sites will shift from the realms of uncertainty to the unknown and, ultimately, to the unknowable, an area of speculation and fantasy.
At the turn of the century Sizewell C, if permitted, will be coming to the end of its operating phase. Beyond lies the long period of decommissioning and clean-up which could last for an indeterminate period. The assumption is that spent fuel will remain in store on the site until it has cooled and lost some of its radioactivity. Eventually it will be removed to be disposed of in the GDF, if available. The Development Proposals provide only a sketchy outline of proposals for managing wastes on the site in the far future.
The interim spent fuel store would be designed for a life of at least 100 years, which could be extended if necessary. The interim spent fuel store would be designed to be capable of operating independently of other parts of the power station in recognition that its lifetime would, under current assumptions, extend beyond the operational life and decommissioning of the other facilities on-site. (EDF, 2019a, 7.2.23, p.163 )
The confidence expressed in this statement cannot realistically be supported. The time line of decommissioning, clean up and site clearance is unknown and, in the absence of a GDF, could extend indefinitely. To all intents and purposes the concept of ‘interim’ becomes ‘interminable’. It is impossible to forecast the physical conditions at the site during the next century and the social conditions in terms of stability, institutional survival and governance are beyond prediction, a matter of imagination and speculation. A statement on proposals for managing the site during decommissioning and clean-up should be more provisional indicating that it cannot be assumed that the wastes can be safely managed and acknowledging that an unknowable risk will be passed on to future generations. In other words, it is not a practical issue but rather an ethical one of intergenerational equity. Therefore,
BANNG believes that physical and social conditions at the Sizewell site will become increasingly unpredictable to the point where they are unknowable. Proposals for defending the site against climate change and its effects will be, at best, short term. In the longer run, and especially during the indefinite period of decommissioning and clean-up, it is impossible to provide unequivocal technical assurance of safety and security in the management of radioactive wastes, including spent fuel. There is the possibility of calamitous risks being passed on to generations in the far future. This may be acceptable to the developer and government, in which case they should say so. It is not acceptable to BANNG and others who oppose this development. We believe it is technically improbable and ethically indefensible for the present generations who enjoy the (debatable) benefits to consign the costs to the future which has no voice and no interest in the present proposals. Therefore, both on pragmatic and ethical grounds, we consider the Sizewell C proposals should be abandoned.
Prof. Andrew Blowers, OBE
On behalf of Blackwater Against New Nuclear Group 29 March 2019
BANNG (2013) Sizewell C Proposed Nuclear Development Stage 1 Pre-Application Consultation. Initial Proposals and Options Consultation Documents, Response from BANNG, February (BANNG Paper No. 18)
BANNG (2017) Sizewell C Proposed Nuclear Development Stage 2 Pre-Application Consultation Document. Response from BANNG, February (BANNG Paper No. 32)
DECC (2011) Overarching National Policy Statement for Energy (EN-1), June
EDF Energy (2019a) Sizewell C, Stage 3 Pre-Application Consultation, Vol. 1 Development Proposals, SZC EDF Energy CGN, January
EDF (2019b) Sizewell C, Stage 3 Pre-Application Consultation, Vol. 2a Preliminary Environmental Information, SCZ EDF Energy CGN, January
Met Office (2018) UKCP18 Factsheet: Sea level rise and storm surge
NIC (National Infrastructure Commission), Incinerating Less, Recycling More