Memorandum submitted by C Reed
CASE AGAINST KIRKSANTON NUCLEAR POWER STATION
1. SUMMARY
1.1 Towards the end of the 1987 movie
Wall Street the character Gordon Gecko (representing the unacceptable
face of capitalism) is having a discussion with his prot
g
Bud Fox (who is having serious doubts about
Gecko's methods). At one point Gecko says to Fox: "you're
not naive enough to believe we're living in a democracy are you
?"
1.2 I think these sentiments resonate with
the way the Government is attempting to use the Planning Act 2008 to
ride roughshod over the environment, local communities and UK,
European and International law.
1.3 I am strongly opposed to the proposal
to build a nuclear power station at Kirksanton. My main concerns
are as follows:
(a) There would be a severe detrimental impact
on a wild and remarkably beautiful landscape.
(b) It would have a severe detrimental impact
on England's most beautiful and best-loved National Park, the
Lake District, which is protected by the 1995 Environment
Act.
(c) It would have a severe detrimental impact
on wildlife and plant habitat currently protected by UK, European
and International law.
(d) It would be a greenfield development in a
rural area and it would irrevocably change the character, quality
and tranquility of the landscape for the local community and for
visitors to the area.
(e) It would severely damage the tourist industry
in the immediate area and it would alter the perception of the
Lake District National Park as a tourist destination.
(f) The Government's planning process is severely
flawed and it is un-democratic and un-British.
(g) The Government's documents are unfairly biased
in the way that information is presented.
(h) There is sufficient evidence to suggest that
the Kirksanton site would not be deployable by 2025 which
is one of the Government's main requirements for development.
1.4 The proposed build of a Nuclear Power
Station at Kirksanton is causing considerable stress and upset
to a lot of people. I do not believe the Kirksanton site is viable
and it should be removed from the Government's list of potential
sites. This should be done as soon as possible to prevent further
unnecessary upset to people.
2. DESTRUCTION
OF LANDSCAPE
2.1 Select Committee Visit
2.1.1 I feel that the Select Committee need
to see first-hand the landscape that the Government are proposing
to destroy. It is important to visit on a nice clear day when
the surrounding Lake District mountain tops are visible. The best
place to get an appreciation of the landscape would be from Kirby
Moor with the fell road between Kirby and Ulverston being a convenient
viewpoint.
2.2 The Proposed Site
2.2.1 The site would occupy an area of 131 hectares
which is approximately 180 football fields. The reactor height
would be approximately 200 feet. Sea defences would consist
of a wall of between 13' and 20' high—this has been referred
to as akin to the Berlin Wall.
2.3 The Effect on the Lake District Landscape
2.3.1 The proposed Kirksanton site would
result in a severe detrimental visual impact on a large part of
the south west area of the Lake District National Park.
2.3.2 The views from Black Combe, White
Combe and Great Burney looking out from the Lake District National
Park over the Duddon Estuary are truly exceptional views. They
would be spoilt by a Nuclear Power Station at Kirksanton.
2.3.3 Possibly the best view in the whole
of England is the view from the fells above Kirby to the east
of the Duddon Estuary looking over the estuary to Kirksanton,
the Irish Sea, the Isle of Man, Black Combe and all the way round
to the highest mountains in England. It is a little known view
and would be spoilt by a Nuclear Power Station at Kirksanton.
2.4 The Effect on Silecroft Beach
2.4.1 Silecroft beach is an extremely beautiful
and unspoilt beach that borders the full western boundary of the
proposed site. The beach extends for approximately six miles from
Haverigg Point to beyond Gutterby (four miles of the beach lies
within the Lake District National Park).
2.4.2 A Nuclear Power Station would be visible
from the full six mile length of this unspoilt beach. The proposed
wave protection defence of between 13' and 20' in height would
also have a severe detrimental visual impact on the beach.
2.5 The Effect on the Duddon Estuary Landscape
2.5.1 The Duddon Estuary basin is unique
within England. There is nowhere else in England where mountains
as high as the Lake District's Black Combe are so close to the
sea. There is nowhere else in England where a magnificent estuary
and wetland is surrounded on all sides by such high mountains.
This landscape would be spoilt by a Nuclear Power Station at Kirksanton.
3. IMPACT ON
WILDLIFE AND
PLANT HABITAT
3.1 The Duddon Estuary adjacent to the proposed
Kirksanton site is a European Special Protection Area (SPA), and
International Ramsar site. It also contains a European Special
Area of Conservation (SAC) at Duddon Mosses as well as UK Sites
of Special Scientific Interest (SSSI).
3.2 Morecambe Bay adjacent to the proposed
Kirksanton site is a European Special Area of Conservation and
it also contains the Morecambe Bay Special Protection Area and
Ramsar site.
3.3 The Duddon Estuary contains some special
wildlife and plant habitat in a magnificent and unique landscape.
This is a fragile and precious environment, which is why the area
is protected by UK, European and International law. A Nuclear
Power Station at Kirksanton would not only affect the animals
and plants of the Duddon Estuary it would also spoil the enjoyment
for the people who enjoy this area for its wild beauty.
3.4 If we can't protect these areas what
message does it send to our children? How can we hope to persuade
other countries to protect their wild areas if we fail to protect
our own? What sort of world do we want to leave for our children
and future generations?
3.5 We are only temporary custodians of
the world we live in. Certainly our energy needs are important.
But if we are clever enough to be able to split the atom surely
we can find other ways to meet our energy needs without destroying
the environment.
4. IMPACT ON
LOCAL COMMUNITIES
4.1 Effect on a Quiet Rural Area
4.1.1 The proposed Kirksanton site would
be a greenfield development. This in itself goes against a stated
aim in the Government's own Appraisal of Sustainability objectives
which is "to avoid the use of greenfield land and encourage
the re-use of brownfield sites."
4.1.2 The area surrounding the proposed
Kirksanton site is a quiet, rural area. The villages of Kirksanton,
Silecroft and Haverigg could be described as "sleepy"
villages which is the very reason that most of the locals choose
to live in the area.
4.1.3 Building a Nuclear Power Station at
Kirksanton would have a devastating impact on the lives of the
people who live in the area. The noise and disruption of the build
phase would last for at least six years. When operational the
peace and tranquility of the area would be lost forever.
4.2 Opposition is Not NIMBY-ism
4.2.1 The proposed Kirksanton site is in
the backyard of the Lake District National Park which, as the
word "National" indicates, belongs to the people of
this country.
4.2.2 It is in the backyard of the Duddon
Estuary which is a unique and extremely beautiful landscape and
wildlife habitat. It has some magnificent views of the Lake District
National Park. These views rank amongst the best in the country.
4.2.3 It is in the backyard of Silecroft
Beach which is a truly exceptional beach stretching for six miles
from Haverigg Point to beyond Gutterby.
4.2.4 The Lake District National Park, Duddon
Estuary, and Silecroft Beach are free and can be enjoyed by all
of society—rich & poor, young & old, black &
white—the scenery doesn't discriminate.
4.3 The Need for Jobs
4.3.1 One of the arguments put forward by
supporters of the Kirksanton site is that it would bring jobs
to the area. I would agree that jobs are important. However, any
developments must be in keeping with the character of the area.
It is also worth noting that there are only approximately 130 people
currently unemployed in Millom. Given the will and investment
it should not be difficult to find alternative employment for
these people. For example, the development of the Marina at Barrow-in-Furness
will require many local people.
4.3.2 If a Nuclear Power Station is built
at Kirksanton there is a strong possibility that Haverigg Prison
would have to close. This is because the Prison is adjacent to
the proposed site and it would not be possible to evacuate the
inmates if there was an emergency. Closing the Prison would result
in the loss of 300+ local jobs.
4.4 Sustainable Future
4.4.1 The Planning Act 2008 requires
any significant new developments to be sustainable. The lifetime
of a nuclear power station is 60 years—then what do
the local people do for jobs?
4.4.2 The Copeland economy is already too
heavily dependent on the nuclear industry. It seems at times that
we are being bullied into accepting more nuclear with the threat
that "if you don't accept nuclear then West Cumbria will
die."
4.4.3 We need jobs and investment that are
sustainable and more in fitting with our environment.
5. IMPACT ON
TOURISM
5.1 Effect on Tourism in Millom
5.1.1 Over the last few years Millom (two
miles east of proposed site) has been working to develop the local
tourist industry. A quote from the Millom website reads: "Millom
today provides access to unspoilt golden sands with unrivalled
panoramic views of the nearby Lakeland hills and fells. It boasts
the facilities of a town and the opportunities of the unspoilt
countryside." This proud claim would no longer be true if
a Nuclear Power Station was built at Kirksanton.
5.1.2 Many local jobs depend on tourism.
There are caravan parks at Silecroft at the north end of the proposed
site and at Haverigg at the south end. There are a number of B&Bs
in the area. Local shops get a boost from tourism particularly
in the summer months.
5.1.3 The area provides a cheap holiday
for many young families and less "well-off" families
who can't afford expensive holidays abroad. Who wants to bring
their children to play on a beach next to a Nuclear Power Station
? Is it right that we deny access to a beautiful area to the less
"well-off" members of society ?
5.1.4 The Millom tourist industry would
be destroyed if a Nuclear Power Station was built at Kirksanton.
5.2 Effect on Tourism Further Afield
5.2.1 A Nuclear Power Station at Kirksanton
would damage the perception of Copeland, the Furness Peninsula
and the Lake District as a tourist destination both in this country
and abroad. It would also adversely affect other developments
such as the proposed Marina at Barrow-in-Furness.
5.2.2 The Western Lakes contain some beautiful
mountain and coastal scenery yet tourist numbers are much less
than the central lakes. This is probably due to the proximity
of Sellafield. Whilst I am not arguing the pros and cons of Sellafield
here I would suggest that building a Nuclear Power Station at
Kirksanton would further damage the perception of the area.
6. THE GOVERNMENT'S
PLANNING PROCESS
IS DEEPLY
FLAWED
6.1 Timescale is Too Short
6.1.1 The timescale for local communities
and other groups to consider a proposal such as a Power Station
at Kirksanton is far too short. The volume of Government documentation
to be read, assimilated and a response provided is overwhelming
in the time available.
6.1.2 The documents people opposed to the
Kirksanton site need to read include: EN-1 (93 pages);
EN-6 (94 pages); Appraisal of Sustainability Main Report
(136 pages); Appraisal of Sustainability for Kirksanton (64 pages);
Habitats Regulations Assessment for Kirksanton (47 pages).
To argue a case against the Government people also need familiarity
with such things as: the Planning Act 2008; the Environment Act
1995; alternatives to nuclear; concerns over radioactive waste
storage etc etc.
6.1.3 Yet the time between the Draft National
Policy Statements for Nuclear Power being published on 9 November
2009 and the deadline for comments being submitted to the
Select Committee is only nine weeks. It is only 15 weeks
from the date the draft policy statements were published to the
Government's deadline on 22 February 2010 for comments
on the Nuclear National Policy Statements.
6.2 Cost of Legal Challenge
6.2.1 The Government is riding roughshod
over UK, European, and International environmental law. However,
local communities opposed to the Government's planning proposals
do not possess the financial means to challenge the Government
in the courts.
6.3 Government Riding Roughshod over the Environment
Act
6.3.1 The Government state in their National
Policy Statement for the Kirksanton site that "Fully effective
mitigation of adverse visual effects during the construction and
operational phases is highly unlikely" [EN-6 para. 5.11.88]
6.3.2 The Environment Act 1995 states
that the purpose of National parks is to (a) to conserve and enhance
the natural beauty, wildlife and cultural heritage; (b) to promote
opportunities for the public understanding and enjoyment of the
special qualities of those areas by the public.
6.3.3 Plain common sense together with the
Government's own assessment of the Kirksanton site indicate that
effective mitigation is not possible (even assuming cooling towers
are not constructed). To build a nuclear power station at Kirksanton
would be a clear violation of the Environment Act.
6.3.4 The Environment Act was created for
the benefit of the public and to protect the environment from
developers. However, the biggest danger to the environment turns
out to be our own Government.
6.3.5 If an Act of Parliament is to have
any meaning then the proposed development at Kirksanton should
be rejected immediately. Failure to do so will only cause the
general public to lose more confidence in how the country is run.
6.4 Violation of UK, European and International
Law
6.4.1 The Habitats Directive and Birds Directive
are European laws that have been created to protect important
European wildlife and plant habitat. These European directives
have led to the Duddon Estuary being classified as a Special Protection
Area (SPA) and Special Area of Conservation (SAC). The Duddon
Estuary is also a Ramsar site which is an international law aimed
at protecting wetlands of international importance. The Duddon
Estuary also contains UK designated Sites of Special Scientific
Interest (SSSI).
6.4.2 Morecambe Bay is also a SAC, SPA and
Ramsar site.
6.4.3 If these laws are to have any meaning
then the Kirksanton site should be rejected.
6.5 Invoking IROPI is Illegitimate
6.5.1 The Government is quoting "Imperative
Reasons of Overriding Public Interest" in order to get its
own way. The legality of this is at best dubious and quite possibly
illegal. If allowed to go unchallenged it sets a dangerous precedent.
6.5.2 The Government uses as justification
for IROPI that there is a lack of alternatives [EN-6 para.
5.11.66]. However this is not true. Energy demand could be reduced
by energy saving measures (which the Government seem reluctant
to adopt) and there are other alternative means of energy supply.
6.5.3 It could be equally well argued that
it is in the national interest to protect our National Parks and
to conserve our wildlife and plant habitat.
6.5.4 It could also be strongly argued that
it is the Government's negligence that has created the concerns
over future energy supply. The Government has known for a long
time that existing nuclear power stations were reaching the end
of their life. If it was in the national interest to secure our
future energy supply why have they left it so late to act ?
6.6 Lack of National Debate on Nuclear Policy
6.6.1 There appears to have been very little
national debate on (a) whether or not the public want nuclear,
(b) the alternatives to nuclear, and (c) if we do want/need nuclear
then where as a nation are we willing to site new nuclear power
stations.
6.7 The National Policy Statements are Unfairly
Biased
6.7.1 There are many examples of misleading,
biased and erroneous statements in the Government's National Policy
Statements. The following example is taken from [EN-6 para.
5.11.83] and refers to the proposed Kirksanton site.
6.7.2 The Government state that "there
could be opportunity for the development to sit within a strong
new landscape framework with the creation of tree belts, lakes
and replacement public rights of way." This is biased in
that it creates the impression that the current landscape can
be significantly improved when in fact the reverse is true—the
current landscape will be spoilt forever. It could equally have
been written along the lines of "the development will result
in a severely detrimental and irrevocable change to the character,
quality and tranquility of the landscape."
6.7.3 There are many other examples of biased
and misleading statements in the National Policy Statements.
7. NOT DEPLOYABLE
BY 2025
7.1 There is little or no evidence presented
by RWE or the Government to suggest that the Kirksanton site could
be operational by the Government's own target date of 2025.
7.2 In the time frame both the energy utilities
and reactor suppliers are unable to simultaneously build nuclear
power stations in the UK, Europe and worldwide due to financial
risk exposure, availability of skilled workforce and qualified
sub-contractors, and bottlenecks with supply of certain materials
(eg Japan Steel Works are the sole maker of certain reactor parts).
7.3 The Kirksanton site is the least favoured
site of RWE which recently announced the Wylfa and Oldbury sites
as the sites they will develop. Braystones is another proposed
site. What are RWE's outline financial and project plans for developing
all of these sites by 2025?
January 2010
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