Memorandum submitted by Rother District
Council
THE DEPARTMENT FOR ENERGY & CLIMATE CHANGE
(DECC)
CONSULTATION RESPONSE TO DRAFT NPS—EN-6 ON
NUCLEAR ENERGY WITH PARTICULAR REFERENCE TO THE EXCLUSION OF DUNGENESS
INTRODUCTION
1. Rother District covers the eastern third
of East Sussex and borders Kent and Shepway District to the east.
Dungeness Power Station is located several miles into Kent. Rother
District falls well within the 25 miles drive to work area
of the power station.
2. This response has been prepared in consultation
with Cllr Brian Kentfield (Chairman of Planning Committee) and
Cllr Paul Osborne (Cabinet Lead on Plan Policy).
EXECUTIVE SUMMARY
3. Dungeness Power Station currently employs
approximately 1,000 people. It is a major local employer
and has significant benefits for the local economy. It is considered
that future socio-economic benefits, particularly in the Rother
District, have not been given sufficient weight in the decision
making process to exclude Dungeness.
COMMENTS
4. The draft Nuclear NPS (EN-6) follows
the Government's Strategic Siting Assessment (SSA) process and
lists 10 sites that the Government has judged to be potentially
suitable for the deployment of new nuclear power stations by the
end of 2025. These are all locations where existing nuclear power
stations are located. Dungeness had been nominated by EDF Energy
as a candidate site for a new station and this nomination has
been supported by Rother District Council. However, because the
site did not meet SSA discretionary criterion D6: "Internationally
designated sites of ecological importance", the Government
has stated that it is not satisfied that Dungeness is potentially
suitable for the deployment of a new nuclear power station by
the end of 2025. Consequently Dungeness is the only nominated
site not included in the draft Nuclear NPS.
5. In addition to their main function as
energy suppliers the power stations have been a longstanding driver
of growth, prosperity, skills and educational attainment and have
been highly supportive of social and environmental action on the
locality. With the current decommissioning of A Station and future
decommissioning of B Station (planned for 2018 but possibly
with production extended to 2023), the exclusion of a future power
station at Dungeness will have not only a critical impact on the
locality, by limiting the potential for socio-economic development
locally, but could also limit the country's capacity to produce
non-carbon based electricity.
6. Dungeness has been a major power source
for the region for the last 40 years which have been major
drivers for growth, prosperity and skills development sub-regionally.
The site currently employs approximately 1,000 staff in the
following breakdown:
A Station, currently decommissioning, employs:
361 full time posts (incl. nine graduates)
B Station currently employs:
553 full time British Energy employees in
Jan 09
211 full time contract staff
7. B Station's wage bill contribution to
the sub-region (most employees live within 25 miles of the
power station; which includes Rother District as well as Dover
and Hastings) is in excess of £30 million per annum
8. Rother District Council strongly object
to the exclusion of Dungeness as a future site for a nuclear power
station on the grounds of:
— The regional/local socio-economic benefits
of developing Dungeness should be given more weight
9. Rother District Council would also support
Shepway District Council's objection to the exclusion of Dungeness
as a future site for a nuclear power station. These reasons are
summarised below:
— It is premature to conclude that the
direct loss of vegetated shingle habitat from the Special Area
of Conservation cannot be adequately compensated and that Natural
England's objections cannot be addressed and there is no evidence
that a combination of measures including avoidance, mitigation
and compensation is not unviable.
— Notwithstanding any ecological concerns
there is an Imperative Reason of Overriding Public Interest (IROPI)
which justifies the inclusion of Dungeness.
— Dungeness can be brought forward more
quickly than the other identified sites.
— That the Dungeness site can make a meaningful
contribution to the UK's non-renewable capacity by 2025 and
that it has not been assumed that the other nominated sites will
be sufficient to meet this target or indeed that all those sites
will receive development consent from the IPC.
— That reaching conclusions prior to the
consultation is premature.
January 2010
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