Memorandum submitted by Shepway District
Council
1. EXECUTIVE
SUMMARY
1.1 The government's Draft National Policy
Statement for Nuclear Power Generation (EN-6) proposes to
reject on environmental grounds any new nuclear build at Dungeness,
located within the District of Shepway. Yet the Dungeness site
offers key strategic, logistical and economic advantages that
make it an ideal location for replacement new nuclear build in
the UK.
1.2 Replacement nuclear build at Dungeness can
both help to cut Britain's carbon emissions fastest and plug an
existing 8.7GWe (33%) shortfall in electricity generation capacity
in South East England. It would inject at least £2.4 billion
directly into the local economy of Shepway District.
1.3 Shepway District Council strongly supports
new nuclear build at Dungeness with an overall 82.5% majority
of elected Councillors in favour, while a report commissioned
from ORC in 2008 showed 62% of Shepway residents in favour.
Two existing nuclear power stations have successfully operated
at Dungeness for 45 years, beginning electricity generation
in 1965. These reactors have operated safely and without harm
to the environment.
1.4 Shepway currently hosts the retired
Dungeness-A nuclear power station which closed in 2006 and
the Dungeness-B nuclear power station which is scheduled to close
by 2018. Replacement nuclear build at Dungeness could supply much-needed
low carbon electricity generation for South East England and provide
essential continuity of local employment.
1.5 Based on past experience, there are
good reasons to believe that any environmental impacts at Dungeness
can be mitigated and managed successfully. The Infrastructure
Planning Commission (IPC) could take any site-specific decision
on the suitability of Dungeness for nuclear build, based on a
full project-level application for development consent.
1.6 For these reasons, Shepway District
Council believes that Dungeness should be reinstated as a nuclear
build site within the finalised Nuclear National Policy Statement
for approval by the Secretary of State. The following bodies have
all indicated their support for Dungeness as a location for a
new power station:
— Hastings Borough Council.
— Rother District Council.
— Local Town and Parish Councils.
— Channel Chamber of Commerce.
— Romney Resource Centre.
2. SHEPWAY DISTRICT
COUNCIL
2.1 Located in Kent, the Shepway District
covers 360 sq. km and has a population of 100,100 (2008).
Shepway is the third most socio-economically deprived local authority
in Kent. Classified as a "Significant Rural District",
its principal settlements are Folkestone, Hythe, New Romney, Lydd
and Hawkinge. Shepway's central and east Folkestone wards exhibit
particularly deep socio-economic problems. Dungeness is located
within Lydd ward which has an unemployment rate of 4.3% (2009),
nearly twice the 2% unemployment rate in the South East.
3. CASE FOR
RETAINING DUNGENESS
AS NUCLEAR
BUILD SITE
3.1 Shepway District Council commissioned
two independent expert reports from Jackson Consulting nuclear
consultants and Hammonds legal advisors.[273],[274]
The reports are available to the Select Committee and are attached
at Annex 1 and Annex 2 of this memorandum of evidence.
These technical and legal studies suggest that there are Imperative
Reasons of Overriding Public Interest (IROPI) that make a compelling
energy policy case for allowing new nuclear build to proceed at
Dungeness. The Council has also prepared a synopsis of its socio-economic
case (Annex 3).
3.2 Shepway communities have 45 years
of experience safely operating two nuclear power stations locally.
In addition to providing a safe, substantial and reliable supply
of low carbon energy for the region, the nuclear industry is a
major driver for prosperity and provides a wide range of employment
opportunities directly and through the local supply chain.
3.3 The existing Dungeness-B nuclear power
station injects £30 million to £50 million annually
into the local economy but is scheduled to close by 2018. Because
modern PWR nuclear power stations have design lives of 60 years,
the future loss of nuclear build opportunity will have major implications
for local employment and community sustainability. If nuclear
build does not proceed the economy will lose £2.4 billion
over the next 60 years, as well as local income lost from
the five year construction phase. A replacement PWR nuclear power
station built at Dungeness would probably employ 400 workers
directly, and indirectly support another 88 local jobs (shops,
hotels, goods and services) through local multiplier effects.
Although the construction phase of a new nuclear build programme
will produce a rapid temporary boost to the regional economy,
it is the sustainable local jobs from reactor operation that are
probably more important for the long term prosperity of Shepway
District.
3.4 Dungeness can help to cut Britain's
carbon emissions fastest. Dungeness has a nuclear grid connection
available from 2016, among the first sites in the country. The
capability of Dungeness to rapidly connect to the grid ahead of
nearly all other nuclear sites is extremely important. This is
because the government has prioritised early deployability in
the public interest, to maximise carbon emission savings (tonnes
CO2 avoided) during the period from 2017-25, the NPS deadline
date. There are no major technical obstacles preventing reactor
construction. The Spanish nuclear energy utility Iberdrola has
stated that a new nuclear power station could be fully operational
at Dungeness by as early as 2019.
3.5 New nuclear build at Dungeness could
help offset a major shortage in low carbon generation in South
East England. For historical reasons there is a growing negative
regional energy gap between electricity generation and electricity
demand in the South East. Today the South East generates 17.2GWe
of capacity but needs to import about another 8.7GWe (one third
of its electricity needs) from other regions of the UK. The problem
was an important issue originally recognised at the Sizewell-B
public inquiry which examined the case for Britain's newest nuclear
power station. The South East supply-demand gap will continue
to widen outstripping most other regions of the UK. For example
by the 2025 NPS deadline, South East England will need three
times as many new power stations as Southern Scotland.
The problem will be exacerbated by the expected
closure of the Kingsnorth coal-fired power station in 2015 and
the Dungeness AGR nuclear power station in 2018. Replacement nuclear
capacity could be embedded directly within the South East at Dungeness.
Source: Jackson Consulting
(2009)
3.6 Dungeness is of strategic national importance
as a viable nuclear generating site close to areas of high energy
demand in the South East. Disregarding advice from the Institute
of Engineering and Technology (formerly known as the Institution
of Electrical Engineers founded in 1871), the government ignored
grid connection as only a local siting issue. There is empirical
market-based evidence to show that the government's approach was
probably wrong, at least in the commercial judgment of utilities
and their investors. Eight nuclear development sites were sold
in 2009 for a total of £1 billion. Analysis of these
transactions shows a strong correlation between higher price and
early grid connection, and also a strong correlation between higher
price and preferred regional location in the South East and South
West of England. Some 70% of the £1 billion spent on nuclear
land was on sites in the South East and South West. The highest
prices were paid for sites in the South East (39% of the total
transaction value). Furthermore the market price paid for nuclear
development land declines very rapidly, losing about £44
million for each year of delay connecting to the grid after 2016.
These pricing signals strongly suggest that Dungeness would be
a good location for new nuclear build, reflecting the viability
and overall strategic desirability of early "first wave"
nuclear build sites located in the South of England.
Source: Jackson Consulting
(2009)
3.7 Nuclear development near environmentally
sensitive habitats at Dungeness raises understandable concerns.
Yet the government's preliminary environmental reasoning to reject
Dungeness appears excessively restrictive and a more pragmatic
environmental approach is justified. There are good reasons to
believe that the long term environmental impacts may not be severe,
mitigation strategies through Biodiversity Action Plans (BAPs)
will be effective, and nuclear construction may even be helpful
to continue to protect the internationally designated ecology
sites from coastal erosion. At worst, the 91 hectare nuclear
development site would encroach on just 0.3% of the internationally
protected 27,000 hectare Natura 2000 Romney Marsh wetland
Special Area of Conservation (SAC) and Sites of Special Scientific
Interest (SSSI). Only 30% of the 91 hectare nuclear site
land would be developed, the remaining 70% (65 hectares)
would become a security buffer zone remaining relatively unchanged
and protected under Biodiversity Action Plan arrangements. If
a nuclear power station is not constructed then about 240 metres
depth of shingle habitat at Dungeness will likely be destroyed
by natural coastal erosion over the next 160 years (the same
time period as the proposed nuclear reactor lifecycle). There
are also likely to be some synergies and opportunities to reuse
or redevelop existing nuclear infrastructure at the adjacent Dungeness-A
and Dungeness-B nuclear stations. For example shared modern spent
fuel storage, intermediate level waste storage, and waste treatment
and encapsulation facilities might substantially reduce the overall
land area needed.
Future proposals for accelerated decommissioning
of the government's shut-down Dungeness-A nuclear power station
might also free-up some land for brownfield nuclear redevelopment.
3.8 It is possible that Small Modular Reactors
(SMRs) could be deployed at Dungeness, further reducing the land
area needed for new nuclear build. Such modular nuclear power
systems are particularly suitable for deployment within Britain's
future decentralised grid network architecture, as envisaged under
recent Conservative energy policy proposals. Dungeness could remain
as a development option for smaller utilities who might choose
to invest in scaleable clusters of SMR reactor units, which can
be built relatively quickly at lower cost and are easier to finance.
3.9 Shepway District Council has approached
the government's NPS consultation process constructively and is
fully supportive of nuclear build proposals at all of the UK sites
nominated by energy utilities. Nevertheless legal advice from
Hammonds suggests that there are some apparent flaws in the government's
evaluation of Dungeness, when compared with other nuclear build
sites that have provisionally been approved in the Draft NPS.
3.10 In practical terms, nuclear development
at Dungeness is not impossible, and it is too soon to rule-out
Dungeness as a site on the basis of the outline information presently
to hand. The advantages offered by keeping options open at Dungeness
must not be lost, particularly as there is no detailed application
for development consent which the IPC could fully evaluate. Dungeness
should be included within the finalised NPS. The site can be ruled-out
at a later stage by the IPC if these reasons are not sufficient
or if the environmental impacts cannot be overcome.
3.11 The government has set out a clear
imperative for undelayed low-carbon nuclear development, which
is a vital part of the argument in favour of Imperative Reasons
of Overriding Public Interest (IROPI). The IROPI test has been
considered at each of the 11 proposed nuclear build sites, which
all have at least some potential to cause detrimental affects
on designated European Sites that are protected under the EU Habitats
Directive. In the face of that national low-carbon energy policy
imperative, DECC's proposed rejection of Dungeness is irrational,
especially in view of its significant potential for early deployment
avoiding CO2 emissions.
3.12 Furthermore DECC's evaluation of Dungeness
includes detriments and omits matters which are important to the
case in favour of Dungeness, both in comparison with other sites,
and on the basis of Dungeness's intrinsic value as a unique development
asset in South East England. DECC's public consultation process
includes organised meetings and local events near the 10 sites
which DECC has proposed to approve.
The failure of DECC to consult locally at Dungeness
is procedurally unfair and presupposes the outcome of the NPS
national consultation process. Shepway wish to participate fully
in the local consultation process but are unable to do so unless
DECC remedies the defective local consultation.
3.13 The government has rightly taken into
account the views of local communities as an important factor
for siting an underground repository for nuclear reactor waste
disposal. Yet in contrast the government has ignored local community
support as a factor for nuclear reactor build. This confusing
approach to public consultation for nuclear facility build is
both illogical and irrational. The lack of priority given to local
community support at Dungeness for development is completely at
odds with the Strategic Environmental Assessment (SEA) process
for radioactive waste repository new build, which is to be led
by a local community volunteerism approach.[275]
In matters of important national infrastructure the approach set
out in the DECC MRWS[276]
process of seeking to engage with and give weight to the views
of local communities is correct. But several important reports
setting out local views at Dungeness have been excluded from the
NPS consultation without full reason being given by DECC. There
is no justification for the exclusion of local views supporting
nuclear reactor build, in the face of the MRWS national radwaste
consultation process. The failure to give sufficient weight to
socio-economic factors including local public support may render
the NPS consultation defective.
4. CONCLUSIONS
4.1 Shepway District Council supports the
inclusion of Dungeness as a site for the development of a new
nuclear power station by 2025, and having considered the draft
overarching National Policy Statements for Energy (EN-1) and Nuclear
Power Generation (EN-6) contends that:
(a) It is premature to conclude that objections
by Natural England regarding 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.
In addition there is no evidence that a combination of intervention
measures including avoidance, mitigation and compensation is not
unviable.
(b) Notwithstanding any ecological concerns it
can be argued there is an Imperative Reason of Overriding Public
Interest (IROPI) which justifies the inclusion of Dungeness.
(c) Dungeness can be brought forward more quickly
than other identified sites, it can rapidly connect to the national
grid and it has the potential to offset generation shortage in
South East England.
(d) That the Dungeness site can make a meaningful
contribution to the UK's non-renewable capacity by 2025 and
that it should not be 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.
(e) That reaching conclusions prior to the consultation
is premature.
(f) That the regional/local socio-economic benefits
of developing a third station at Dungeness should be given more
weight.
January 2010
273 Ian Jackson. Arguments and Evidence for Retaining
Dungeness within the Government's Nuclear National Policy Statement
in the National Interest. Issue 2. Jackson Consulting (UK) Limited.
24 December 2009. Back
274
Claire Harvey. Legal Arguments and Evidence for Retaining Dungeness
within the Government's Nuclear National Policy Statement in the
National Interest. Hammonds LLP. 30 December 2009. Back
275
Defra. Managing Radioactive Waste Safely: A Framework for Implementing
Geological Disposal. White Paper Command 7386. June 2008. Back
276
Managing Radioactive Waste Safely (MRWS). Back
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