Memorandum submitted by Varrie Blowers[5]
A1. It is most unfortunate that by responding
to the various stages of a Government-set consultation process
on the proposal to build a new nuclear complex at Bradwell, participants
appear to legitimise that process. The only hope for any redress
for this situation is for respondents to describe the actual experience
on the ground of each stage of the consultation process. This
will establish the inadequacy of the process on which the National
Policy Statements are based.
A2. The consultation process has been flawed
at every stage. Most importantly, there has been no emphasis on
the aspect of the proposal that represents a major departure from
past practice: the storage of highly radioactive spent fuel and
intermediate wastes on site at Bradwell for around 160 years.
The proposal to build a new station and the proposal to store
spent fuel have been conflated and I am afraid this looks like
an attempt to deceive the public. As it is intended that spent
fuel would be stored over the long-term at Bradwell, the public
needs to be properly informed and consulted on this proposal in
a process separate to that for a new nuclear power station. It
is quite disgraceful that when the issue of spent fuel storage
was discussed at meetings, it was well-informed members of the
public who raised it, not the representatives of British Energy
or the Department for Energy and Climate Change.
A3. There has further been no emphasis on
the other ways in which a new nuclear power station would differ
to its predecessor:
— the much higher burn-up of fuel in a
new power station resulting in a period of 100 years in which
to cool down; and as a result of this; and
— the requirement for more than three times
the amount of cooling water to be taken from the shallow and vulnerable
Blackwater estuary, which would have a very damaging impact on
the oyster and fishing industries, the environment and ecology
of the estuary and its marine life.
A4. The consultation process as perceived
at the grassroots-level has occurred in six stages to date: British
Energy Roadshow; Draft Strategic Siting Assessment; Justification;
`Have Your Say'; DECC exhibition (West Mersea, Maldon, Bradwell)
and public meetings (West Mersea and Maldon); Draft National Policy
Statements.
A5. I would contend that at each stage proper
consultation has not occurred and that affected local communities—the
focus of the consultations—have not been properly engaged.
This has been an exercise in "consultation done" box-ticking
for Government.
1. BRITISH ENERGY
(BE) ROADSHOW
1.1 British Energy was surprised at the
small numbers attending some of these events during November,
2008 and there was a tendency for it to conclude that the majority
of people were quite happy with the proposals. It should have
been obvious to BE that it is very difficult for many people to
attend meetings held on weekday afternoons.
1.2 The requirement to pre-register to attend
these events seems also have deterred some people, who were concerned
about how their details would be used and that they would be photographed
attending.
1.3 Towns in the area with large populations—Colchester,
Chelmsford, Southend and Clacton—were not included as venues
although they have a legitimate interest in what happens at Bradwell.
Nor was Brightlingsea directly downwind of Bradwell.
1.4 At the meetings at Tollesbury and West
Mersea, the audiences expressed a great deal both of hostility
to the idea of a new power station and of scepticism at British
Energy's claim that the chances of an accident were "vanishingly
small". As members of an island community two miles over
the Blackwater estuary from Bradwell, the audience at the West
Mersea meeting was particularly hostile and felt that its concerns
fell on deaf ears. These concerns included: the storage of highly
radioactive spent fuel well into the next century on such a low-lying
site liable to flooding and storm surges in the next 50 years;
the virtual impossibility of evacuating Mersea Island in the event
of an accident; the deleterious effects on the Colchester Native
Oyster industry and the marine ecology of the estuary.
1.5 It was apparent from the meetings that
those attending did not trust the nuclear industry. Local communities
had been promised that the old nuclear power station would be
decommissioned and the site returned to greenfield within 25 years.
As a result of a lack of funding, that time has been revised to
100 years.
1.6 At the Tollesbury meeting, it was pointed
out that little or no mention was being made of the proposed storage
of highly radioactive nuclear waste at Bradwell. The BE representative
countered by saying that "spent fuel" storage was referred
to in BE's literature. The point was made by a member of the audience
that most lay members of the public did not know what spent fuel
was and that the industry was cynically taking advantage of this
ignorance instead of raising public awareness and consulting on
this vital issue separately.
2. DRAFT STRATEGIC
SITING ASSESSMENT
(SSA) CRITERIA
2.1 The Blackwater Against New Nuclear Group
(BANNG) made a substantial and well-informed response to the SSA
consultation. The response drew attention to many problems with
the criteria, particularly demographics, flooding and coastal
processes. Unfortunately, it seems that scant attention has been
paid to some of the criticisms and others have simply been ignored.
Responses from the Government have been general rather than specific
and there has been virtually no change made to the criteria.
3. JUSTIFICATION
3.1 The Blackwater Against New Nuclear Group
(BANNG) made a substantial and well-informed response to the Justification
consultation and, along with several other groups, called for
a Public Inquiry into whether new nuclear practices in the form
of new power stations could be justified. Unfortunately, it seems
that scant attention has been paid to the responses by the Government
and the requests for a Public Inquiry have simply been ignored.
4. "HAVE YOUR
SAY"
4.1 The "Have Your Say" consultation
on the nominated sites appears to have been an "extra"
stage added in to the Government's consultation process. The consultation
period was short, one month.
4.2 The Blackwater Against New Nuclear Group
(BANNG) made a substantial and well-informed response to the "Have
Your Say" consultation, taking the opportunity to remind
government of the group's responses to the SSA and Justification
consultations. Again, it seems that scant attention was paid to
this.
4.3 Individual members of the public found
it extremely difficult to take part in the "Have Your Say"
consultation. The Dept. of Energy and Climate Change provided
a template of questions to be answered on different aspects of
the criteria and which required some very detailed knowledge.
This restricted and attempted to channel public comment. It may
be that this deterred responses. It is to the credit of those
members of the public who took part that they did so regardless
of the many obstacles that needed to be overcome.
5. DEPARTMENT OF
ENERGY AND
CLIMATE CHANGE
(DECC)—EXHIBITION AND
PUBLIC MEETINGS
5.1 The DECC Exhibition was obviously regarded
by the Government as an opportunity for local communities to see
the proposals for the Bradwell site; the public meetings as an
opportunity for local communities to make known their feelings
on the proposalsto DECC. "Your views make a difference"
and "The Government wants to hear your views" declared
each of the 11,000 leaflets that DECC hoped had been distributed
(in some places door-to-door) around the Blackwater estuary. DECC
acknowledges that this did not happen as planned. The resulting
lack of advertisement of the events was reflected in the numbers
attending the exhibition and public meetings. Again, as with the
British Energy Roadshow, the times of the events that took place
on Thursday 10 and Friday 11 December at West Mersea and Maldon
respectively were not convenient for working people. Again, the
requirement to pre-register was offputting.
5.2 In an article in the Mersea Island
Courier (4 December 2009), the Blackwater Against New Nuclear
Group (BANNG) informed readers of the Exhibition and public meetings.
The Editor of the Courier took it upon himself to find a DECC
leaflet and publish it. While collecting signatures for the BANNG
Petition outside the Exhibition in Maldon on 11 December, I discovered
that almost everyone to whom I spoke knew nothing about this or
the public meeting to be held on 12 December in Maldon. In the
interests of openness and democracy, I directed members of the
public to the Exhibition, otherwise there would have been very
few attending. I also informed them of the public meeting. Those
petitioning for BANNG in the afternoon did likewise.
5.3 Neither the Exhibitions at West Mersea
and Maldon nor the public meetings in both places attracted large
numbers of people and the absence of adequate advertisement of
the meetings certainly contributed to this. There were around
60 members of the public at the meeting in West Mersea and around
30 at Maldon.
Public Meeting at West Mersea on 10 December,
2009
5.4 Despite the inconvenient timing of the
public meeting, in the middle of a working day, there was a turnout
of around 60 Mersea Islanders keen to press home their objections
to the proposed new power station. In a series of hard-hitting
and well-informed contributions from the floor, the inadequacies
of the Government's draft National Policy Statement on Nuclear
Energy in relation to Bradwell were vigorously exposed. Among
the points made by those attending, were that a massive nuclear
power station, and possibly up to three, would create a major
industrial complex that would totally transform the landscape,
ecology, economy and amenity of the Blackwater estuary. More than
that, such a project imposed high risks and potential dangers
threatening the security and safety of many thousands of people
within a short distance of the power station. In the event of
a major incident, it was doubted that emergency planning procedures
would be able to cope with evacuation of the population.
5.5 The shallow Blackwater estuary could
hardly cope with providing cooling water for one of these giants,
let alone two or three, for which cooling towers would be necessary.
The threat to fishing, oysters, the tourist trade and, indeed,
the well-being of the Blackwater community would persist over
many generations.
5.6 Members of the audience took exception
to the lack of emphasis on the proposed storage of highly radioactive
waste on this most vulnerable site and the idea of it being safely
managed 160 years hence was frankly incredible.
5.7 The format of the meeting, whereby members
of the public asked questions from the floor which were answered
by Department of Energy and Climate Change officials from the
platform, allowing little questioning of responses, was not regarded
as a satisfactory way of engaging the public.
Public Meeting at Maldon on 12 December, 2009
5.8 Similar questions were raised at the
Maldon meeting. It was pointed out by several attending that without
the information provided by members of BANNG outside the exhibtion
at Maldon on 11 December, they would not have known about the
public meeting.
(The Committee would find it informative to
read the transcripts of both public meetings.)
Choice of venues for Exhibition and public meetings
5.9 It is doubtful that West Mersea would
have been included as a venue for the Exhibition had it not been
for the activities of the Blackwater Against New Nuclear Group
(BANNG). The Chair of BANNG, Professor Andrew Blowers, OBE, was
instrumental in DECC agreeing to hold a public meeting there.
Originally, only Maldon and Bradwell were scheduled as venues
for the Exhibition with one public meeting at Maldon.
5.10 The Exhibition and public meetings
were not taken to places where large populations have a legitimate
interest in the building of a major nuclear complex nearby. Colchester
is more or less on the doorstep and Chelmsford is within a 20
mile radius. There are other significant populations, too, such
as Southend, Clacton and Brightlingsea. These towns were not included
by DECC in its leaflet distribution.
6. DRAFT NATIONAL
POLICY STATEMENTS
6.1 The Blackwater Against New Nuclear Group
(BANNG) will be submitting a substantial and, once again, well-informed
response to the consultation on the Draft NPSs.
6.2 Many individuals are also proposing
to respond to the consultation.
6.3 From a cursory look at the NPS EN-6,
it is clear that the Government is framing the consultation by
asserting that nuclear power is necessary and that ten existing
sites are the best locations for new nuclear power stations.
Consultation Period (9 November 2009 to 22 February
2010)
6.4 Bearing in mind that the Government
assures the public that "Your views make a difference"
and "The Government wants to hear your views", the consultation
period, with the Christmas season intervening, is extremely short.
6.5 The shortness of the consultation period
is exacerbated by the vast amount of material to be trawled through—by
ordinary members of the public. It is to be hoped that the people
whose views matter to the Government so much will not be deterred.
Evidence to the House of Commons Committee on
Energy and Climate Change on the Draft National Policy Statements
6.6 It is not helpful for those wishing
to submit evidence to the Committee that this is required by 15
January—over one month before the Government's deadline.
7. BLACKWATER AGAINST
NEW NUCLEAR
GROUP (BANNG): RAISING
PUBLIC AWARENESS
AND CONSULTATION
VIA PETITION
BANNG's Main Aims
7.1 BANNG is a citizens-based organization,
founded in West Mersea. It has five main aims:
1. to raise public awareness among the Blackwater
communities of the potential consequences for health, environment
and safety of proposals for new nuclear development;
2. to identify key issues of concern and to gather
credible and responsible research and information to pursue the
case against nuclear development;
3. to challenge any proposals for future nuclear
power at the Bradwell site by presenting robust evidence and arguments
to local and national decision makers, regulatory bodies, the
nuclear industry, non government organisations, the media and
the general public;
4. to support the early and successful decommissioning
and clean up of the existing Bradwell nuclear site as an integral
element of the long-term protection and conservation of the Blackwater
estuary; and
5. to call for an open, transparent and deliberative
decision making process in which local communities are afforded
full access to all information and involvement in key decisions
affecting them.
7.2 The Chair of BANNG, Professor Andrew
Blowers, OBE, is an expert on the social and ethical issues of
radioactive waste management. He is a former member of two Government
committees: Radioactive Waste Management Committee (RWMAC) and
the first Committee on Radioactive Waste Management (CoRWM). He
was also the Government appointed non-executive Director of Nirex.
7.3 BANNG relies on volunteer supporters
to help it to carry out its aims. It is not a government department
with a large staff, such as DECC. It does not have the huge financial
resources of the nuclear industry, nor its privileged access to
the "ear" of government.
7.4 And yet BANNG, since its inception in
April, 2008, has done more than government, local authorities
(excepting Colchester Borough Council and now West Mersea Town
Council), Members of Parliament and the nuclear industry to make
people aware of what is proposed for the Bradwell site—including
the storage of highly radioactive spent fuel until the end of
the 22nd century—and to respond to each stage of the Government's
consultation process. It is thanks to the hard work of BANNG that
there were so many well-informed contributions made at the DECC
public meetings in West Mersea and Maldon (see item 4 above).
BANNG Petition
7.5 BANNG is currently collecting signatures
for its Petition. The Petition statement is as follows:
To the Secretary of State for Energy and Climate
Change,
We, the undersigned, wish to express our strong
opposition to the construction of a new nuclear power station
at Bradwell and the storage of highly radioactive waste on site.
We, therefore, demand that the Government reject
this proposal.
Further, we demand that the site of the former
Bradwell power station be returned to greenfield status within
25 years of closure as proposed by the Nuclear Decommissioning
Authority.
7.6 BANNG supporters have been collecting
signatures door-to-door on Mersea Island, at Bradwell and Southminster.
Collections have also taken place on the beaches at West Mersea
and Bradwell, in Maldon, Colchester and Tollesbury. Supporters
have also attended local fetes to collect signatures. It is intended
to continue to collect signatures at other communities around
the Blackwater estuary in the coming months.
7.7 While claims are made by the Government
that local communities welcome the prospect of a new nuclear power
station at Bradwell, the experience of signature collectors is
somewhat different. The BANNG Petition represents the only opportunity
for people living around the Blackwater and other stakeholders,
such as the many caravan owners, beach hut owners and holidaymakers,
to be asked face-to-face for their views. BANNG petitioners have
found that the overwhelming majority of the thousands of people
they have approached is against a new power station at Bradwell.
7.8 The BANNG petitioners have been astounded
at the number of people around the Blackwater who were unaware
of the proposals to build a new nuclear power station at Bradwell
until asked if they would sign the Petition. This was particularly
marked in Maldon, where the District Council will have a significant
say on any Planning Application.
7.9 The BANNG petitioners have been further
astounded at the number of people—from those at the highest
level of national and local representation to workers in the nuclear
industry—who were not aware of the proposal to store highly
radioactive spent fuel at the Bradwell site until the end of the
22nd century.
7.10 It has been left to a small group of
unpaid volunteers to explain the Government's proposals to local
communities. That must speak volumes for the adequacy and efficacy
of the Government's consultation process on Bradwell as a suitable
site.
8. CONCLUSION
8.1 The Government might be said to be conducting
a "hit and miss" consultation on its proposals for a
major nuclear complex at Bradwell. It has failed (as did British
Energy) to include large towns with a legitimate interest in what
happens at Bradwell as venues for the DECC Exhibition and public
meetings. It also failed to advertise the events adequately. Both
these failures have denied thousands of people the opportunity
to be part of a public debate on an issue that will have huge
implications for their lives.
8.2 With respect to the lack of emphasis
on the proposal to store highly radioactive spent fuel on the
Bradwell site until almost the end of the 22nd century, it seems
that British Energy and the DECC have deemed it sufficient to
make mention of this here and there in their literature and at
the DECC Exhibition, as though such storage is in the normal run
of things. Since both the size of a new power station and the
long-term storage of highly radioactive waste on site are both
significant departures from the situation that pertained in relation
to Bradwell A, consultation can only be carried out on a properly
informed public. "Sleight of hand" has no place in such
serious proceedings. Once again the public has been denied the
opportunity to understand or to have a debate on this vital issue.
8.3 It is difficult to imagine how members
of the public—whose views the Government declares it wants
to hear—will be able to cope with the consultation on the
National Policy Statements, particularly within the time constraints
imposed.
8.4 From grassroots-level, it appears that
the Government has failed to engage properly with the public on
its proposals not only to build a new nuclear power station but
also a highly radioactive spent fuel store at Bradwell and the
consultation process has been merely a box ticking exercise.
9. POSTSCRIPT—A
LEVEL PLAYING
FIELD
Funding for Colchester Borough Council Investigations
9.1 Colchester Borough Council has been
made aware of and takes very seriously the concerns of many of
its residents about the proposals for Bradwell. The Council would
like to be able to carry out investigations into some of the issues
raised but lacks the funding to do so.
9.2 In order to allow the Council to carry
out its duties to its residents in relation to issues for which
a Council would not normally make budgetary provision, perhaps
the Government or the nuclear industry would provide the funding
for independent research to be undertaken. This would demonstrate
that both are indeed keen on proper consultation. A Borough Councillor
suggested this at the DECC public meeting at West Mersea on 10
December but received no reply.
Funding for Local Groups
9.3 It would help if some funding were provided
for local groups to carry out their work more effectively, in
order to engender a more balanced and genuinely participative
debate.
January 2010
5 Although this is a Personal Submission, I am the
Secretary of the Blackwater Against New Nuclear Group (BANNG)
and have also contributed to the group's submission to the Committee. Back
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