Memorandum submitted by Cumbrians Opposed
to a Radioactive Environment
CORE [Cumbrians Opposed to a Radioactive Environment]
is grateful for the opportunity to comment on the NPS and we ask
that our written submission is given due consideration by the
Committee.
As a local environmental group, CORE has campaigned
since 1980 on nuclear issuesspecifically focusing
on the commercial operations undertaken at Sellafield. These include
the reprocessing of spent reactor fuel, environmental discharges
and contamination, radioactive waste management, nuclear transports
and local health detriment. The comments we submit to the Committee
are therefore largely confined to that element of the combined
National Policy Statements that relates to nuclear power.
1. We make the following points on the process
to date:
The sheer volume and complexity of the
consultation documents defies a properly reasoned response being
made by the due date
We do not believe that we, and communities
nationwide, have been given the fullest opportunity to participate
at a sufficiently early stage of the development of the Policy
Statements.
We are concerned that the Infrastructure
Planning Commission (IPC) will be left to resolve issues of major
import without public challenge or input, and that the unexplored
and contentious question of on-site storage of high burn-up reactor
fuel at new power station sites is not within the IPC remit.
We contend that it is premature for the
Government to preliminarily conclude that effective arrangements
will exist to manage and dispose of future wastes produced by
reactors from the new-build programme. Given the unresolved issues
surrounding the MRWS programme on existing wastes, it is dangerously
irresponsible for Government to postulate that, on nuclear waste
disposal, the IPC "need not consider this question".
The MRWS programme is specifically designed
and trailed to encourage public input throughout the programmethe
value of such participation being wholly undermined by premature
IPC approval for developments.
2. On the plans for the development/expansion
of nuclear power in the UK, we comment:
We perceive little merit in making a
worthwhile contribution to the consultation on new build on the
grounds that Government decisions have already been made.
That as a means of mitigating carbon
emissions, nuclear power will deliver too little too late to be
of benefit;
It will bring additional environmental
detriment locally and nationally;
Its inclusion in UK's energy mix will
act as an unjustified distraction to national effort on the vital
development of renewable energies;
That there can be no confidence whatsoever
that the industry's historic failure to deliver projects on time
and to budget will not be repeated;
That the likelihood of an increase in
health detriment (as evidenced by recent US and German studies)
has been inadequately addressed by Government and that
The late publication (after the NPS and
Justification consultation deadlines) of COMARE's report on the
German KiKK study on childhood leukaemia around nuclear power
stations precludes public scrutiny and response.
On new-build plans for West Cumbria, we make
the following site-specific points:
We note that none of the three nominated
sites in West Cumbria "fits the bill" in terms of the
Government's initial guidelines on locations for new-buildnamely
that a) sites should preferably be licensed nuclear sites, b)
that sites should be located close to the demand for electricity
and c) that sites should possess the necessary transmission infrastructure.
It is well documented that all aspects
of West Cumbria have been dominated by the nuclear industry (Sellafield)
for the last half century. This dependence upon one industry has
lead directly to a stagnation of non-nuclear enterprise in the
area.
New-build in West Cumbria will not only
perpetuate this domination for a further 60 years or more
but will also ensure the area's continuing dependence on the vagaries
of one historically unreliable industry, at the same time deterring
non-nuclear investment in the region.
The damaging prospect of one or more
new nuclear power stations in the regional is already recognised
by Governmentas described in its Draft National Policy
Statement for Nuclear Power Generation (EN-6) which acknowledges
that the development of individual West Cumbrian sites could have
negative effects on the local infrastructure and that "these
negative effects may become more significant if more than one
nuclear power station is developed in the region".
Cumbria County Council's Emergency Planners
have already warned, in terms of emergency planning capabilities,
of the inadequacy of local infrastructure systems to deal with
events outside those currently scoped for the Sellafield site
itself.
Written evidence presented to the 1996 NIREX
Rock Characterisation Facility (RCF) Public Inquiry by local authority
planners confirmed that the long-established nuclear presence
in West Cumbriaand its indelible environmental legacy of
commercial operations (nuclear wastes, radioactive discharges
and health detriment) was shown to have acted not only
as a deterrent to new non-nuclear enterprise and investment being
attracted to West Cumbria but also as a deterrent to holidaymakers.and
the expansion of the tourist industry in West Cumbria.
It is well documented that, central to
the aspirations of Britain's Energy Coast West Cumbria (BECWC),
nuclear expansion is to be the mainstay of the regeneration plans.
Such underpinning will be detrimental to attracting the non-nuclear
investment and employment that has been sought with urgency by
West Cumbria's local authorities and others over the last decade.
As nominator of West Cumbria's Kirksanton
site, Germany's RWE has confirmed that development of that site
will result in the removal of the long established and viable
Haverigg windfarmundermining both Government assurance
that nuclear development will not damage renewable programmes
and the claim by Britain's Energy Coast Plan that it will cater
equally for renewables as little more than lip service.
January 2010
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