Memorandum submitted by Mr Nigel Gilligan
NUCLEAR NATIONAL POLICY STATEMENT EN-6
IMPERATIVE REASONS OF OVERRIDING PUBLIC INTEREST
(IROPI)
WHY THE JUSTIFICATION FOR IROPI IN ANNEXE
A IS NOT VALID
EXECUTIVE SUMMARY
The arguments presented as a reason for the
government to apply IROPI are explained in Annexe A of the Draft
National Policy Statement for Nuclear Power Generation (EN-6).
It has to be questioned as to whether the arguments
for justification are actually valid. The discussion below examines
each general point made within Annexe A of EN-6, and concludes
that the case is made that IROPI is not justified, or valid.
DISCUSSION
1. The need to move towards a low carbon economy
is valid. But how to move in that direction is a matter of policy,
based on political decisions. The technology of possible solutions,
and the science behind climate change, do not justify the arguments
presented in Annexe A.
The arguments extend over 8 pages of A4,
but they can be summarised by the following three points:
— the imperative need for action; and
— "the protection of human health,
and public safety, and to beneficial consequences of primary importance
to the environment."
2. No alternatives.
1. The Liberal Democrat Party believes there
is an alternative.
2. The Green Party believes there is an
alternative.
3. The Labour Party before 1997, and debatably
up to 2007, thought there was an alternative.
4. The Zero Carbon Britain1 proposals
by CAT are a viable alternative. These are well researched, thoroughly
argued, and widely presented by CAT staff, both in the UK and
abroad. These alternatives can be initiated much before any contribution
by significant outputs of nuclear power.
5. The Carbon Trust awards for 2009 demonstrate
a vast range of viable solutions to decarbonising the economy
using green energy, not nuclear.
6. The Commission's ruling regarding the
validity of applying IROPI refers to situations where "plans
or projects envisaged prove to be indispensable".2 This
is not the case, because there are reasonable alternatives available.
3. The imperative need for action
1. The decision to go down the nuclear route
has only recently been taken, but knowledge about the likely lifetime
of a nuclear power station has been known since they were constructed.
2. The need to reduce global carbon emissions
has been apparent since the decisions of the Rio Earth Summit
in 1992
3. Because of the in-built lag in the global
climate system, reductions in carbon emissions now will have little
or no impact on climate change for several decades.3
4. By the same token, reductions consequent
on having operational nuclear power stations may not be detectable
for several decades beyond that. The calculation is 2025 +
40 = 2065.4
5. To repeat the obvious, the timetable
for nuclear power is too slow, and its impact on climate change
may not be detectable until 2065.
4. Human Health and Public Safety.
1. A number of power stations are due to
close by 2025. The projected interruptions to electricity supplies
and consequent effects on human health can be dealt with in many
different ways, by more aggressive action on reducing energy waste
within the domestic and industrial sectors, by planned options
from within the portfolio of clean energy alternatives, and by
alternative actions at the time.
2. Climate change is likely to cause more
frequent and more severe weather events, such as severe storms
and floods. These will cause great stress and danger to life,
disrupt transport systems, and the ability of affected communities
to function. These are of greater concern, less predictable, and
potentially much more damaging than any impacts due to interruptions
to the electricity supply caused by known deficiencies of the
electricity generation and national grid system.
3. The government's concerns as described
in Annexe A are inconsequential compared with the likely international
impacts of climate change. These are tabulated in the IPCC document
referenced below.5
5. Beneficial consequences of primary importance
to the environment
1. These have not been defined. Annexe A
does not enlarge on this important aspect of the case!
REFERENCES
1 Centre for Alternative Energy (CAT)
Zero Carbon Britain report. See www.cat.org.uk
2 Lewis Wind Farm Proposal (2006)—Report
to inform the Imperative Reasons of Overriding Public Interest
(IROPI)—TEST. Introduction, para 7.
3 The Hadley Report. Observations and Predictions.
The Hadley Centre, UK Met Office, 2004.
Over the next 40 years the warming predicted
for the five scenarios is similar, despite there being significant
differences in the amount of greenhouse gas emissions for each
case. This is because the long lifetime of atmospheric carbon
dioxide and the large thermal inertia of the climate system mean
that much of the change over the next few decades is already built
into the climate system from present day emissions and those from
the last few decades. By the same token, the climate outcome for
the latter half of the 21st century will strongly depend on the
emissions over the next few decades.
4 Whilst 2025 might seem an unduly pessimistic
date for the average completion of a nuclear power station, the
initial negative impact of a large CO2 contribution from
the construction process must be included. It will probably be
of the order of several years before the point where the excess
emissions have been cancelled out. Added to this is the likelihood
that completion will not be achieved within the timetable, so
that the figure of 2025 may well be an overly optimistic
one.
5 The International Panel on Climate Change
Summary for Policymakers of the Synthesis Report
of the IPCC Fourth Assessment Report.
Draft Copy, November 2007. Page 10, Examples of some
projected regional impacts.
January 2010
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