Memorandum submitted by Greenpeace
1. INTRODUCTION
1.1 Greenpeace welcomes the opportunity
to submit evidence to the Energy and Climate Change Committee
hearing on the Energy National Policy Statements (NPS).
1.2 Greenpeace believes that new nuclear power
is inadequate, unnecessary and dangerous. It is inadequate because
it offers too little, too late in terms of climate change. It
is unnecessary because we can reduce emissions and keep the lights
using better technologies instead. It is dangerous because of
the intractable problems of radioactive waste and nuclear weapons
proliferation. But there is another danger: the danger of distraction.
Renewables and energy efficiency are booming in other countries,
could be the cornerstone of a green economic recovery in Britain,
quickly secure our power and become a springboard for greater
emission reductions in future. But despite the UK's abundant wind,
waves and engineering skill, lack of government focus and priority
means Britain's renewables industry remains tiny.
1.3 Justification for new nuclear capacity in
the NPSs is based on an apparent refusal to acknowledge the significant
potential for renewable electricity generation. Instead they present
a hobson's choice between either more nuclear or more gas, oil
and coal: "failure to take account of the ability to develop
new nuclear power stations significantly earlier than the end
of 2025 will increase the risk that the UK is locked into higher
CO2 emissions than would otherwise be necessary. This is because
of the high-carbon nature of thermal generation capacity that
might otherwise help to meet the demand for electricity."2
It is quite wrong and deeply misleading to present the argument
in this way.
2. VIEWS ON
THE NATIONAL
POLICY STATEMENTS
2.1 There is a significant disconnect between
government policy and the Infrastructure Planning Commission (IPC)
over climate change. Under the NPSs the IPC does not have the
remit to consider infrastructure projects in terms of their potential
lifetime greenhouse gas (GHG) emissions. This is because climate
change targets are policy issues for government and so outside
the IPC's remit. This means that the IPC effectively exists in
a vacuum, deciding on major infrastructure projects that will
have significant GHG emissions implications, in an economy that
is attempting to decarbonise, yet unable to take into consideration
the climate impacts of the projects that they are assessing.
2.2 This is a most peculiar state of affairs.
It remains to be seen how the IPC can possibly green-light infrastructure
projects that will meet our binding climate change targets, or
severely compromise them through carbon lock-in, when they cannot
consider the GHG emissions of the projects themselves.
2.3 There is also a question of whether
the NPSs constitute adequate planning documents. The NPSs are
supposed to allow the IPC to make considered and evidence-based
decisions on whether to allow major infrastructure projects to
proceed, but certainly in terms of nuclear, their considerations
must be made having taken suppositions from government on issues
such as radioactive waste disposal at face value. Significant
concerns exist as to the practicability of safely managing new
build spent fuel arisings (not least because the industry has
thus far been either unwilling or unable to say exactly how they
intend to deal with them), yet the Nuclear NPS instructs the IPC
to unquestioningly accept promises from government and industry
that arrangements for cooling, storage, conditioning, encapsulation
and eventual disposal of spent fuel "exist or will exist"
at some unspecified point in the future.
2.4 Given both the lack of concrete proposals
that presently exist for dealing with new build spent fuel, and
the nuclear industry's dubious safety record and history of evasiveness
and dishonesty, this is an extraordinary assumption to be forced
to make. This makes it seem as though the sole purpose of the
nuclear NPS is to allow the IPC to say "build a reactor"
without any real consideration of the technical practicalities
of if/how radioactive wastes arising from their construction can
be dealt with. Consequently the absence of such significant information
that would normally guide planners' decisions means that under
no circumstances does the nuclear NPS fulfil its stated purpose.
2.5 Will the IPC be so narrowly focused
(because of the guidance in the NPS) that it will only examine
site-specific issues (eg access roads) as opposed to wider issues
of major public concern, such as spent fuel management? Take this
theoretical position:
— EdF submit an application to the IPC
for Hinkley C sometime in 2010.
— Their plans for spent fuel remain as
hazy as they are today.
— The regulatory position is that the Generic
Design Assessment (GDA) pre-licensing of reactors hasn't properly
assessed the acceptability of waste management proposals for the
EPR reactor (GDA probably will not finish before 2012 and this
issue was specifically mentioned by the Health and Safety Executive
(HSE) in their 3rd Stage Assessment in November 2009).
— At the same time the Department for Energy
and Climate Change (DECC) has not finalised the proposals for
a Funded Decommissioning Programme (in which potential operators
must clarify back-end management plans) and crucial Fixed Unit
Price are not expected to do so until after 2011. The public consultations
on these have not yet started.
The question is this: will the NPS allow the
IPC to freeze EdF's application until these issues are adequately
resolved, or will they press on regardless?
3. THE NATIONAL
POLICY STATEMENT
PROCESS
3.1 The amount of documentation that the
public must read, understand and consider before they can be expected
to make reasoned comments on the conclusions of the draft nuclear
NPS by 22 February 2010 (a period of only 15 weeks including the
Christmas and New Year holidays) is vast. A member of the public
living near Bradwell in Essex would have to read a staggering
1,674 pages of documents to take in the bare bones of every part
of the consultation, including looking at why other sites like
Dungeness were not selected. This is more than Tolstoy's War
and Peace.1 Whilst our energy future is an issue that concerns
each of us, given its very complex nature and some of the important
conclusions the NPS reaches, and the fact that the consultation
is running concurrently with the Regulatory Justification consultation
(and other consultations eg CoRWM's consultation on new build
wastes), we believe the amount of data and the confusing way in
which is has been presented by the Department for Energy and Climate
Change have made entirely unreasonable demands on the public and
local authorities.
3.2 The overall emphasis of the Energy NPSs is
skewed in such a way as to paint new nuclear in an overly positive
manner, to the detriment of alternative renewable technologies.
For instance, there are 39 references to the term "employment"
in the nuclear NPS2 but no references to the same term in the
renewable NPS.3 The nuclear NPS also consistently refers to "energy"
and conflates this with "electricity", giving a further
misleading appraisal of the potential for new nuclear.
4. THE NEED
FOR NEW
NUCLEAR
4.1 The nuclear NPS claims that new nuclear
is needed because "excluding nuclear power as an option for
generating electricity would make it harder and more expensive
to meet our emission targets. It could also jeopardise the security
of the UK's energy supply."2 Greenpeace strongly refutes
this notion. We do not believe that there is an overriding national
need for any new nuclear generating capacity.
4.2 Even the most optimistic estimates suggest
that new nuclear will provide only a 4% emissions reduction sometime
after 2020.4 Our binding target is a 34% cut by 2020.5 Nuclear
is presented as a key pillar of energy strategy. It is not.
4.3 The UK can reduce emissions and keep
the lights on using better technologies instead. In the next decade
meeting our existing renewables and efficiency targets would safely
close the "energy gap" and cut emissions, while leaving
plenty of potential to expand renewables even further later.6
4.4 There have been claims that nuclear
power could supply 40% of the UK's electricity beyond 2030.7 Greenpeace
is doubtful that in a liberalised energy market the possible size
of the generating fleet can be determined. What can be safely
assumed, however, is that if new nuclear produces not just 10GW
but anywhere up to 23GW or more this will crowd out sustainable
energy alternatives. If government continues to favour nuclear
power, through direct or indirect political or financial support,
utilities will follow their lead, which would be to the detriment
of renewable energies. A massively expanded new build fleet would
also have enormous implications for the management of highly radioactive
wastes, for which there is no proven solution.
5. REGULATORY
JUSTIFICATION
5.1 The UK government has yet to confirm
whether the practice of operating the new Areva/EdF European Pressurised
Water Reactor (EPR) and Westinghouse AP-1000 reactors is justified
under EU law.8
5.2 Justification is a regulatory requirement
under EU law that must be completed before new reactors can be
built. Justification is a high level strategic assessment in which
the disadvantages of a "practice" involving releases
of ionising radiation (in this case new nuclear power and all
associated activities eg spent fuel storage and disposal) are
weighed against its potential benefits (economic, CO2 emissions
etc).
5.3 There is an on-going consultation on
this issue that will not conclude until the end of February 2010.
Though the government has reached a preliminary conclusion that
new nuclear is justified, Greenpeace feels it is presumptuous
to assume that the practice of new nuclear will certainly be signed
off in the near future.
5.4 The IPC has been instructed not to consider
whether the aims of the EU Directive have been or will be implemented
(see NNPS 4.8.12).
6. GENERIC DESIGN
ASSESSMENT AND
LICENSING
6.1 The Health and Safety Executive's (HSE)
Generic Design Assessment (GDA) process, though not legally binding,
is an overarching safety assessment of the EPR and AP1000 reactors
designed to avoid many of the pitfalls of past reactor programmes.
Yet is it likely it will not deliver the outcome the Government
hopes.9
6.2 The UK nuclear industry has an appalling
track record of meeting schedules and budgets and any claims that
vendors or potential operators make regarding bringing new capacity
online on time should be treated with utmost circumspection. The
Committee should carefully consider the catalogue of delays at
cost overruns bedevilling the projects at both Olkiluoto-3 in
Finland10 and Flamanville-3 in France11 as we feel they illustrate
the nature of the problems we are likely to face with UK new build.
6.3 Indeed, problems are already surfacing
in reports from the safety regulators. It has been reported that
at the end of the GDA process in around mid-2011 there will most
likely be "exclusions" and "conditions" attached
to the sign off on reactor designs.12 These issues will have to
be resolved by potential builders and operators under the site-specific
licensing process. Given the issues outstanding there is no guarantee
either GDA or licensing will be finished to the timelines produced
by government.
6.4 As an example of the problems outstanding,
we refer the committee to the HSE's recently published the 3rd
Stage GDA report on the EPR.13 They concluded that "we have
identified a significant number of issues with the safety features
of the design." This followed the HSE taking the unprecedented
step of releasing a Joint Regulatory Position Statement on the
EPR with their Finnish and French counterparts. The statement
said, "The issue is primarily around ensuring the adequacy
of the safety systems (those used to maintain control of the plant
if it goes outside normal conditions), and their independence
from the control systems (those used to operate the plant under
normal conditions). Independence is important because, if a safety
system provides protection against the failure of a control system,
then they should not fail together. The EPR design, as originally
proposed by the licensees and the manufacturer, AREVA, doesn't
comply with the independence principle, as there is a very high
degree of complex interconnectivity between the control and safety
systems. As a consequence of this, the UK nuclear safety regulator,
the French nuclear regulator, and the Finnish nuclear regulator
have asked the licensee and manufacturer to make improvements
to the initial EPR design."14 It is very worrying that EdF
apparently do not agree with the HSE's assessment. The Senior
Vice President Nuclear Engineering recently said that EdF "is
"confident we will qualify" the Siemens SPPA-T2000 control
I&C system for use without modifications."15
6.5 The HSE GDA 3rd Stage report on the
Westinghouse AP1000 was similarly scathing.16 It concluded that
"there is significant additional work to be done by Westinghouse
to satisfy our questions and to make and present an adequate safety
case in the majority of the technical topic areas|In some of the
areas that we have already assessed we found that there was a
lack of detailed claims and arguments."17 But in spite of
these major problems Westinghouse has not responded promptly to
requests for further information about whether the reactor can
stand up to things like earthquakes and aircraft crashes.
6.6 As the GDA findings show, new reactor
designs proposed for the UK do not by any stretch of the imagination
represent a "proven" technology as claimed in the nuclear
NPS. The fact remains that any new reactor, be it an EPR or AP1000,
will be first-of-a-kind and very much UK specific and as it stands
operators are unable to prove that the designs meet basic reactor
safety standards.
6.7 The IPC's relationship to the GDA process
seems fragmented. For instance, the nuclear NPS states that the
IPC "does not need to consider matters that are within the
remit of the nuclear regulators, although it is to liaise with
them." Instead it may seek a regulatory "letter of comfort."
6.8 Given the above it is essential that
the Committee fully considers also the potential impact of an
accident (or malicious act) on a reactor or spent fuel store.
The probability of such an event may be low, but the potential
consequences so huge they have to be thoroughly scrutinised.
6.9 One example of how Governments and industry
view the real impact of an accident is in the changed international
liability insurance regime that covers nuclear accidents. The
UK has yet to consult on, and enact, legislation to cover the
increased financial liability and expanded coverage for a nuclear
accident.18 It has been reported that the insurance industry has
refused to provide the cover necessary for existing and new reactors,
potentially leaving the public exposed to even higher costs in
the event of a major accident.19 This matter should have been
discussed in the nuclear NPS as the risk of accident applies not
only to reactors, but also the spent fuel stores planned for sites.
7. CLIMATE CHANGE:
SEA LEVEL
RISE, STORM
SURGE AND
FLOODING
7.1 All of the sites earmarked for new nuclear
development in the NPS are in coastal areas, mainly because of
the significant volume of water reactors need for cooling. However,
the UK's coastal zone is, in many cases, a dynamic and shifting
environment. Changes in coastal geomorphology may well become
more significant in the future because one of the predicted outcomes
of anthropogenic climate change is an increase in global sea levels.
This in turn could have a significant detrimental impact on nuclear
power stations sited in coastal regions.
7.2 Whilst the government claims it has closely
assessed the potential impact of sea level rise on possible sites
for new nuclear, Greenpeace would like to draw the Committee's
attention to research carried out for us by the Middlesex Flood
Hazard Research Centre.20 This found that "it is hard to
escape the conclusion that the most sensible approach would be
to reject all nuclear new-build within the dynamic coastal environment."21
7.3 New research has suggested that loss
of ice from the West Antarctic ice sheet could "contribute
to a projected total sea level rise of up to 1.4 metres by 2100"22,
23 at a far quicker rate than previously estimated. This figure
is could "result in large tracts of eastern England being
inundated with seawater ... It would also increase the chances
of storm surges flooding major coastal cities, such as New York
and London, even with the protection offered by the Thames Barrier."24
The Met office recently concluded that "by 2100, storm surge
heights may increase dramatically—by up to 1.7 metres in
the most affected areas of Suffolk, where the Sizewell B nuclear
power plant is located."25
7.4 Yet in the nuclear NPS the HSE admit
that it has only been able to assess sea level rise based on modelling
and predictions for 100 years—even though one of the plans
for spent fuel is to keep it on site for possibly up to 160 years.
8. RADIOACTIVE
WASTE MANAGEMENT
8.1 It is claimed in the nuclear NPS that
arrangements to deal with wastes "will exist." The simple
fact is that there is nowhere on Earth to put this waste—there
is no environmentally acceptable and proven "solution"
for the disposal of high level radioactive wastes and spent fuel.
Such disingenuous and misleading statements mark a return to the
days when real decisions on nuclear waste were habitually put
off, leaving future generations to deal with the problem. The
matter, for example, of where and for how long spent fuel might
be stored and conditioned should have been fully detailed in the
NPS so that local communities (at reactor sites and the potential
host community for a national geological repository) could consider
the implications of the various options industry and government
agencies are considering. This is essential because for as the
nuclear NPS states the IPC will not be allowed to consider spent
fuel and waste storage: "having considered this issue, the
Government is satisfied that effective arrangements will exist
to manage and dispose of the waste that will be produced from
new nuclear power stations. As a result the IPC need not consider
this question."2 It is unacceptable that both the principle
and the practicalities of spent fuel management will not be discussed
and all debate foreclosed by the IPC.
8.2 There are clearly differences in the approaches
of the reactor vendors on the issue of spent fuel encapsulation.
These are highlighted in a presentation from the Environment Agency26
and in HSE reports on the two reactor designs. On the EPR the
HSE notes: "EDF and AREVA still need to show that the encapsulation
of spent nuclear fuel for disposal is ALARP and that the environmental
impacts are acceptable. I have raised a TQ requesting EDF and
AREVA to provide this information."27 On Westinghouse's AP1000
the HSE notes: "In the absence of any other firm agreement
it must at this stage be assumed that any encapsulation will be
performed at the reactor site and I have raised TQ-AP1000-329
(Ref. 10) requesting information on how the fuel will be encapsulated.
A response is outstanding, but when received it will need to be
considered with the "disposability" case."28
8.3 Westinghouse and Areva are already openly
challenging the government's assumptions on the proposal that
spent fuel would be stored for 100 years prior to disposal.29
Westinghouse has written to the Nuclear Installations Inspectorate
stating: "[We have] concerns over the length of time that
high burnup spent fuel would have to remain on site before it
could be disposed in the repository design currently envisaged
for the UK. Reliable, high burnup fuel is economically and environmentally
beneficial, yet the projected designs of the spent fuel encapsulation
containers, combined with those of the repository cells are such
that they cannot accommodate such fuel without a cooling period
so long that it would make the repository unavailable for some
of the spent fuel."30
8.4 There is complete uncertainty as to
exactly how spent fuel may be dealt with from new nuclear reactors.
Possibilities include:
— Spent fuel is to be kept on-site at reactors.31,
32, 2
— Pending a period of on-site storage it
could remain on-site or be moved to a regional or central store.33
— Spent fuel may be stored for only five
years (pending possible removal to a central storage facility)
or 10 years,34, 35 but possibly up to 50 years,36 10037 or 160
years (on or off-site).38
— Spent fuel will be encapsulated on site39
or at a central site.
— Stores may or may not need to be replaced.40
Stores may be above ground or underground.41
— Title and liability stays with the operator
until it leaves the site or, if no geological disposal facility
is built, the government/Nuclear Decommissioning Authority (NDA)
take title and liability.42 Title and liability may pass to the
NDA for encapsulation whether there is a repository or not.
— There may be one or two geological disposal
facilities depending on the timing of availability of a repository
(ie how long it is kept open) and also the amount of wastes produced.43
8.5 Whether the industry shares encapsulation
costs with the NDA is an issue which should be examined in case
it constitutes an indirect subsidy (depending on how costs for
encapsulation facilities are allocated). In reply to an FOI request
the NDA stated that: "The operator of a new build power plant
will be responsible for the cost of managing their waste pending
disposal, which includes the cost of packaging spent fuel (SF).
This does not necessarily mean that the operators will package
the SF themselves. They may do so, or they may contract with a
3rd party to encapsulate their SF. In their Funded Decommissioning
Programme (FDP) the operator must set out the steps they propose
to take to manage their waste and have this plan approved by Secretary
of State. These plans will be regularly reviewed and operators
can submit modifications to their plans for approval. The Government
might need to undertake the necessary steps to package the SF
into a disposable form. The costs of encapsulation will be a cost
for which the operator will have made provision in their independent
Fund and in these circumstances the amounts that operators have
budgeted for these costs (set out in their FDP and agreed with
the Secretary of State) would pass to the Government when title
to and liability for the waste transfers, to cover the costs of
performing this."
8.6 The regulations and statutory guidance
on Funded Decommissioning Programmes (FDP) and the Fixed Unit
Price (FUP) are not finalised and will not be until late 2010
and mid-2010 respectively, if then. The FDP and FUP is the process
by which the Secretary of State will sign off on plans for site
decommissioning and spent fuel storage and disposal: "The
Energy Bill will require any operator of a new nuclear power station
to have a Funded Decommissioning Programme, approved by the Secretary
of State, in place before construction of a new nuclear power
station begins and to comply with this programme thereafter"44
(our emphasis).
8.7 The current basis for the initial fixed
unit price for geological disposal is that it will be co-disposed
with legacy wastes. The timing of deciding on both an FDP and
FUP, and agreeing this with reactor operators appears, to conflict
with that of other key processes that need to be determined before
the FUP can be decided. A crucial one of these is that the IPC,
local communities and local authorities, should know exactly what
the waste plans are before these are set in stone though an industry-government
agreement (negotiations on the FUP will be between the operators
and the Government. They will not involve the public or Parliament).
8.8 A recently published timeline shows
the FDP will be finalised the same time as the first site license
is agreed (immediately after the GDA process ends) and when planning
is granted.45 The IPC process will supposedly have started over
a year in advance of this, meaning firm plans will not be available
for public scrutiny. Yet the regulators have said that the issue
of exactly where spent fuel will be stored (and for how long)
and be encapsulated will not be known until 2012-13.
8.9 No assumption can be made that disposal
even of legacy wastes will take place and certainly not on the
timeline proposed by the NDA. This issue is fraught with difficulties.
The addition of new build waste could create many more problems.
The first CoRWM noted: "We believe that future Government
decisions on new build should be subject to their own public assessment
process, including consideration of waste, because such decisions
raise different political and ethical issues when compared with
the consideration of wastes which already exist. We have noted
before that the prospect of a new nuclear programme might undermine
support for CoRWM from some stakeholders and citizens and make
it more difficult to achieve public confidence."46
8.10 The NDA itself has gone on record as
saying: "There is no guarantee that the process will succeed
in Cumbria. We need to bear in mind that the community has the
right of withdrawal at any time and they do not need to justify
their decision."47
8.11 Concerns that Cumbria may not ultimately
accept a repository prompted the government to re-issue its invite
to all local authorities to reconsider applying to volunteer to
host a repository. In October 2009, Energy Minister Lord Hunt
had to remind "local communities about the opportunity to
consider hosting a geological disposal facility."48 This
is because as yet only three councils in the whole country have
expressed an interest, all from Cumbria: Copeland,49 Allerdale50
and Cumbria County Council.51
8.12 Yet the NNPS proceeds on the basis
that:
— Any potential host community will accept
all legacy wastes and all new build wastes—the inventory
has yet to be even discussed in Cumbria. This view contradicts
any notion of true voluntarism by a community.
— That a site can be found that can accommodate
all wastes—the Fixed Unit Price (based on co-disposal of
legacy and new build wastes) for the first round of new reactors
might set this in stone before these matters are signed off on
by a community
— In the interim, a repository host community
might also have to accept a central store for all spent fuel and/or
an encapsulation plant (although this has not been clearly expressed,
which underlines the vagueness of the spent fuel management proposals).
8.13 The concerns over disposal are more
than of a political and social nature. David Smythe, Professor
of geophysics at Glasgow University has stated: "There is
clear evidence, after the expenditure of some £400 million,
mostly directed to the Sellafield area, that West Cumbria possesses
no suitable rocks in which to site such a repository ... To choose
Sellafield yet again, by way of community voluntarism, and despite
the lessons that have been learned, would be wrong and possibly
illegal in international law."52 In addition, by depending
on one (as yet undecided) community, there may be significant
implications for the taxpayer. It has been reported that "the
Treasury is resisting plans to invite councils to bid for the
right to house the waste because it fears that only one council—the
one that includes Sellafield in Cumbria—will apply. This
lack of competition would leave it able to demand extra funding
of more than £1 billion."53
8.14 This means the government's plans could
practically force Cumbria not only take all radioactive wastes,
but possibly also take a long-term store for a new build spent
fuel and an encapsulation plant.
8.15 Yet in all of this it is vital to remember
there is no environmentally acceptable and proven "solution"
for the disposal of high level radioactive wastes and spent fuel.
There is no disposal site operational anywhere in the world for
spent fuel. Indeed, as Areva has noted: "No spent fuel direct
disposal facility is currently available in the world."54
Government assertions that a solution exists are therefore deeply
misleading. The most advanced site, Yucca Mountain in the USA,
has effectively been abandoned: "Yucca Mountain has been
placed in what the Department of Energy calls `cold standby.'
Congress cut almost $100 million from its $386 million budget
this year, forcing DOE to lay off 500 of its 1,400 workers. The
new Obama administration budget proposes to stop funding altogether
while a `blue ribbon' panel explores other alternatives for nuclear
waste disposal."55 It is entirely misleading for government
to point to other countries' plans for possible waste disposal
as a basis for allowing the nuclear industry to create more highly
radioactive wastes.
8.16 The NNPS should be able provide clear
information so that the IPC can answer all of the following questions:
— Is the operator of a new reactor currently
in a position to say publicly exactly what its agreed plan to
deal with spent fuel from any potential new reactors on site is?
If so, what are these plans?
— Post-cooling, will spent fuel be put
into wet- or dry-storage?
— Will storage be sub-surface or at surface
level?
— Exactly how long will spent fuel be stored
on site for?
— How will spent fuel be conditioned? Where?
— How will spent fuel be encapsulated?
Where?
— When will title and liability of the
operator's spent fuel arisings pass to the government?
— Where will final disposal of new build
spent fuel arisings eventually take place? When?
8.17 Greenpeace strongly recommends that
the Committee read a recent article by Professor Gordon MacKerron,
former Chair of CoRWM, on the issue of waste disposal and the
nuclear NPS. It is attached in Appendix 1 of this submission.
9. NON-NUCLEAR
ISSUES
9.1 It is clear from current investment
forecasts that gas will remain a fundamental part of the UK energy
mix for at least the next decade, whichever transition pathway
is ultimately pursued. Given this fact, Greenpeace believes there
is insufficient detail within the existing NPS regarding the pathway
to bring about the decarbonisation of UK gas use, particularly
in gas-fired power stations. There is no equivalent to the coal
CCS demonstration programme announced last year by the government,
despite the fact gas is and will remain a more significant source
of the UK's primary energy consumption than coal. Without the
inclusion of the recommendation by the Committee on Climate Change
to reduce emissions from the electricity sector by 2030, The NPS
fails to provide sufficient certainty regarding the future CCS
requirements for gas to either utilities looking to construct
new gas capacity or to those concerned about the carbon implications
of new gas capacity. The current requirement of Carbon Capture
Readiness outlined in the NPS is largely a restatement of the
existing conditions contained within section 36 of the Electricity
Act 1989, and adds little to outlining the pathway from readiness
to deployment, which remains a significant gap in the government's
energy and climate change policy.
10. RECOMMENDATIONS
— The Committee asks the reactor vendor
companies and potential new build operators to provide detailed
plans on spent fuel during storage and encapsulation.— The
Committee should ask the HSE and Environment Agency EA for their
views on these plans.
— That the timelines on the local authority/IPC
planning processes, the FDP/Fixed Unit Price processes and licensing
run sequentially so that discussions and decisions take place
in a progressive rather than conflicting manner.
— That the Committee recommends extending
further the time for the consultation, particularly given that
none of the NPSs will be designated before the expected general
election.
— The NPS should contain a map and timeline
for all energy infrastructure projects (plant, transmission etc),
showing what order the government believe they have to come on-line
to meet the government's stated objectives.
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