Memorandum submitted by Jenny Hawkes
There appear to be 4 consultation exercises
taking place between November 2009 and February 2010 relating
to energy and climate change that members of the public should
be consulted on, but know little about. Public engagement has
been badly handled, with 4 separate consultations to different
bodies about linked issues, all taking place at the same time.
It has been difficult to find out about the consultation exercises
and what to put into each submission. So I have had to combine
my responses into one document. The public consultation processes
are so flawed and confusing that the law may have been breached
and will need to be tested through judicial reviews.
I have undertaken a lot of independent research and
now believe that expanding the nuclear industry in the UK will
have a huge long term detrimental effect on the economy, jobs,
skills, local and regional business. By focussing most economic
and business interests on one main source of power production
it will deprive other types of industry of investment for many
years; it will stifle diversity and has the potential to destroy
the environment in and around the Lake District. Also, there is
no justification for the Secretary of State to approve applications
to build and operate two new types of nuclear reactor in the UK.
My reasons for such views relate to:
1. Untenable and flawed public consultation.
4. Safety and timescales.
1. UNTENABLE
AND FLAWED
PUBLIC CONSULTATION
1.1 I do not agree with the Secretary of
State's views in relation to the proposed expansion of nuclear
power in the UK including West Cumbria (at Braystones, Sellafield
and Kirksanton) or his statement to the house on 9 November 2009
in which he stated that the production of nuclear power is cost
effective, safe and reliable because of a lack of reliable, objective
evidence from DECC. The public consultation processes around the
National Policy Statements and the justification process are totally
unacceptable and do not comply with the government's own consultation
criteria for formal consultation set out in the revised Government
Code of Practice on Consultation (July 2008).
1.2 There has been no legitimate or effective
consultation with the public about the NPS or Regulatory Justification
process. The public have not been given the opportunity or time
to respond effectively to the Secretary of State's decisions on
the proposals on the Regulatory Justification of the new nuclear
power station designs. They have not been given access to the
needs based evidence on which those decisions were based, the
opportunity to challenge those decisions, or to raise any other
matters which they believe are relevant. It appears that decisions
about future energy production have been made on market based
evidence from energy producers rather than a detailed joint needs
assessment.
1.3 The National Policy Statement framework
and the Regulatory Justification consultations are not transparent,
responsive or accessible. The key issues of health, need, location
and safety cannot be discussed by the public through the NPS framework
which means that significant matters of public interest have been
excluded from consultation processes.
1.4 There is no clarity about what is being
proposed, or evidence of what the impact of the proposal are likely
to be. There is no evidence based information to the public on
the expected costs and benefits of the proposals or what scope
the public have to influence the processes. Nor have the public
been involved early enough in the planning process to modify or
change proposals when there is still time to do so.
1.5 The law may have been breached in relation
to the lack of comprehensive public consultation and engagement
in other ways too. The short duration of public consultation about
one of the most significant and complex planning decisions to
be made this century renders the whole approach unacceptable and
open to legal challenge. In the revised government code of practice
on consultation (July 2008), Criterion 2 states that consultation
should normally last for at least 12 weeks with consideration
given to longer timescales where feasible and sensible. For example,
NPS site specific consultation with the public at Braystones in
West Cumbria took place over a four day period at the end of the
consultation period with the main consultation meeting with the
public taking place on 16 January. In essence there has been no
valid public consultation and engagement. The public were not
offered a longer timescale.
1.6 The public consultation processes are
not easy to understand or to access and are clearly targeted at
major national organisations and bodies including the nuclear
industry. Local communities who will be affected by the proposals
set out in the Secretary of State's proposals have been given
minimal access to genuine consultation. There is a wide range
of consultation techniques that DECC could have used to explain
the very complex issues under debate but these have not been offered
and people who do not have access to a computer have struggled
to obtain information.
1.7 Nor has the general public been given
easy access to the relevant evidence or government information
in order to bring rigour to challenge the decisions being made.
I have had to apply for a range of relevant information on the
development of nuclear industries through the Freedom of Information
Act.
1.8 Since April 2009 I have repeatedly written
to Mr Miliband asking for information from DECC relating to costs,
safety, reliability and environmental issues in relation to the
evidence for his statements to the House advocating the nuclear
energy developments. In particular I asked for evidence that led
to his view that nuclear is a low-cost, low-carbon form of electricity
generation which can yield economic benefits to the UK.
1.9 I have received no acknowledgement or
response from Mr Miliband, so, in November 2009 and again in December
2009, I wrote to Gordon Brown saying that as an ordinary member
of the public I felt unable to make accurate comment on the serious
issue of new nuclear power based on evidence from DECC. I had
had no answers to the questions that I have posed to Mr Miliband.
I also pointed out that time is now of the essence if members
of the public are to be encouraged to respond to the NW Select
Committee in the North West or the government's consultations.
I was very disappointed that Mr Brown was prevented from seeing
my brief correspondence by civil servants at the Direct Communications
Unit at number 10. Whilst I understand that Mr Brown receives
thousands of letters each week and is unable to respond personally
to all of them. By simply forwarding the letter to DECC, about
whose lack of response I was complaining, adds to my concerns
about the flawed consultation processes. I copied all the correspondence
to my own MP, Lady Ann Winterton who has also asked for a response
from Mr Miliband. To date neither she nor I have even received
even an acknowledgement from Mr Miliband or DECC.
1.10 As a result of my research I can find
no justification for the Secretary of State to approve applications
to build and operate two types of nuclear reactor in the UK.
2. ECONOMIC ASSESSMENT
2.1 I strongly disagree with the Secretary
of State's view that nuclear is a low cost form of electricity
generation which can yield economic benefits to the UK. Mr Miliband
has failed to provide evidence on the comparative costs between
the main sources of future power production, in particular renewables,
fossil fuels and nuclear power production. It is unclear how the
overall costs of nuclear power production have been determined
by DECC. These costs do not appear to include the total cost of
nuclear power production cycle which is huge and could lead to
fuel poverty in this country. Massive costs range from the mining
and transportation of uranium to this country; transporting fuel
and spent fuel across England and Wales (Scotland has already
said no to nuclear); production of nuclear fuel from the raw materials;
building and running nuclear power plants and ancillary non-nuclear
power plant; de-commissioning of nuclear-related plants; dealing
with increased toxic waste from new types of nuclear reactors
(7x greater than existing reactors); legacy nuclear waste (50
years worth of highly toxic waste sitting in ponds at Sellafield
that no one knows what to do with) and taxpayers' underwriting
of the safety aspects of nuclear power. In early summer 2009,
in a government debate on additional funding for nuclear reprocessing
at Sellafield, Jamie Reed, MP reported that £1.3 billion
per year is currently being spent on legacy nuclear waste at Sellafield.
My research based on detailed evidence shows that nuclear power
is not financially viable or sustainable and has the highest cost
of all energy production methods.
2.2 Mr Miliband has failed to explain where
the substantial financial investment is to come from or how the
government can be assured that companies will be able to fund
and build any new nuclear power stations or that there will be
no future burden on the tax payer. He provides no evidence for
his statements that "there are unlikely to be any economic
dis-benefits arising from new nuclear power stations or that there
are benefits to the fuel poor from limiting increases in the cost
of electricity generation from nuclear power."
2.3 There are many sources of strong evidence
which set out the reasons why the UK should not pursue the further
development of the nuclear option. 3 key pieces of evidence that
should be considered by the Select Committee are:
(i) The evidence from France shows that the French,
who have adopted nuclear power on a large scale, are still importing
energy as they cannot afford nuclear power and 25% of people in
France are living in power poverty. Their oil imports have not
been diminished, their nuclear safety record is very poor.
(ii) The most detailed, independent, recent analysis
of the comparative costs of nuclear power come from Citigroup
Global Markets Inc. research and analysis paper of 9 November
2009 "New Nuclear—The Economics Say No". It explains
in detail why there should be no investment in nuclear new build.
There is no similar independent evidence from DECC.
(iii) In November 2009 the Guardian newspaper
reported that Sellafield Ltd admitted its £1.8 billion nuclear
reprocessing plant may not be able to meet NII orders for operation,
as a result of continuing technical problems. Two of the plants
have been breaking down repeatedly, and the third has been closed
after a rise in radiation levels. Work has started on a new £100
million evaporator, but it is behind schedule, and probably won't
come on stream before 2013. Germany may sue if spent fuel is not
returned reprocessed. Closure of the plant would slow decommissioning
of British nuclear plants, and remove much of the £70bn needed
for that process, which reprocessing at Thorp was supposed to
raise a good deal of, meaning another drain on the British public's
taxes.
3. STIFLE DIVERSITY
3.1 When Mr Miliband launched the consultation
at the Houses of Parliament on 9 November 2009, he made no mention
of how the taxpayers would pay for this nuclear gamble, nor the
cost to other developing energy technologies of putting all our
eggs in the nuclear basket. For example, there is a wide range
of developing energy technologies and higher education opportunities
across the whole of the north west of England that are being deprived
of investment because of the impact of concentrating all available
funding on the expanding the nuclear industry. One of the simplest,
cheapest, quickest and viable ways of maximising potential benefits
for the public and businesses communities across the region is
not to choose nuclear but to improve our energy efficiency. Everyone
can be involved, we can do it now, safely and it won't cost the
earth.
4. SAFETY AND
TIMESCALES
4.1 The costs of producing power from nuclear
sources are prohibitive; also there is no way that the new nuclear
reactors could be built in time. The government already subsidises
the nuclear industry and there have also been proposals to add
a tariff to consumer bills to pay for the excess costs of nuclear
power. Two new types of nuclear reactors are being proposed for
plants in this country. One of a type proposed for the reactors
in West Cumbria is being built by a French company called Areva
at the Olkiluto plant in Finland and at Flamaville in France.
Both building programmes have fallen far behind schedule because
of design problems and are way over budget. The French company
is involved in a legal battle in Finland with the end user utility
company about the overruns. The new American Westinghouse design
is also running behind schedule. Both designs have serious flaws.
4.2 The HSE has to approve the safety of
any new designs before they can be built in the UK. Kevin Allars,
director of new nuclear build at the HSE, admitted frustration
that the design assessment process of the new nuclear reactors
being proposed for this country is already behind schedule owing
to insufficient information from the companies promoting the reactors
and to the lack of enough trained staff in his own directorate
to do the work. In a report published on 26 November 2009, the
HSE said that it is too early to say yet if issues relating to
the structural integrity of the design of the Areva EPR can be
resolved simply or whether it may result in design modifications
being necessary. An alternative nuclear reactor design being proposed
for the UK is the new American Westinghouse design. This design
was owned by BNFL prior to Labour selling it off to Westinghouse,
is now owned by Toshiba of Japan. It too, is running significantly
behind schedule and has also been criticised by the HSE. Their
report questions aspects of the civil and mechanical engineering
plans as well as the structural integrity of the Westinghouse
design.
4.3 Nuclear technology is not robust, safe
or environmentally friendly. There were 1,767 leaks, breakdowns,
or other safety "events" at British nuclear plants between
2001 and 2008. A recent Nuclear Installations Inspectorate (NII)
report says about half were serious enough "to have had the
potential to challenge a nuclear safety system". A radioactive
leak, undiscovered for 14 months, was found at Sellafield just
before a visit by the prime minister in February last year. A
board of inquiry concluded the leak went unnoticed because "managerial
controls over the line were insufficient and there was inadequate
inspection". Meanwhile, elsewhere on the site two containers
of highly radioactive material went missing. The operator said
it was most likely that "the anomaly lies within the accounting
procedures".
4.4 Since September 2009 there have been
four fires at nuclear power stations, three in France in September
and November, and one at Dungeness B in Kent last month. A spate
of nuclear leaks last year forced the French government to address
public fears by ordering drilling into, and sampling, of the groundwater
under all 58 French nuclear reactors. Last July, a heatwave shut
a third of French reactors, because rivers became too hot to act
as coolant. France was forced to import electricity from the UK.
4.5 Should there be any judicial reviews
as a result of the flawed consultation processes, the timescales
could run significantly behind schedule.
5. ENVIRONMENTAL
ISSUES
5.1 Mr Miliband also stated that nuclear
power is proven and reliable—it is not. Nuclear technology
is not robust, safe or environmentally friendly. The Government
is proposing to site three new nuclear power stations between
Workington and Ulverston on the West Cumbrian coast—in the
very area which has suffered, and regularly suffers, from unpredictable
extensive flooding. Worse still, DECC is considering burying nuclear
waste, that they don't otherwise know what to do with, in the
same areas Mr. Brown visited when he spoke to the flood victims.
There is no proven, safe or reliable way anywhere in the world
of disposing of nuclear waste so why bury it on a flood plain
in West Cumbria? There are concerns about water contamination
from the Yucca Mountain Project where America buries its nuclear
waste, in an area where the annual rainfall is 9.5" per
annum. Cumbria averages 35.84" rainfall per annum,
even without the current exceptional storms. In December 2009,
Dr John Ashton, Director of Public Health in West Cumbria raised
concerns about water contamination with the flood victims in West
Cumbria, how much worse could it be for local people if flood
water became contaminated with radio-active waste?
5.2 My research shows that nuclear energy
is not CO2 free. The only part of the nuclear power production
cycle that seems to be carbon neutral is the actual running of
the nuclear power plants; the government also appears to be overlooking
the fact that nuclear power plants produce many other toxic emissions,
far more damaging to the environment than CO2. It's interesting
that Sellafield's nuclear reprocessing plant has to have its own
reliable gas fired power plant which burned £30 million of
gas last year.
6. INFRASTRUCTURE
West Cumbria Issues
6.1 There has been no mention of how the
regional infrastructure in West Cumbria will need to be developed
during and post any construction phases or who is to fund it.
Local networks such as road, rail, power supplies, drainage, sewers
and telecommunication connections are currently overloaded and
insubstantial. For example, there have been no discussions with
Network Rail about any development of the coastal railway line
which is already prone to flooding and needs continuing significant
work to maintain the single track. Access by road to West Cumbria
is difficult with only one main A road, the A595 which, when closed
for any reason, results in long detours across mountain roads.
Road access to the villages of Braystones and Kirksanton is very
poor because of the topography of the area. Extensive and robust
flood defences will need to be installed before any of the construction
work begins around the proposed sites at Braystones, Kirksanton
and Sellafield because of river and coastal erosion, and the area
is crossed with rivers which regularly flood. RWE has proposed
building a marine offloading facility at Braystones to bring in
construction supplies by sea including the nuclear reactors. They
have taken no account of the lack of draught available even at
high tide or the need to dig out the sea bed which is heavily
contaminated with plutonium.
7. HEALTH MATTERS
7.1 The Committee on Medical Aspects of
Radiation in the Environment (COMARE) will only pronounce on the
health aspects of nuclear power after the closing dates for the
consultation on the Energy NPS and your response submission dates.
7.2 Nor can I find any evidence based health
information from the local PCTs on health matters in relation
to public health and nuclear power, of the possible radiological
health detriment to the people of West Cumbria from Sellafield
or the potential health detriment arising from three new nuclear
power plants. There is no mention of the potential health detriment
arising from the management and disposal of nuclear waste in and
around West Cumbria, the continuing toxic emissions into the atmosphere
or ongoing discharges into the Irish Sea.
7.3 I had assumed that, as the most authoritative
health body in West Cumbria, NHS Cumbria would be submitting a
response to the NW Select Committee and to the governments' consultation
on Nuclear Power, regarding the possible radiological health detriment
to the people of West Cumbria from Sellafield or the potential
health detriment arising from three new nuclear power plants at
Braystones, Kirksanton and Sellafied. In the light of repeated
flooding in Cumbria over recent years the Public Health response
should give a detailed assessment of the potential health detriment
arising from the management and disposal of nuclear waste in and
around West Cumbria. Also I expected that such a response would
take account of the Redfern Inquiry into human tissue analysis
in UK nuclear facilities. Under the Freedom of Information Act
I asked if Dr John Ashton could send me a timely copy of the response
and asked him if he intended to publish it in the national and
local press. To date I have not received any acknowledgment of
my request or a copy of his response.
7.4 The most informative evidence based
health research I can find is from the German KiKK study which
has been accepted by the German Government and shows increased
cancer incidences near all 16 German nuclear reactors and a 2.2
x increase in child leukemias which both have proven strong links
to living near and working in nuclear reactors.
January 2010
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