Memorandum submitted by Horizon Nuclear
Power
INTRODUCTION
1. Horizon Nuclear Power (HNP) welcomes
the opportunity to submit evidence to the Energy and Climate Change
Select Committee's Inquiry into the Proposals for National Policy
Statements on Energy. We note that the Committee has indicated
that a specific focus will be on whether the draft energy National
Policy Statements (NPSs) provide a coherent and practical framework
within which the Infrastructure Planning Commission (IPC) can
assess future planning applications for energy infrastructure.
2. HNP is a joint venture between E.ON UK
and RWE npower. We aim to develop and construct around 6GW of
new nuclear power station capacity in the UK and have already
acquired interests in land at Oldbury in Gloucestershire and Wylfa
on Anglesey in Wales. We have also concluded grid connection agreements
for both sites.
3. Both the Oldbury and Wylfa sites were
nominated into the Government's Strategic Siting Assessment (SSA)
and we are pleased that both have subsequently been identified
in the draft Nuclear NPS as potentially suitable sites for nuclear
power station development.
4. We recognise the importance of reading
the technology specific NPSs in conjunction with the draft Overarching
Energy Infrastructure NPS (EN-1). We have, therefore, commented
as appropriate on EN-1 and taken into account aspects of other
NPSs including the electricity networks NPS (EN-5). In this evidence
we have, however, focussed primarily on the draft Nuclear NPS
(EN-6) and its associated documentation and, in terms of site
specific matters, on our two sites at Oldbury and Wylfa, recognising
that our shareholder companies will more properly consider other
technology specific NPSs in their own submissions to the Committee.
THE NATIONAL
POLICY STATEMENTS
5. The publication of the draft NPS documentation
is an important step in the creation of a planning policy framework
for nationally important energy infrastructure projects. In particular,
EN-1 establishes the national need for new low carbon generating
capacity. We believe that all available low carbon technologies
will be required if the UK is to meet its energy policy objectives
of achieving environmentally sustainable, secure and affordable
supplies of energy.
6. As potential investors in new nuclear
capacity, we are pleased to see that the scale of new capacity
identified as being required in the draft NPSs means that there
is scope for a significant amount of new nuclear build, allowing
society to enjoy the accompanying benefits of low carbon and secure
electricity supplies. This would involve substantial capital investments
and it is important that the planning framework is both predictable
and reliable. We believe that the designated Nuclear NPS should
also acknowledge that nuclear power provides added fuel security
benefits not only through increasing fuel diversity, but also
through the industry's ability to store fuel and to continue generating
electricity over a long period of time without refuelling if required.
7. The NPSs are, therefore, a vital element
in an overall planning framework that should:
— ensure energy companies interested in
promoting new, large energy projects can develop their projects
in the context of a stable, agreed strategic need for new energy
infrastructure to maintain and develop a diverse fuel mix for
electricity generation;
— once designated, avoid the need to repeat
consideration of this strategic need when the IPC is examining
planning applications for specific nuclear and other power generation
projects;
— define the criteria, including technology
specific aspects, which companies and the IPC must take into account;
and
— provide appropriate opportunities for
public consultation and involvement.
8. We therefore support the formal designation
of the NPSs as part of an integrated approach which will be essential
in promoting investment in a diverse fuel mix for electricity
generation.
GUIDANCE TO
THE INFRASTRUCTURE
PLANNING COMMISSION
9. Some specific observations on the guidance
offered to the IPC by the draft NPSs, focussing on the draft Nuclear
NPS and its associated documentation, are offered below.
STRATEGIC NEED
FOR NEW
NUCLEAR
10. EN-1 sets out the urgent national need
for new electricity generating capacity. The draft Nuclear NPS
and its Annex A "Imperative Reasons of Overriding Public
Interest (IROPI)" reiterate this need. The draft nuclear
NPS sets out the benefits offered by new nuclear capacity as a
source of safe, secure, reliable and affordable form of low carbon
electricity generation with the ability to make a significant
contribution to security of supply. We agree that new nuclear
build is one of the key technologies capable of being deployed
within the timescales required to help meet the UK's emissions
targets and assist in decarbonising the economy.
11. We also welcome the identification of
specific sites that are potentially suitable for deployment by
2025. This is underpinned by very detailed sustainability and
ecological assessments—the Appraisals of Sustainability
(AoS) and Habitats Regulations Assessments (HRAs) both for the
NPS as a whole and the specific sites identified as potentially
suitable for development.
12. Establishing the strategic need and
planning criteria for new nuclear build will assist all participants
in the planning process and remove the potential for delays in
decision-making caused by a lack of clarity about national policy.
PROJECT ASSESSMENT
CRITERIA
13. The generic project assessment criteria
for nationally significant energy projects are set out in EN-1
(the Overarching Energy NPS) and include the aspects of project
development that we would expect to address in any planning application
and associated documentation. EN-6 sets out the appropriate specific
criteria that the IPC should take into account for new nuclear
power stations. We therefore believe that, taken together, EN-1
and 6 give strong guidance to the IPC with respect to project
assessment criteria.
14. In our opinion, the draft Nuclear NPS
appropriately covers in strategic terms the impacts of new nuclear
power stations and potential options to mitigate those impacts.
Mitigation measures will be developed and refined iteratively
as part of the development of proposals. We consider their further
assessment in the project level Environmental Impact Assessment
(EIA) to be appropriate. The inclusion of environmental management
plans in the Environmental Statement (ES) accompanying the application
for development consent is also appropriate.
15. The wider, generic societal benefits
and detriments are being considered separately through the Regulatory
Justification process. Generic and site specific aspects of the
candidate designs are being or will be considered through the
generic design assessment and site licensing processes respectively.
16. It is important that a clear division
between the regimes for planning and regulation of the nuclear
industry is maintained. We would also emphasise that the IPC should
not review or revisit any regulatory decision that has already
been made in relation to the proposed development and that it
need not consider matters which are within the remit of the nuclear
regulators.
SUITABILITY OF
SITES
17. We consider the Government's preliminary
conclusion on the suitability of Oldbury and the Wylfa sites as
outlined in the draft Nuclear NPS to be valid. The overall findings
from the AoS and HRA reports for the draft Nuclear NPS are also
considered to be appropriate both for the document as a whole
and with respect to the site specific AoS and HRA assessments
of Oldbury and Wylfa. Furthermore, we feel the potential positive
and negative impacts of developing at Oldbury and Wylfa have been
set out in clear terms in EN-6 and its accompanying documentation,
along with the potential for dealing with those impacts appropriately.
18. We have no specific site-related comments
with regards to the suitability of the other potential sites included
in the draft Nuclear NPS. However, we do welcome the preliminary
conclusion that a number of sites may be potentially suitable
for the development of new nuclear power stations. As the Government
recognises in the draft NPS, it is by no means certain that every
candidate site would eventually achieve development consent. We
therefore agree that it is appropriate that sufficient sites are
included in the designated Nuclear NPS to enable new nuclear to
fulfil its potential role as a major contributor to carbon emissions
abatement and to the security of electricity supplies.
19. We have no specific comments to offer
on the Government's considerations of alternative sites. We do
however have confidence that the NPS process to date, including
the SSA process and rigorous sustainability and habitats regulations
assessments, has led to the identification of a list of suitable
potential sites deployable by 2025. As noted earlier, and building
on the need case set out in EN-1, EN-6 is also further underpinned
by Annex A which sets out the Imperative Reasons of Overriding
Public Interest (IROPI) for concluding that the sites identified
as potentially suitable should be available for development according
to IROPI.
CLIMATE CHANGE
ADAPTATION
20. We recognise that climate change adaptation
will be a particular priority for consenting and developing new
nuclear infrastructure and welcome the Government's advice regarding
climate predictions and emission scenarios set out in the draft
Nuclear NPS. We also support the opportunity for developers to
provide evidence that further adaptation measures could be provided
should the need arise, rather than solely at the outset of development.
RADIOACTIVE WASTE
MANAGEMENT
21. We have carefully reviewed Annex G to
EN-6 on the "management and disposal of waste from new nuclear
power stations", and the associated paper on "The arrangements
for the management and disposal of waste from new nuclear power
stations: a summary of evidence" published by DECC in November
2009. We believe that these provide a thorough and detailed review
of available information on spent fuel, intermediate and low level
waste, non-radioactive hazardous waste and radioactive discharges.[87]
Waste and decommissioning issues associated with nuclear power
generation have been successfully resolved around the world using
well-established procedures and technologies.
ASSOCIATED INFRASTRUCTURE
22. We are particularly concerned that the
consideration of applications for critical infrastructure associated
with a new nuclear generating station should fall within the IPC's
remit and authority. The designated Nuclear NPS should make it
clear that the boundary of the nominated site is not definitive
and development of a generating station with some facilities connected
with the plant, associated development and ancillary development
(for example, cooling water works, marine offloading facility
and transport infrastructure) outside that boundary is supported
by government policy. Clearly, in the IPC process, the application
will need to be the subject of suitable detailed assessment, particularly
in respect of relevant Environmental Impact Assessment and Habitats
Regulations.
23. If new nuclear power stations are to
make a timely contribution to meeting demand it will be vital
that grid connections including new lines and any required transmission
infrastructure reinforcements are available on the same timescales.
It follows that applicants for new power stations and associated
transmission infrastructure should be encouraged by the IPC to
submit their applications to it on a timescale that is appropriate
to permit a new nuclear generating station to be deployed in accordance
with the timescales indicated by the Government.
CONCLUSION
24. HNP supports the designation of the
draft NPSs and believes this is an essential element in creating
certainty for investors, which will be fundamental for the delivery
of the Government's energy policy objectives. In the context of
these objectives and our own development sites, we welcome the
recognition that that there is a strategic need for new nuclear
capacity and that the Oldbury and Wylfa sites have been included
on the list of potentially suitable sites for new nuclear power
stations. We believe the criteria set out in the draft Overarching
(EN-1) and Nuclear (EN-6) NPSs are those that are appropriate
for applicants for new nuclear stations and the IPC to consider
in preparing and assessing planning applications respectively.
January 2010
87 They draw together information from the Nuclear
Decommissioning Authority (NDA), the UK nuclear regulators, nuclear
waste producers, prospective operators such as HNP and the Committee
on Radioactive Waste Management (CoRWM). International guidance
and experience from IAEA, NEA and the EU has been used to support
the arguments together with experience from Canada, USA, Sweden,
Finland, Switzerland, France and Germany. Back
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