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Memorandum submitted by Hastings Borough Council (NPS 55)
CONSULTATION RESPONSE TO DRAFT NPS EN-1 and EN-6 ON NUCLEAR ENERGY WITH PARTICULAR REFERENCE TO THE EXCLUSION OF DUNGENESS
Introduction
1. The nominated site at Dungeness has been excluded from the draft Nuclear NPS on the basis that it did not meet discretionary criterion D6. It was concluded that given the nature of the habitat and potential difficulties in mitigating the impacts on the shingle system, the building of a new nuclear power station would cause an adverse effect on the integrity of the Special Area of Conservation that might not be avoided or mitigated. There were also concerns under criterion D2, but it was concluded that that Dungeness should not be ruled out against this criterion at this stage. 2. The Government has specifically invited views as part of its consultation on its preliminary conclusion about the suitability of Dungeness.
Executive summary 1. Dungeness Power Station currently employs over 1,000 people. It is a major local employer and has significant benefits for the local economy. It is considered that future socio-economic benefits, within the travel-to-work area (approx 25-30 miles) which includes Shepway, Rother and Hastings districts, have not been given sufficient weight in the decision making process to exclude Dungeness. 2. Hastings Borough Council believes that there is no evidence at this stage to conclude that a combination of avoidance, mitigating and compensating measures will not counter the adverse environmental impact on the internationally designated ecologically important site. 3. Hastings Borough Council therefore believes that the Government's preliminary conclusion about Dungeness is premature, and urges that this site be included in the final Nuclear NPS. Continued exclusion of Dungeness would preclude full public consultation and a comprehensive consideration of the merits and disadvantages of this site, which we believe is of national strategic importance in terms of reducing the gap between energy supply and demand and reducing carbon emissions well before 2025. 4. Comments
1. There are several imperative reasons of overriding public interest which argue for the inclusion of Dungeness on the list of sites within the Nuclear NPS. 2. The construction of a facility at Dungeness can be carried out relatively quickly and the site will have a nuclear grid connection available from 2016, enabling rapid connection of the new facility. Early deployment of nuclear power stations is in the public interest because it will maximise carbon emission savings. 3. The siting of a new nuclear facility at Dungeness will offset the negative impact that the decommissioning of Dungeness A and B has on the production of non-carbon based energy in the southeast, and will help reduce the rapidly growing gap between electricity production (supply) and demand in this region. 4. The Dungeness site can make a meaningful contribution to the UK's non-renewable capacity well before 2025. It cannot be assumed that development of the other sites would be sufficient to meet the national target in this respect. 5. It is premature to conclude that the direct loss of vegetated shingle habitat from the Special Area of Conservation cannot be adequately compensated for. There is no compelling evidence that a combination of measures including avoidance, mitigation and compensation is not viable. 6. In the absence of more detailed consideration of the environmental issues, it can be argued that the biodiversity action plans and other mitigation measures that would accompany the development and operation of a new nuclear facility could help to further protect the internationally designated ecology site at Dungeness from coastal erosion. 7. Section 4.1.1.iii of the Draft Overarching National Policy Statement for Energy (EN-1) states that when examining and determining applications for energy infrastructure that the Infrastructure Planning Commission (IPC) should take into account adverse environmental, social and economic impacts. This principle in relation to socio-economic impacts was not applied in the Strategic Siting Assessment process, and therefore, the exclusion of Dungeness on the basis of nature conservation is intrinsically flawed and precludes a balanced assessment of whether identified adverse impacts outweigh the benefits, taking into account measures to avoid, reduce or compensate for adverse impacts. 8. There are compelling arguments for the inclusion of Dungeness on socio-economic and regenerative grounds, and these should be given more weight. 9. The presence of a nuclear power station at Dungeness is a major driver for growth and prosperity, providing significant employment for local people in an area where there is significant deprivation. Shepway is the fifth most deprived area of those sites nominated (123rd on the IMD rankings) and is thus significantly more economically dependent on Dungeness than other included nominated sites are on nuclear facilities in their areas. 10. Nearby Hastings (pop 85,000) is a source of employees for Dungeness. Hastings is in the most deprived 10% of local authority areas nationally (IMD 2007), with some wards in the most deprived 2%. It is the most deprived town in the South-East and is the country's second most deprived coastal resort town after Blackpool. Unemployment at 6.2% is well above the national average of 4.1%, and Hastings is an unemployment "hotspot" according to the DWP's official definition. 11. The construction of Dungeness A and B provided employment to a large number of local people in the surrounding area including Hastings, primarily in construction and technical trades. It is anticipated that the building and operation of a new site at Dungeness would create hundreds of new local employment opportunities and significantly contribute to the economic profile of the area, and bring renewed economic uplift. 12. Dungeness A and B currently employ over 1,000 people. Some Dungeness employees reside within Hastings, and a larger number live within the "travel to spend" area. Thus, Dungeness is an important contributor to the Hastings' economy. Furthermore, the site attracts professional working age incomers, thereby improving the overall economic profile of the area. The Dungeness wage bill contributes in excess of £30 million annually to the local economy. It is likely that a new facility at Dungeness would increase this by an order of magnitude, providing long-term wealth generation in an area with no alternative major employment locations of a similar scale. 13. The siting of a new nuclear facility at Dungeness will help offset the negative impact that the decommissioning of Dungeness A and B will have on the production of non-carbon based energy in the southeast, and will help reduce the rapidly growing gap between electricity production (supply) and demand in this region. 14. Sussex Coast College Hastings is now an approved "PAA/VQ/SET" centre for the delivery of Awareness of Nuclear Engineering, Radiation Protection and NVQs 2 and 3 in Nuclear Decommissioning. Working in partnership with the University of Brighton, the College will be offering a new Foundation Degree in Nuclear Engineering. Both Sussex Coast College Hastings and University Centre Hastings are optimistic that they would build from this strong base to provide skills and qualifications to enable Hastings residents to take up opportunities in the construction and operational phases of a new nuclear facility at Dungeness. 15. Two key features of the Hastings economy are the low skills and educational base and the number of small, low value employers supplying a local market. The contribution that a nuclear facility at Dungeness makes to providing stable, higher quality employment is a significant factor in the regeneration of the area. 16. Hastings Borough Council strongly objects to exclusion of Dungeness and urges that it be included in the final Nuclear NPS to enable fuller consideration and public consultation on a site which is of national, regional and local strategic importance. January 2010 |