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Memorandum submitted by Bradwell for Renewable Energy (NPS 56)
We are a grass-roots group, comprised of people in Essex, which has been in existence in various forms since 1987. Our concerns are of nuclear power generation at Bradwell, in the fragile environment of the Dengie Peninsula and our support of renewable energy projects in our county.
Public consultation usually means that individual voices are ironed out in the outcomes. We therefore use verbatim quotes from the DECC consultation meetings in Mersea and Maldon, to show the Honourable Members how strongly locals feel, and indeed, how well informed they are. The links to these quotes can be found at: http://data.energynpsconsultation.decc.gov.uk/documents/transcription_bradwell.pdf (i) for Mersea http://data.energynpsconsultation.decc.gov.uk/documents/transcription_bradwell2.pdf (ii) for Maldon
The Consultation process involving the National Policy Statements
We have serious concerns over the nature and procedures over the public consultation:
1. Organisation of the events:
Neil Mortimer: Are you going to make certain that every household knows that they can reply to the consultation that is going on? Most people here found out about the meeting accidentally, and the timing is most inconsiderate for a lot of people who are going to work...I am bunking off work to be here. There are a vast number of people at work now who would like to be here listening and making comment." (i) page 17
Barry Turner: We had a meeting in Mersea a few days ago and a poll of the 40-50 people who attended showed that only three or four had been informed of this by one of the 11.000 leaflets you claim to have circulated....there were a few who had seen a single advert in the local free paper which was put in on the initiative of the publisher himself...(ii) page 8
We ask why there were no meetings planned for Colchester, which is nearer than Maldon, especially given that the Colchester Borough Council Strategic Overview and Scrutiny Panel arranged an excellent meeting at Mersea with a variety of speakers of different persuasions, encouraging public follow-up at their subsequent meetings. Their work gained much trust and public support.
2. What is the value of the public contribution?
Adam Dawson (DECC) "I want to re-emphasize that your views are important". (ii) VI page 4
There is no explanation of why the public's views are important, how they will be factored in to any decision-making process. There is a suspicion that the consultation exists as a box-ticking exercise:
Judy Ratcliffe: I do worry that the exercise is illusory. It is the first time I have been moved to comment at all but when I saw the exhibition yesterday I was even more worried not less. It kept coming back to phrases like "imperative reason of overriding public interest" but we are the public." (ii) page 9
These Draft National Policy Statements and the creation of the Infrastructure Planning Commission represent the most radical shake-up in planning for many years. For the public, the draconian overriding of public interest in favour of the national good should mean a much more structured and detailed consultation process, as after a decision is made there will be no redress, no public inquiry. The nearest example to that desired state of affairs would be CoRWM 1's consultation process. There should be a detailed audit trail of issues raised, and how they are dealt with, with a clear explanation of how far the public's views have been taken into account. There should be pro-active attempts to involve local interest groups. It is essential to engender public trust and understanding of the difficulties involved, whether or not in the final analysis they agree with the results.
For those preparing for the consultation, this has been a most unwieldy process, suitable for civil servants, but not user-friendly for the public. For example, it would have been useful to have a collation of all material relating to each chosen nuclear site, rather than ferreting around tightly bound copies. The lone individual has no hope.
As for the overall nature and content of the consultation meetings, Barrie Jones concludes his views: I know you mean well, but I am sorry I do not believe what you are saying and I find it difficult to see how you can really believe it yourself... (ii) page 32 From someone who has argued respectfully and cogently (see his previous statement), this is indeed a damning indictment of the consultation process and bodes ill for any public recognition of legitimacy in the democratic process.
3. Gaps in the Consultation Process
Elizabeth Doyle ...while I appreciate consultation I do not feel this is informed consultation because, flicking through your literature today, any negative point or assessment, is met for potential for mitigation... (i) page 29 This is a common criticism of many consultations, that the consulter is in a defensive mode, and is seeking to persuade the consultee that all will be well, come what may. This is hardly an honest approach. For example: Adam Dawson: we have been managing radioactive waste for 50 years in this country". Those of us who have taken part in the CoRWM stakeholder engagement process know that it is only now that a management strategy is being developed, and that some storage methods existing from the past leave a lot to be desired in terms of present day safety standards.
(a) New build waste
Missing documents: Valerie: An important document is missing: The arrangements for the management and disposal of waste from New Nuclear Power Stations: a Summary of Evidence is missing.(i) page 30
It is of great concern that the public is not to be consulted on the high burn up fuel remaining from the generation of these new reactors, necessitating being stored on site for up to 160 years, as, unlike the Magnox fuel, it is too hot to be taken to Sellafield in the previous fashion. The omission gives an incomplete view of any possible detriment to the environment, such as climate change, coastal erosion and geomorphologic influences.
BRARE recently signed a joint letter from campaigning groups to Professor Robert Pickard, Chairman of CoRWM 2, to remind him that, early in 2008 he said: "The recommendations of CoRWM were accepted for legacy waste and active nuclear facilities, but the Committee recommendation was for this waste only. For waste from new nuclear builds, a new safety case and a new evaluation has to take place." (New Civil Engineer)
We are concerned that, according to the NNPS the Government is satisfied that effective arrangements will exist. "As a result the IPC need not consider this question" (3.8.20). To bolster this argument DECC argues "waste from new nuclear power stations would not require a technically different solution. " (i) page 21 The Nuclear Decommissioning Authority has been working on assessments of this new fuel, and has asked the Environment Agency to report. This report is not due until the Spring. Therefore we the public are not party to the information for this consultation.
(b) Radiation and health
This is of great concern to those living around the Blackwater Estuary. It is therefore alarming that no account can be taken of COMARE's commentary on the KiKK study on childhood leukaemias near German nuclear power plants, as it will only be published after the Justification consultation has ended. Justification is the key to whether any of these reactors will get the go-ahead. Stephen King: Environmental Health practitioner: "In my opinion, as a public health practitioner, it is highly likely that bringing up children near a nuclear power plant involves exposing them to an elevated risk of childhood cancer. I would like to know what the Government and nuclear industry can tell local residents to clearly show that nuclear power plants will not adversely affect the health of their children." (i) page 23
Evidence of bias
The overall format of the consultation documents, with nearly 2.000 pages on nuclear, suggests a nuclear hard sell.
The public consultations are taking place mainly around the proposed nuclear sites.
Energy efficiency and conservation measures are not the hot topic of the energy generators. Yet an overall energy infrastructure plan needs to include this. Why has the Government's Low Carbon Transition Plan not been included in the consultation? Otherwise how can consultees judge whether DECC's portfolio is balanced ("we want a balanced portfolio". (ii) points 6 & 8)
"climate needs nuclear" DECC (i) page 10. The NNPS states that the site has been chosen because of the rush to secure energy supply, and to mitigate climate change (5.6.3) Nuclear will achieve only 4% of carbon reduction needed. What about the 96%? Energy efficiency is up to 7X more cost effective. Money spent on nuclear means less effect on climate change reduction. (Amory Lovins. More profit with less carbon, Scientific American Sept 2005 http://sciam.com/media/pdf/Lovinsforweb.pdf
Why has the low Carbon Programme and ENTEC not been integrated into the consultation and into the assessment for national structures? One answer lies in the NNPS 2.5.1: "...nuclear power should be free to contribute as much as possible towards meeting the need for 25GW of new non-renewable capacity". Does it really matter how this capacity is filled? How about leaving it to the market? This matters greatly to the concerned public around the proposed nuclear sites, vulnerable as they are to a decision that could be made of overriding public interest.
4. Characteristics of the Bradwell site, the Blackwater estuary and the Dengie Peninsula
(a) Flooding and erosion
Bradwell is a preferred site even though it is in flood risk zone 3 (NPS 4.22). At 4.20 the NPS states that: "coastal change is a key consideration alongside other specifics related to coastal environments". At 4.27 the Environment Agency comments that the existing flood defences leave much to be desired in parts. At 4.31"... nominated site could potentially be protected against flood risks through its lifetime". D2 states that the EA believes coastal processes are possible to mitigate. D10 talks of the flood zone defences and possible effects on erosion and on the visual landscape. D6 describes the area as an internationally designated site of ecological importance, with potential for adverse effects from construction. At 5.6.9 advocates that more detailed work needs to be carried out. Mention is made of possible detriment to fish stocks. In spite of this, at 5.6.52: Reason of Overriding public interest will be used to override concerns about the Habitats Regulations Assessments...This site therefore passes this criterion.
Barry Turner: predictions of sea level rise are increasing. How can we assume that the Bradwell site is safe for 160 years?" "...we are talking about absolutely ridiculous assumption...nonsense" . (i) page 23 Frank Izzert: you talk about a fund being set up by the developer to pay for the whole lifetime of this nuclear power plant, but are you going to ask the developer to pay for the protection of the communities around the River Blackwater? (ii) page 13
Noelle: I do not know whether you have actually walked along this coast and had a look across there. The other end of the island loses a metre a year. Over 160 years that is 160 metres. There is no Dengie Peninsula in 160 years so I do not know how on earth you can decide how much that is going to cost.". (i)m page 26
Extract from Parliamentary Question from Rt Hon Bernard Jenkin, MP {305573}
What representations he has received from English Nature on the environmental effects of proposals for a new nuclear power station at Bradwell, Essex. [305573] Huw Irranca-Davies The Government requested and received comments from Natural England-formerly English Nature-on the appraisal of sustainability and habitats regulations assessment reports on the site at Bradwell, which was nominated in the Government's strategic siting assessment process. Mr. Jenkin I thank the Minister for his response but, even though I am an enthusiast for new nuclear power stations, may I draw his attention to the serious concern expressed to me, particularly by local fishermen and oystermen, that the volume of the outfall from a new power station is likely to be four times greater than that from the previous power station, thus causing serious continuing damage to the ecology of the Blackwater estuary? Can he assure me that that will be addressed, perhaps by ensuring that the intake and outfalls will be sufficiently far away?
(b) Fish stocks
Varrie Blowers: We thought we would like to give you a surprise. We here have some world-famous native Colchester oysters for you to try...I do not know if you realise this, but if a new station is built at Bradwell, it will have a devastating effect on the marine ecology on the Blackwater Estuary and on the oyster industry and on the livelihoods of oystermen and fishermen." {the oysters were graciously declined} (i) page 2
In response to the potential dangers of cooling water plumes on fish stocks, DECC notes: "since no discussions have been made on the technology that would be used, it has not been possible to give a definitive assessment at this stage". (i) page 16
This uncertain state of affairs does not suit Bernard Jenkin: " MP fears nuclear plan fish threat" http://www.essexcountystandard.co.uk/news/localnews/4355142.MP_fears_nuclear_plant_fish_threat/
(c) Emergency Planning and Evacuation of Mersea Island
John Bouckley: I am a councillor on Colchester Borough Council and after the meeting here earlier in the year the Borough set up a task and finish group to study this whole topic because there were so many adverse comments at the first meeting. All sorts of things have come out, and I sympathise with many of the questioners here today. For example we found that Mersea was not included in any emergency evacuation. We were astonished. We were told to tell the police: 'they will probably tell you to stay indoors'",
Over the years there has been constant concern over evacuation when there is just one road out, and when the island is flooded at high tide. Mersea has a unique geographical characteristic that does not seem to fall within the remit of the regulatory authorities.
(d) The contribution of a new nuclear power station to the local "public good"
In its guidance to the IPC the Government states: "multiple safety features within modern nuclear power stations make an untoward event "exceedingly unlikely". Recently the Health & Safety Executive has criticised the two proposed designs. This reflects difficulties in the problematic construction of one such reactor in Finland. Almost in the same breath, at section 108 it states: "Overall the likely enhancement in employment, community wealth, housing stock and other associated neighbourhood infrastructure should improve community well being and health generally".
Ian Clarke: ...you talk in terms of community well being, that a new power station will enhance employment and wealth, will improve the local housing stock and infrastructure. These are the most incredible claims; it is a total nonsense to say that, when there is also to be taken into account the detriments that this will cause in terms of anxiety, potentially in health, in blight and on the local economy, as you have heard. No assessment has been made of this. The NPS is a charade. It is vague, it is tendentious, and it is open to question. Actually there are so many holes in it that we should be able to make fun of it, but it will make no difference, because my experience is that you will just carry on ramming it down people's throats." (i) pages 20-21
Conclusion
Ian Clarke's comments above encapsulate many of the concerns of the ordinary people living in this area. It is difficult to see, with the detailed recommendations that the Government has imposed on the IPC, how independent this body will be. Furthermore, we understand that the final decision rests not with an independent body, but with the Secretary of State himself. This is not a good state of affairs. We have just learned that a decision on the Energy Strategy will be made before the General Election, which confirms our view that this consultation is a biased and politicised exercise. The reputation of Parliament has had a knocking recently. The most important change in Infrastructure Planning in decades is being rushed through, compromised by ineptitude and political expediency. We are relieved that an Early Day Motion expressing concern at this turn of events has been announced.
We are grateful the Energy and Climate Change Select Committee is interested in our views. You are our main hope. Whatever the outcome, due process must be seen to have been followed, so that any conclusion can be seen to have been fairly and justly arrived at.
January 2010
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