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Memorandum submitted by the Communities against Nuclear Expansion (NPS 37)
We
represent a body of local people in the vicinity of Sizewell, Our aims and objectives can be found at www.suffolkcane.org.uk The organisation includes a number of
teachers, doctors, former civil servants, campaigners and former councillors
with experience of the impacts of two nuclear power stations and the plans for further
reactors at Sizewell. The organisation has substantial experience of planning
issues and social and health issues. Whilst CANE is opposed to further new
build at Sizewell it is also opposed to nuclear new build throughout the
Statement CANE understands that the National Policy Statements are to be the Planning policy guidance for the Energy Infrastructure for future years. The Infrastructure Planning Committee will be using these documents when they are finally published. In this context we believe there is a discrepancy between the policy EN6 and the policies EN2 and EN3. It appears that far less consideration has been given to sustainability and the environment in EN6 leaving the policy guidance extremely weak when any planning application is being determined by the IPC. With the consideration that many nominated sites are in areas of high ecological value, which would be disrupted for many decades and could be irreparably damaged. We would expect that the policy EN6 when adopted should protect the designated high value of the environment. As written the document does not give the IPC sufficient grounds to refuse, restrict or put conditions on any planning approval.
Further EN6 conflicts with Government Policy and Strategy at 2.1 in EN1. At bullet point 5 "To contribute to sustainable development by seeking energy infrastructure development that helps reduce climate change whilst also minimising negative impacts on the local environment''
Comments on the Overarching Policy EN1 EN6 and Justification
1) We believe the policy EN6 for Nuclear Power to be misguided and dangerously flawed. Any shortfall of energy supply could be made up by more local schemes and combined heat and power schemes and by a concentrated effort for a reduction of use, both by residential and business use, all of which would be far more cost effective and empower local communities to achieve the best solutions for their own environment.
2) We do not believe that the case has been made or proven for Nuclear Power, we would wish to see many more policies on reduction of energy use. Nuclear has a very poor history on cost and timescale and will serve as a distraction from achieving a sustainable, low cost, robust and resilient energy infrastructure in a reasonable time scale. 3). We firmly believe that Nuclear power should not be part of the mix because of:- a) Long term waste management, unresolved issues with legacy waste which are not fully and adequately addressed. In future, stations using the much hotter fuel to be used in the EPRs which will have to be stored on sites to cool down for up to 160 years. This does not appear to be addressed in the documents. b) Climate change risks from sea and fluvial flooding over the full lifetime including decommissioning. c) Security risks imposed by the close grouping of sites over many decades and the consequences for emergency planning, and the additional Policing needed for the security of both the plant and the storage of waste. The nominated sites predominantly include ones where there are existing nuclear facilities. We consider this is wrong. Historically Magnox power stations including Sizewell are remote sites miles from point of need. They were sited so as to minimise risk. If risk from these new reactors is considered to be significantly less, new sites should have been considered as being better suited to the available infrastructure. d) Unknown costs of all of the above to future generations. e) We do not believe that the health risks particularly from low level radiation are fully understood. In this context we reject entirely the "Justification under the Ionising regulations" for particularly the Areva EPR on the grounds that there is insufficient factual data on health and too many unknown costs. Much of the justification is not based on sound science.
Comments on the Site Nominations particularly Sizewell Description of Site. Reference 5.14 The statement is factually inaccurate and fails to mention the many environmental designated sites.
1. Even if we agree that nuclear is an option (Which as an organisation we do not) Sizewell should not be accepted as a nomination for the following reasons The Sizewell site at present comprises Sizewell A in decommission phase which may take up to 100years to complete Sizewell B PWR operational until 2035/45. Radio active waste storage until a deep geological repository is available. We submit
that this site situated as it is in the
It will
also mean an increase in the Grid Wires in the Thus despoiling both of the
2)Sizewell A site in 1958/9 was chosen for its remoteness and low population, recognising there were risks to the population, we are now told that the risk is much diminished, surely then it stands to reason that there are other less environmentally damaging sites nearer to the need for energy than that of the Sizewell site.
Mitigation Measures for the Sizewell Site Mitigation is mentioned for many of the identified environmental problems at this site. 1)Coastal Flooding and Sea defences. It is claimed that this can be managed by hard sea defences, it does not recognise the problems this may cause both north and south on the coast leading to problems for Dunwich, Thorpeness and Aldeburgh. The impact and visual intrusion on the Heritage coast will be intolerable. As will the disruption to the vegetative shingle on the shingle beach and dunes. 2) The Access Road of one and a half kilometres, a bridge and all the associated works will be situated across the AONB, and the road bridge will cross the SSSI, also the batching plant, machinery lay up area and car park will be sited somewhere along the access road. This would be the worst kind of environmental vandalism we could imagine. It will introduce noise, light, dust and petrochemicals into an unspoilt area of peace and tranquillity. We submit over the seven years of construction there are no measures that can mitigate the damage and despoliation this will cause.
This was recognised at the Layfield inquiry into Sizewell B *2 DoE Summary of Conclusions and Recommendations Sizewell B public enquiry. Chapter 108 General Conclusions Page 9 minute 108.38 It was also stated by Sir Frank Layfield in his conclusions to the Sizewell B Inquiry when giving his recommendation that Sizewell B be given permission, was as follows '' except that deemed planning permission should be refused for the proposed second access road'' Another fact is as follows *1 Local Community Liaison Committee 15 -04-1992 Page8 and 9 from minute 359 to minute 364. States when Nuclear Electric bought the area to the west of the existing stations local people were assured that the land would NOT be used for the building of Sizewell C but that it would be used as an environmental buffer to the existing stations.
We firmly believe by concentrating on mitigation measures EN6 totally flies in the face of true environmental sustainability, and is contrary to the European Habitats Directives.
Sizewell is the only nominated site in an AONB. Where we would have two further reactors of an entirely different design adding to the destruction of our Heritage coast and AONB. Major engineering and infrastructure improvements would be needed before construction could commence. A bridge and Road as suggested would effectively cut the AONB in half and would cross a SSSI which is .also adjacent to a Ramsar site and Special Area of Conservation and is in close proximity to the internationally renowned RSPB Minsmere. Visual intrusion of this magnitude is inconceivable, and there can be nothing which will mitigate this damage.
Deployability and Grid connections. Reference 5.14.5 Existing reactors are monitored 24/7 by the civil nuclear police now. Building two reactors over a number of years would we believe cause major security concerns to the security of operation of Sizewell B. We submit
the production of so much power at one site would risk massive disruption if
grid lines were targeted or suffered accidental damage. Roughly 5000 megawatts
of supply could be lost from the Sizewell grid alone. We submit the grid cannot
be monitored adequately or securely over its entire length. In addition there
is much controversy surrounding further power lines which will need to cross
another AONB in the
Flooding and flood risk D1 By allowing industry to nominate sites the risk from flooding due to sea level rise and coastal erosion is not entirely addressed and is not objective. PPS 25 which is supposed to address flood risk and particularly at the affect on neighbouring locations is ignored. The Environment Agency responsible for shoreline management have been left in the invidious position of trying to engineer defences and are left to make a number of assumptions. Mitigation measures are unlikely to be compatible with the AONB and Heritage coast status. Locally EA engineers do not believe hard
defences are sustainable. Professor Hugh Pethick, a British Energy consultant,
and acknowledged world expert on sea defences, said that "sea defence was a
natural process and best left without intervention". The
Cooling Water Reference. D10 Marine cooling for these new reactors requires huge volumes of sea water, grouping of a number of reactors will not only decimate fish stocks and all sea life but will increase sea temperatures. We understand this temperature rise causes loss of efficiency. If desalination plants for the pure water system are used, the chemicals will cause further damage to sea life and the vegetation on the coastal strip and further reduce plant efficiency. If town water is used each reactor will consume the equivalent of water for 5000 people, a not inconsiderable amount considering we will need to conserve water in future years. The policy does not acknowledge that substantial volumes of pure water are required, nor does it mention the environmental consequences of that need.
Economy Sizewell / Leiston Much emphasis is placed on the economy and jobs for the local area that will ensue from new nuclear build. The build programme for Sizewell C/D may last for 7/8 years. From the experience of the building of Sizewell B there was an itinerate workforce of 7000 at the peak of the build programme,( Leiston's voting population is around 4500 ) this led to many problems and conflicts. It did bring some temporary benefits but the down side has to be lived through to be understood. It has taken many years for Leiston to recover, taking an inordinate amount of time effort and money. This quiet area of East Suffolk is a haven for the Tourist industry, something which many people have been working toward, we are fearful that if Sizewell C/D goes ahead the economy that is generated for and by the tourist industry will be lost, many people come for the quiet county walks for birding and for the relaxed laid back area. This will change during the build programme and will take many years to recover if ever. There will certainly be a downturn in the tourist economy and this should be a material consideration within EN6
Summary
Making a policy to fit the sites rather than the sites fit the policy, is not helpful to any good planner Mitigation measures should not be considered when alternative sites may be far less damaging. Choosing Sites because they are easy to obtain not because they are the best sites does not make for a good sustainable planning outcome and allows maximum disturbance to the Area of Outstanding Natural Beauty and other areas of high landscape value. Causing the potential for massive Environmental damage. In our opinion in making the Nuclear policy fit nominated sites so many risks are introduced as to make the planning policy completely unsustainable. It is simply not acceptable that deployability is used as a reason to undermine environmental criteria. If it is to have any credibility on this policy Government must be prepared to site these reactors close to point of need and fulfil without question criteria such as flood risk well into the future. In this context it may be that sites are more suited to industrial areas. In any case the many issues surrounding waste and health would have to be satisfied first.
Conclusions
1) We reiterate our stance that the case for more Nuclear power stations has not been made. 2) That the situation for legacy waste which is not solved, is dire, and should be resolved before permission is given for new build which will create hotter R A waste leaving a deplorable problem for future generations. 3) Environmental damage that can not be erased leaving the environment in a worse state for the future is totally immoral for the well being of the natural world 4) That we
should be ensuring the state of the planet is better when we leave it than it
was when we found it, by using good stewardship as signed up to at the 5) We firmly believe the Governments aim of reducing CO2 emissions can be achieved without Nuclear Power
But in the event that Government continues to go ahead with its proposed policy we believe the AONB Designation and policy should protect Sizewell from further development. We submit that whilst the Government may have established a need for new nuclear stations, believing there is a national need, it has also accepted 9 other nominated sites. Sequential testing tells us that with its AONB designation Sizewell should be considered last not first or second in the round of new build.
January 2010
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