Memorandum submitted by Varrie Blowers
BRADWELL (NPS 45)
A1 It is most unfortunate that by responding to the various stages of a Government-set consultation process on the proposal to build a new nuclear complex at Bradwell, participants appear to legitimise that process. The only hope for any redress for this situation is for respondents to describe the actual experience on the ground of each stage of the consultation process. This will establish the inadequacy of the process on which the National Policy Statements are based.
A2 The consultation process has been flawed at
every stage. Most importantly, there has
been no emphasis on the aspect of the proposal that represents a major
departure from past practice: the
storage of highly radioactive spent fuel and intermediate wastes on site at
Bradwell for around 160 years. The
proposal to build a new station and the proposal to store spent fuel have been
conflated and I am afraid this looks like an attempt to deceive the
public. As it is intended that spent
fuel would be stored over the long-term at Bradwell, the public needs to be
properly informed and consulted on this proposal in a process separate to that
for a new nuclear power station. It is
quite disgraceful that when the issue of spent fuel storage was discussed at
meetings, it was well-informed members of the public who raised it, not the
A3 There has further been no emphasis on the other ways in which a new nuclear power station would differ to its predecessor:
· the much higher burn-up of fuel in a new power station resulting in a period of 100 years in which to cool down; and as a result of this,
· the requirement for more than three times the amount of cooling water to be taken from the shallow and vulnerable Blackwater estuary, which would have a very damaging impact on the oyster and fishing industries, the environment and ecology of the estuary and its marine life.
A4 The consultation process as perceived
at the grassroots-level has occurred in six stages to date:
A5 I would contend that at each stage proper consultation has not occurred and that affected local communities - the focus of the consultations - have not been properly engaged. This has been an exercise in 'consultation done' box-ticking for Government.
1.2 The requirement to pre-register to attend these events seems also have deterred some people, who were concerned about how their details would be used and that they would be photographed attending.
Towns in the area with large populations - Colchester,
At the meetings at Tollesbury and
It was apparent from the meetings that those attending did not trust the
nuclear industry. Local communities had
been promised that the old nuclear power station would be decommissioned and
the site returned to
1.6 At the Tollesbury meeting, it was pointed out that little or no mention was being made of the proposed storage of highly radioactive nuclear waste at Bradwell. The BE representative countered by saying that 'spent fuel' storage was referred to in BE's literature. The point was made by a member of the audience that most lay members of the public did not know what spent fuel was and that the industry was cynically taking advantage of this ignorance instead of raising public awareness and consulting on this vital issue separately.
2. Draft Strategic Siting Assessment (SSA) Criteria
2.1 The Blackwater Against New Nuclear Group (BANNG) made a substantial and well-informed response to the SSA consultation. The response drew attention to many problems with the criteria, particularly demographics, flooding and coastal processes. Unfortunately, it seems that scant attention has been paid to some of the criticisms and others have simply been ignored. Responses from the Government have been general rather than specific and there has been virtually no change made to the criteria.
3.1 The Blackwater Against New Nuclear Group (BANNG) made a substantial and well-informed response to the Justification consultation and, along with several other groups, called for a Public Inquiry into whether new nuclear practices in the form of new power stations could be justified. Unfortunately, it seems that scant attention has been paid to the responses by the Government and the requests for a Public Inquiry have simply been ignored.
4. 'Have Your Say'
4.1 The 'Have Your Say' consultation on the nominated sites appears to have been an 'extra' stage added in to the Government's consultation process. The consultation period was short, one month.
4.2 The Blackwater Against New Nuclear Group (BANNG) made a substantial and well-informed response to the 'Have Your Say' consultation, taking the opportunity to remind government of the group's responses to the SSA and Justification consultations. Again, it seems that scant attention was paid to this.
4.3 Individual members of the public found it extremely difficult to take part in the 'Have Your Say' consultation. The Dept. of Energy and Climate Change provided a template of questions to be answered on different aspects of the criteria and which required some very detailed knowledge. This restricted and attempted to channel public comment. It may be that this deterred responses. It is to the credit of those members of the public who took part that they did so regardless of the many obstacles that needed to be overcome.
5. Department of Energy and Climate Change (DECC) - Exhibition and Public Meetings
5.1 The DECC
Exhibition was obviously regarded by the Government as an opportunity for local communities to see the proposals for
the Bradwell site; the public meetings as an opportunity for local communities
to make known their feelings on the
proposalsto DECC. 'Your views make a
difference' and 'The Government wants to hear your views' declared each of the
11,000 leaflets that DECC hoped had been distributed (in some places
door-to-door) around the Blackwater estuary.
DECC acknowledges that this did not happen as planned. The resulting lack of advertisement of the
events was reflected in the numbers attending the exhibition and public
meetings. Again, as with the
5.2 In an
article in the
5.3 Neither the
Public Meeting at
5.4 Despite the inconvenient timing of the public meeting, in the middle of a working day, there was a turnout of around 60 Mersea Islanders keen to press home their objections to the proposed new power station. In a series of hard-hitting and well-informed contributions from the floor, the inadequacies of the Government's draft National Policy Statement on Nuclear Energy in relation to Bradwell were vigorously exposed. Among the points made by those attending, were that a massive nuclear power station, and possibly up to three, would create a major industrial complex that would totally transform the landscape, ecology, economy and amenity of the Blackwater estuary. More than that, such a project imposed high risks and potential dangers threatening the security and safety of many thousands of people within a short distance of the power station. In the event of a major incident, it was doubted that emergency planning procedures would be able to cope with evacuation of the population.
5.5 The shallow Blackwater estuary could hardly cope with providing cooling water for one of these giants, let alone two or three, for which cooling towers would be necessary. The threat to fishing, oysters, the tourist trade and, indeed, the well-being of the Blackwater community would persist over many generations.
5.6 Members of the audience took exception to the lack of emphasis on the proposed storage of highly radioactive waste on this most vulnerable site and the idea of it being safely managed 160 years hence was frankly incredible.
5.7 The format of the meeting, whereby members of the public asked questions from the floor which were answered by Department of Energy and Climate Change officials from the platform, allowing little questioning of responses, was not regarded as a satisfactory way of engaging the public.
Public Meeting at Maldon on 12 December, 2009:
5.8 Similar questions were raised at the Maldon meeting. It was pointed out by several attending that without the information provided by members of BANNG outside the exhibtion at Maldon on 11 December, they would not have known about the public meeting.
(The Committee would find it informative to read the transcripts of both public meetings.)
Choice of venues for Exhibition and public meetings:
It is doubtful that
5.10 The Exhibition and public meetings
were not taken to places where large populations have a legitimate interest in
the building of a major nuclear complex nearby.
Colchester is more or less on the doorstep and
6. Draft National Policy Statements
6.1 The Blackwater Against New Nuclear Group (BANNG) will be submitting a substantial and, once again, well-informed response to the consultation on the Draft NPSs.
6.2 Many individuals are also proposing to respond to the consultation.
6.3 From a cursory look at the NPS EN-6, it is clear that the Government is framing the consultation by asserting that nuclear power is necessary and that ten existing sites are the best locations for new nuclear power stations.
Consultation Period (9 November, 2009 - 22 February, 2010):
6.4 Bearing in mind that the Government assures the public that 'Your views make a difference' and 'The Government wants to hear your views', the consultation period, with the Christmas season intervening, is extremely short.
6.5 The shortness of the consultation period is exacerbated by the vast amount of material to be trawled through - by ordinary members of the public. It is to be hoped that the people whose views matter to the Government so much will not be deterred.
Evidence to the House of Commons Committee on Energy and Climate Change on the Draft National Policy Statements:
6.6 It is not helpful for those wishing to submit evidence to the Committee that this is required by 15 January - over one month before the Government's deadline.
7. Blackwater Against New Nuclear Group (BANNG): raising public awareness and consultation via Petition
BANNG's Main Aims:
7.1 BANNG is a
citizens-based organization, founded in
1. to raise public awareness among the Blackwater communities of the potential consequences for health, environment and safety of proposals for new nuclear development;
2. to identify key issues of concern and to gather credible and responsible research and information to pursue the case against nuclear development;
3. to challenge any proposals for future nuclear power at the Bradwell site by presenting robust evidence and arguments to local and national decision makers, regulatory bodies, the nuclear industry, non government organisations, the media and the general public;
4. to support the early and successful decommissioning and clean up of the existing Bradwell nuclear site as an integral element of the long-term protection and conservation of the Blackwater estuary;
5. to call for an open, transparent and deliberative decision making process in which local communities are afforded full access to all information and involvement in key decisions affecting them.
7.2 The Chair of BANNG, Professor Andrew Blowers, OBE, is an expert on the social and ethical issues of radioactive waste management. He is a former member of two Government committees: Radioactive Waste Management Committee (RWMAC) and the first Committee on Radioactive Waste Management (CoRWM). He was also the Government appointed non-executive Director of Nirex.
7.3 BANNG relies on volunteer supporters to help it to carry out its aims. It is not a government department with a large staff, such as DECC. It does not have the huge financial resources of the nuclear industry, nor its privileged access to the 'ear' of government.
7.4 And yet BANNG, since its inception in April, 2008, has done more than government, local authorities (excepting Colchester Borough Council and now West Mersea Town Council), Members of Parliament and the nuclear industry to make people aware of what is proposed for the Bradwell site - including the storage of highly radioactive spent fuel until the end of the 22nd century - and to respond to each stage of the Government's consultation process. It is thanks to the hard work of BANNG that there were so many well-informed contributions made at the DECC public meetings in West Mersea and Maldon (see item 4 above).
7.5 BANNG is currently collecting signatures for its Petition. The Petition statement is as follows:
To the Secretary of State for Energy and Climate Change,
We, the undersigned, wish to express our strong opposition to the construction of a new nuclear power station at Bradwell and the storage of highly radioactive waste on site.
We, therefore, demand that the Government reject this proposal.
we demand that the site of the former Bradwell power station be returned to
7.6 BANNG supporters have been collecting
signatures door-to-door on
7.7 While claims are made by the Government that local communities welcome the prospect of a new nuclear power station at Bradwell, the experience of signature collectors is somewhat different. The BANNG Petition represents the only opportunity for people living around the Blackwater and other stakeholders, such as the many caravan owners, beach hut owners and holidaymakers, to be asked face-to-face for their views. BANNG petitioners have found that the overwhelming majority of the thousands of people they have approached is against a new power station at Bradwell.
7.8 The BANNG petitioners have been astounded at the number of people around the Blackwater who were unaware of the proposals to build a new nuclear power station at Bradwell until asked if they would sign the Petition. This was particularly marked in Maldon, where the District Council will have a significant say on any Planning Application.
7.9 The BANNG petitioners have been further astounded at the number of people - from those at the highest level of national and local representation to workers in the nuclear industry - who were not aware of the proposal to store highly radioactive spent fuel at the Bradwell site until the end of the 22nd century.
7.10 It has been left to a small group of unpaid volunteers to explain the Government's proposals to local communities. That must speak volumes for the adequacy and efficacy of the Government's consultation process on Bradwell as a suitable site.
8.1 The Government might be said to be
conducting a 'hit and miss' consultation on its proposals for a major nuclear
complex at Bradwell. It has failed (as
8.2 With respect to the lack of emphasis on the
proposal to store highly radioactive spent fuel on the Bradwell site until almost
the end of the 22nd century, it seems that
8.3 It is difficult to imagine how members of the public - whose views the Government declares it wants to hear - will be able to cope with the consultation on the National Policy Statements, particularly within the time constraints imposed.
8.4 From grassroots-level, it appears that the Government has failed to engage properly with the public on its proposals not only to build a new nuclear power station but also a highly radioactive spent fuel store at Bradwell and the consultation process has been merely a box ticking exercise.
9. POSTSCRIPT - A LEVEL PLAYING FIELD
Funding for Colchester Borough Council Investigations:
9.1 Colchester Borough Council has been made aware of and takes very seriously the concerns of many of its residents about the proposals for Bradwell. The Council would like to be able to carry out investigations into some of the issues raised but lacks the funding to do so.
9.2 In order to allow the Council to carry out its duties to its residents in relation to issues for which a Council would not normally make budgetary provision, perhaps the Government or the nuclear industry would provide the funding for independent research to be undertaken. This would demonstrate that both are indeed keen on proper consultation. A Borough Councillor suggested this at the DECC public meeting at West Mersea on 10 December but received no reply.
Funding for Local Groups:
9.3 It would help if some funding were provided for local groups to carry out their work more effectively, in order to engender a more balanced and genuinely participative debate.
 Although this is a Personal Submission, I am the Secretary of the Blackwater Against New Nuclear Group (BANNG) and have also contributed to the group's submission to the Committee.