Memorandum submitted by Varrie Blowers[1]



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 representatives of British Energy or the Department for Energy and Climate Change.


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: British Energy Roadshow; Draft Strategic Siting Assessment; Justification; 'Have Your Say'; DECC exhibition (West Mersea, Maldon, Bradwell) and public meetings (West Mersea and Maldon); Draft National Policy Statements.


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. British Energy (BE) Roadshow


1.1 British Energy was surprised at the small numbers attending some of these events during November, 2008 and there was a tendency for it to conclude that the majority of people were quite happy with the proposals. It should have been obvious to BE that it is very difficult for many people to attend meetings held on weekday afternoons.


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.


1.3 Towns in the area with large populations - Colchester, Chelmsford, Southend and Clacton - were not included as venues although they have a legitimate interest in what happens at Bradwell. Nor was Brightlingsea directly downwind of Bradwell.


1.4 At the meetings at Tollesbury and West Mersea, the audiences expressed a great deal both of hostility to the idea of a new power station and of scepticism at British Energy's claim that the chances of an accident were 'vanishingly small'. As members of an island community two miles over the Blackwater estuary from Bradwell, the audience at the West Mersea meeting was particularly hostile and felt that its concerns fell on deaf ears. These concerns included: the storage of highly radioactive spent fuel well into the next century on such a low-lying site liable to flooding and storm surges in the next 50 years; the virtual impossibility of evacuating Mersea Island in the event of an accident; the deleterious effects on the Colchester Native Oyster industry and the marine ecology of the estuary.


1.5 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 greenfield within 25 years. As a result of a lack of funding, that time has been revised to 100 years.


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. Justification


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 British Energy Roadshow, the times of the events that took place on Thursday, 10 and Friday, 11 December at West Mersea and Maldon respectively were not convenient for working people. Again, the requirement to pre-register was offputting.


5.2 In an article in the Mersea Island Courier (4 December, 2009), the Blackwater Against New Nuclear Group (BANNG) informed readers of the Exhibition and public meetings. The Editor of the Courier took it upon himself to find a DECC leaflet and publish it. While collecting signatures for the BANNG Petition outside the Exhibition in Maldon on 11 December, I discovered that almost everyone to whom I spoke knew nothing about this or the public meeting to be held on 12 December in Maldon. In the interests of openness and democracy, I directed members of the public to the Exhibition, otherwise there would have been very few attending. I also informed them of the public meeting. Those petitioning for BANNG in the afternoon did likewise.


5.3 Neither the Exhibitions at West Mersea and Maldon nor the public meetings in both places attracted large numbers of people and the absence of adequate advertisement of the meetings certainly contributed to this. There were around 60 members of the public at the meeting in West Mersea and around 30 at Maldon.


Public Meeting at West Mersea on 10 December, 2009:


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:


5.9 It is doubtful that West Mersea would have been included as a venue for the Exhibition had it not been for the activities of the Blackwater Against New Nuclear Group (BANNG). The Chair of BANNG, Professor Andrew Blowers, OBE, was instrumental in DECC agreeing to hold a public meeting there. Originally, only Maldon and Bradwell were scheduled as venues for the Exhibition with one public meeting at Maldon.


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 Chelmsford is within a 20 mile radius. There are other significant populations, too, such as Southend, Clacton and Brightlingsea. These towns were not included by DECC in its leaflet distribution.


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 West Mersea. It has five main aims:


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).

BANNG Petition:


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.

Further, we demand that the site of the former Bradwell power station be returned to greenfield status within 25 years of closure as proposed by the Nuclear Decommissioning Authority.


7.6 BANNG supporters have been collecting signatures door-to-door on Mersea Island, at Bradwell and Southminster. Collections have also taken place on the beaches at West Mersea and Bradwell, in Maldon, Colchester and Tollesbury. Supporters have also attended local fetes to collect signatures. It is intended to continue to collect signatures at other communities around the Blackwater estuary in the coming months.


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 did British Energy) to include large towns with a legitimate interest in what happens at Bradwell as venues for the DECC Exhibition and public meetings. It also failed to advertise the events adequately. Both these failures have denied thousands of people the opportunity to be part of a public debate on an issue that will have huge implications for their lives.

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 British Energy and the DECC have deemed it sufficient to make mention of this here and there in their literature and at the DECC Exhibition, as though such storage is in the normal run of things. Since both the size of a new power station and the long-term storage of highly radioactive waste on site are both significant departures from the situation that pertained in relation to Bradwell A, consultation can only be carried out on a properly informed public. 'Sleight of hand' has no place in such serious proceedings. Once again the public has been denied the opportunity to understand or to have a debate on this vital issue.


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.




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.


January 2010

[1] 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.