Memorandum submitted by C Reed (NPS 46)

Case Against Kirksanton Nuclear Power Station

 

1 Summary

1.1 Towards the end of the 1987 movie Wall Street the character Gordon Gecko (representing the unacceptable face of capitalism) is having a discussion with his protégé Bud Fox (who is having serious doubts about Gecko's methods). At one point Gecko says to Fox: "you're not naive enough to believe we're living in a democracy are you ?"

1.2 I think these sentiments resonate with the way the Government is attempting to use the Planning Act 2008 to ride roughshod over the environment, local communities and UK, European and International law.

1.3 I am strongly opposed to the proposal to build a nuclear power station at Kirksanton. My main concerns are as follows:

(a) There would be a severe detrimental impact on a wild and remarkably beautiful landscape.

(b) It would have a severe detrimental impact on England's most beautiful and best-loved National Park, the Lake District, which is protected by the 1995 Environment Act.

(c) It would have a severe detrimental impact on wildlife and plant habitat currently protected by UK, European and International law.

(d) It would be a greenfield development in a rural area and it would irrevocably change the character, quality and tranquility of the landscape for the local community and for visitors to the area.

(e) It would severely damage the tourist industry in the immediate area and it would alter the perception of the Lake District National Park as a tourist destination.

(f) The Government's planning process is severely flawed and it is un-democratic and un-British.

(g) The Government's documents are unfairly biased in the way that information is presented.

(h) There is sufficient evidence to suggest that the Kirksanton site would not be deployable by 2025 which is one of the Government's main requirements for development.

1.4 The proposed build of a Nuclear Power Station at Kirksanton is causing considerable stress and upset to a lot of people. I do not believe the Kirksanton site is viable and it should be removed from the Government's list of potential sites. This should be done as soon as possible to prevent further unnecessary upset to people.

2 Destruction of Landscape

2.1 Select Committee Visit

2.1.1 I feel that the Select Committee need to see first-hand the landscape that the Government are proposing to destroy. It is important to visit on a nice clear day when the surrounding Lake District mountain tops are visible. The best place to get an appreciation of the landscape would be from Kirby Moor with the fell road between Kirby and Ulverston being a convenient viewpoint.

2.2 The Proposed Site

2.2.1 The site would occupy an area of 131 hectares which is approximately 180 football fields. The reactor height would be approximately 200 feet. Sea defences would consist of a wall of between 13' and 20' high - this has been referred to as akin to the Berlin Wall.

2.3 The Effect on the Lake District Landscape

2.3.1 The proposed Kirksanton site would result in a severe detrimental visual impact on a large part of the south west area of the Lake District National Park.

2.3.2 The views from Black Combe, White Combe and Great Burney looking out from the Lake District National Park over the Duddon Estuary are truly exceptional views. They would be spoilt by a Nuclear Power Station at Kirksanton.

2.3.3 Possibly the best view in the whole of England is the view from the fells above Kirby to the east of the Duddon Estuary looking over the estuary to Kirksanton, the Irish Sea, the Isle of Man, Black Combe and all the way round to the highest mountains in England. It is a little known view and would be spoilt by a Nuclear Power Station at Kirksanton.

2.4 The Effect on Silecroft Beach

2.4.1 Silecroft beach is an extremely beautiful and unspoilt beach that borders the full western boundary of the proposed site. The beach extends for approximately 6 miles from Haverigg Point to beyond Gutterby (4 miles of the beach lies within the Lake District National Park).

2.4.2 A Nuclear Power Station would be visible from the full 6 mile length of this unspoilt beach. The proposed wave protection defence of between 13' and 20' in height would also have a severe detrimental visual impact on the beach.

2.5 The Effect on the Duddon Estuary Landscape

2.5.1 The Duddon Estuary basin is unique within England. There is nowhere else in England where mountains as high as the Lake District's Black Combe are so close to the sea. There is nowhere else in England where a magnificent estuary and wetland is surrounded on all sides by such high mountains. This landscape would be spoilt by a Nuclear Power Station at Kirksanton.

3 Impact on Wildlife and Plant Habitat

3.1 The Duddon Estuary adjacent to the proposed Kirksanton site is a European Special Protection Area (SPA), and International Ramsar site. It also contains a European Special Area of Conservation (SAC) at Duddon Mosses as well as UK Sites of Special Scientific Interest (SSSI).

3.2 Morecambe Bay adjacent to the proposed Kirksanton site is a European Special Area of Conservation and it also contains the Morecambe Bay Special Protection Area and Ramsar site.

3.3 The Duddon Estuary contains some special wildlife and plant habitat in a magnificent and unique landscape. This is a fragile and precious environment, which is why the area is protected by UK, European and International law. A Nuclear Power Station at Kirksanton would not only affect the animals and plants of the Duddon Estuary it would also spoil the enjoyment for the people who enjoy this area for its wild beauty.

3.4 If we can't protect these areas what message does it send to our children ? How can we hope to persuade other countries to protect their wild areas if we fail to protect our own ? What sort of world do we want to leave for our children and future generations ?

3.5 We are only temporary custodians of the world we live in. Certainly our energy needs are important. But if we are clever enough to be able to split the atom surely we can find other ways to meet our energy needs without destroying the environment.

4 Impact on Local Communities

4.1 Effect on a Quiet Rural Area

4.1.1 The proposed Kirksanton site would be a greenfield development. This in itself goes against a stated aim in the Government's own Appraisal of Sustainability objectives which is "to avoid the use of greenfield land and encourage the re-use of brownfield sites."

4.1.2 The area surrounding the proposed Kirksanton site is a quiet, rural area. The villages of Kirksanton, Silecroft and Haverigg could be described as "sleepy" villages which is the very reason that most of the locals choose to live in the area.

4.1.3 Building a Nuclear Power Station at Kirksanton would have a devastating impact on the lives of the people who live in the area. The noise and disruption of the build phase would last for at least 6 years. When operational the peace and tranquility of the area would be lost forever.

4.2 Opposition is Not NIMBY-ism

4.2.1 The proposed Kirksanton site is in the backyard of the Lake District National Park which, as the word "National" indicates, belongs to the people of this country.

4.2.2 It is in the backyard of the Duddon Estuary which is a unique and extremely beautiful landscape and wildlife habitat. It has some magnificent views of the Lake District National Park. These views rank amongst the best in the country.

4.2.3 It is in the backyard of Silecroft Beach which is a truly exceptional beach stretching for 6 miles from Haverigg Point to beyond Gutterby.

4.2.4 The Lake District National Park, Duddon Estuary, and Silecroft Beach are free and can be enjoyed by all of society - rich & poor, young & old, black & white - the scenery doesn't discriminate.

4.3 The Need for Jobs

4.3.1 One of the arguments put forward by supporters of the Kirksanton site is that it would bring jobs to the area. I would agree that jobs are important. However, any developments must be in keeping with the character of the area. It is also worth noting that there are only approximately 130 people currently unemployed in Millom. Given the will and investment it should not be difficult to find alternative employment for these people. For example, the development of the Marina at Barrow-in-Furness will require many local people.

4.3.2 If a Nuclear Power Station is built at Kirksanton there is a strong possibility that Haverigg Prison would have to close. This is because the Prison is adjacent to the proposed site and it would not be possible to evacuate the inmates if there was an emergency. Closing the Prison would result in the loss of 300+ local jobs.

4.4 Sustainable Future

4.4.1 The Planning Act 2008 requires any significant new developments to be sustainable. The lifetime of a nuclear power station is 60 years - then what do the local people do for jobs ?

4.4.2 The Copeland economy is already too heavily dependent on the nuclear industry. It seems at times that we are being bullied into accepting more nuclear with the threat that "if you don't accept nuclear then West Cumbria will die."

4.4.3 We need jobs and investment that are sustainable and more in fitting with our environment.

5 Impact on Tourism

5.1 Effect on Tourism in Millom

5.1.1 Over the last few years Millom (2 miles east of proposed site) has been working to develop the local tourist industry. A quote from the Millom website reads: "Millom today provides access to unspoilt golden sands with unrivalled panoramic views of the nearby Lakeland hills and fells.  It boasts the facilities of a town and the opportunities of the unspoilt countryside." This proud claim would no longer be true if a Nuclear Power Station was built at Kirksanton.

5.1.2 Many local jobs depend on tourism. There are caravan parks at Silecroft at the north end of the proposed site and at Haverigg at the south end. There are a number of B&Bs in the area. Local shops get a boost from tourism particularly in the summer months.

5.1.3 The area provides a cheap holiday for many young families and less "well-off" families who can't afford expensive holidays abroad. Who wants to bring their children to play on a beach next to a Nuclear Power Station ? Is it right that we deny access to a beautiful area to the less "well-off" members of society ?

5.1.4 The Millom tourist industry would be destroyed if a Nuclear Power Station was built at Kirksanton.

5.2 Effect on Tourism Further Afield

5.2.1 A Nuclear Power Station at Kirksanton would damage the perception of Copeland, the Furness Peninsula and the Lake District as a tourist destination both in this country and abroad. It would also adversely affect other developments such as the proposed Marina at Barrow-in-Furness.

5.2.2 The Western Lakes contain some beautiful mountain and coastal scenery yet tourist numbers are much less than the central lakes. This is probably due to the proximity of Sellafield. Whilst I am not arguing the pros and cons of Sellafield here I would suggest that building a Nuclear Power Station at Kirksanton would further damage the perception of the area.

6 The Government's Planning Process is Deeply Flawed

6.1 Timescale is Too Short

6.1.1 The timescale for local communities and other groups to consider a proposal such as a Power Station at Kirksanton is far too short. The volume of Government documentation to be read, assimilated and a response provided is overwhelming in the time available.

6.1.2 The documents people opposed to the Kirksanton site need to read include: EN-1 (93 pages); EN-6 (94 pages); Appraisal of Sustainability Main Report (136 pages); Appraisal of Sustainability for Kirksanton (64 pages); Habitats Regulations Assessment for Kirksanton (47 pages). To argue a case against the Government people also need familiarity with such things as: the Planning Act 2008; the Environment Act 1995; alternatives to nuclear; concerns over radioactive waste storage etc etc.

6.1.3 Yet the time between the Draft National Policy Statements for Nuclear Power being published on November 9^th 2009 and the deadline for comments being submitted to the Select Committee is only 9 weeks. It is only 15 weeks from the date the draft policy statements were published to the Government's deadline on February 22^nd 2010 for comments on the Nuclear National Policy Statements.

6.2 Cost of Legal Challenge

6.2.1 The Government is riding roughshod over UK, European, and International environmental law. However, local communities opposed to the Government's planning proposals do not possess the financial means to challenge the Government in the courts.

6.3 Government Riding Roughshod over the Environment Act

6.3.1 The Government state in their National Policy Statement for the Kirksanton site that "Fully effective mitigation of adverse visual effects during the construction and operational phases is highly unlikely" [EN-6 para. 5.11.88]

6.3.2 The Environment Act 1995 states that the purpose of National parks is to (a) to conserve and enhance the natural beauty, wildlife and cultural heritage; (b) to promote opportunities for the public understanding and enjoyment of the special qualities of those areas by the public.

6.3.3 Plain common sense together with the Government's own assessment of the Kirksanton site indicate that effective mitigation is not possible (even assuming cooling towers are not constructed). To build a nuclear power station at Kirksanton would be a clear violation of the Environment Act.

6.3.4 The Environment Act was created for the benefit of the public and to protect the environment from developers. However, the biggest danger to the environment turns out to be our own Government.

6.3.5 If an Act of Parliament is to have any meaning then the proposed development at Kirksanton should be rejected immediately. Failure to do so will only cause the general public to lose more confidence in how the country is run.

6.4 Violation of UK, European and International Law

6.4.1 The Habitats Directive and Birds Directive are European laws that have been created to protect important European wildlife and plant habitat. These European directives have led to the Duddon Estuary being classified as a Special Protection Area (SPA) and Special Area of Conservation (SAC). The Duddon Estuary is also a Ramsar site which is an international law aimed at protecting wetlands of international importance. The Duddon Estuary also contains UK designated Sites of Special Scientific Interest (SSSI).

6.4.2 Morecambe Bay is also a SAC, SPA and Ramsar site.

6.4.3 If these laws are to have any meaning then the Kirksanton site should be rejected.

6.5 Invoking IROPI is Illegitimate

6.5.1 The Government is quoting "Imperative Reasons of Overriding Public Interest" in order to get its own way. The legality of this is at best dubious and quite possibly illegal. If allowed to go unchallenged it sets a dangerous precedent.

6.5.2 The Government uses as justification for IROPI that there is a lack of alternatives [EN-6 para. 5.11.66]. However this is not true. Energy demand could be reduced by energy saving measures (which the Government seem reluctant to adopt) and there are other alternative means of energy supply.

6.5.3 It could be equally well argued that it is in the national interest to protect our National Parks and to conserve our wildlife and plant habitat.

6.5.4 It could also be strongly argued that it is the Government's negligence that has created the concerns over future energy supply. The Government has known for a long time that existing nuclear power stations were reaching the end of their life. If it was in the national interest to secure our future energy supply why have they left it so late to act ?

6.6 Lack of National Debate on Nuclear Policy

6.6.1 There appears to have been very little national debate on (a) whether or not the public want nuclear, (b) the alternatives to nuclear, and (c) if we do want / need nuclear then where as a nation are we willing to site new nuclear power stations.

6.7 The National Policy Statements are Unfairly Biased

6.7.1 There are many examples of misleading, biased and erroneous statements in the Government's National Policy Statements. The following example is taken from [EN-6 para. 5.11.83] and refers to the proposed Kirksanton site.

6.7.2 The Government state that "there could be opportunity for the development to sit within a strong new landscape framework with the creation of tree belts, lakes and replacement public rights of way." This is biased in that it creates the impression that the current landscape can be significantly improved when in fact the reverse is true - the current landscape will be spoilt forever. It could equally have been written along the lines of "the development will result in a severely detrimental and irrevocable change to the character, quality and tranquility of the landscape."

6.7.3 There are many other examples of biased and misleading statements in the National Policy Statements.

7 Not Deployable by 2025

7.1 There is little or no evidence presented by RWE or the Government to suggest that the Kirksanton site could be operational by the Government's own target date of 2025.

7.2 In the time frame both the energy utilities and reactor suppliers are unable to simultaneously build nuclear power stations in the UK, Europe and worldwide due to financial risk exposure, availability of skilled workforce and qualified sub-contractors, and bottlenecks with supply of certain materials (e.g. Japan Steel Works are the sole maker of certain reactor parts).

7.3 The Kirksanton site is the least favoured site of RWE which recently announced the Wylfa and Oldbury sites as the sites they will develop. Braystones is another proposed site. What are RWE's outline financial and project plans for developing all of these sites by 2025 ?

January 2010