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Memorandum submitted by Westinghouse Electric Company (NPS 49)
ABOUT WESTINGHOUSE
Westinghouse Electric Company, a group company of Toshiba Corporation, is the world's pioneering nuclear power company and is a leading supplier of nuclear plant products and technologies to utilities throughout the world. Westinghouse supplied the world's first Pressurised Water Reactor in 1957 in Shippingport, Pennsylvania. Today, Westinghouse technology is the basis for approximately half of the world's operating nuclear plants.
Westinghouse is headquartered in Pittsburgh Pennsylvania and employs around 10,000 people around the world. The company has three core business areas - nuclear fuel, nuclear reactor services and nuclear power plants.
China will build four Westinghouse AP1000 reactors - two on the Sanmen site and two on the Haiyang site. Construction on the first of these plants, at Sanmen, began in February 2008, and is now well underway. A further six AP1000 plants have already been ordered in the US, with many more in the planning stage.
UK regulators are currently assessing two reactor designs in detail - including the Westinghouse AP1000 - to determine if they meet the UK's safety and environmental requirements.
In the UK, Westinghouse runs the Springfields site in Preston, Lancashire (where around 1800 people are employed), on behalf of the Nuclear Decommissioning Authority. The vast majority of the UK's nuclear fuel has been made at Springfields, over a period of more than 50 years.
1. Do you think that the Government should formally approve ('designate') the draft Overarching Energy National Policy Statement?
Yes - most definitely.
The UK is in need of substantial investment in energy infrastructure over the next decade or so, and the nature of the market means that this investment needs to come from privately-owned power utilities, not from Government. Those utilities will wish to have a certain level of confidence in the successful delivery of their projects, and a major part of that will be predictability in timing of key decisions such as planning approval. It is well known that in the past such decisions have often been subject to long delays, therefore the planning reforms now introduced are a key enabler for the utilities in making investment viable. This is particularly important given the long timescales of some of the potential energy projects, such as nuclear power plants.
The National Policy Statements prevent individual planning applications from re-opening discussions on national policy, which have already taken place and been concluded in Parliament. In the case of energy policy, these decisions have been made with full public consultation at various stages, and so additional public consultation on matters of national policy is unnecessary at a site-specific approval stage.
2. Does the draft Overarching Energy National Policy Statement provide the Infrastructure Planning Commission with the information it needs to reach a decision on whether or not to grant development consent?
Yes, we believe that it does.
3. Does the draft Overarching Energy National Policy Statement provide suitable information to the Infrastructure Planning Commission on the Government's energy and climate policy?
Yes, we believe that it does.
However we are surprised that no mention is made of the fact that nuclear energy offers significant attractions in respect of security of energy supplies.
4. Does the draft Overarching Energy National Policy Statement provide suitable direction to the Infrastructure Planning Commission on the need and urgency for new energy infrastructure?
Yes, we believe that it does.
5. Do the assessment principles in the draft Overarching Energy National Policy Statement provide suitable direction to the Infrastructure Planning Commission to inform its decision-making?
We believe that the direction provided is broadly-speaking appropriate. However we are somewhat concerned that the NPS seems to place urgency ahead of other considerations, such as CO2 emissions or security of energy supplies. This could lead to the IPC feeling that priority should be given to projects which can be delivered quickly over those (such as nuclear power plants) which will take longer to come on-stream.
We do not believe that this is intentional and suggest that some clarification might be added in the final version of the NPS. It is worth noting that - in fact - it is those projects with the longest timescales which most need the predictability of timing from the IPC.
6. Does the draft Overarching Energy National Policy Statement appropriately cover the generic impacts of new energy infrastructure and potential options to mitigate those impacts?
Yes, we believe that it does.
7. Do you have any comments on any aspect of the draft Overarching Energy National Policy Statement not covered by the previous questions?
No.
8. Do you think that the Government should formally approve ('designate'): a) The draft National Policy Statement for Fossil Fuel Electricity Generating Infrastructure (EN-2)? b) The draft National Policy Statement for Renewable Energy Infrastructure (EN-3)? c) The draft National Policy Statement for Gas Supply Infrastructure and Gas and Oil Pipelines (EN-4)? d) The draft National Policy Statement for Electricity Networks Infrastructure (EN-5)?
Yes - most definitely.
These more specific statements go hand-in-hand with the Overarching NPS statement to ensure that the right groundrules are in place upon which the IPC can make decisions over specific projects.
In Questions 9 to 15, Westinghouse are only commenting in respect of the National Policy Statement for Electricity Networks Infrastructure (EN-5), as this is the only one where we - as a company dedicated purely to nuclear energy - have detailed relevant expertise.
9. Do the following draft National Policy Statements provide the Infrastructure Planning Commission with the information it needs to reach a decision on whether or not to grant development consent: a) The draft National Policy Statement for Fossil Fuel Electricity Generating Infrastructure (EN-2)? b) The draft National Policy Statement for Renewable Energy Infrastructure (EN-3)? c) The draft National Policy Statement for Gas Supply Infrastructure and Gas and Oil Pipelines (EN-4)? d) The draft National Policy Statement for Electricity Networks Infrastructure (EN-5)?
Yes, we believe that, for EN-5, this is the case.
10. Do the following draft National Policy Statements appropriately cover the impacts of the specific types of new energy infrastructure covered in them, and potential options to mitigate those impacts: a) The draft National Policy Statement for Fossil Fuel Electricity Generating Infrastructure (EN-2)? b) The draft National Policy Statement for Renewable Energy Infrastructure (EN-3)? c) The draft National Policy Statement for Gas Supply Infrastructure and Gas and Oil Pipelines (EN-4)? d) The draft National Policy Statement for Electricity Networks Infrastructure (EN-5)?
Yes, we believe that, for EN-5, this is the case.
11. Do you have any comments on any aspect of the following draft National Policy Statements not covered by the previous questions: a) The draft National Policy Statement for Fossil Fuel Electricity Generating Infrastructure (EN-2)? b) The draft National Policy Statement for Renewable Energy Infrastructure (EN-3)? c) The draft National Policy Statement for Gas Supply Infrastructure and Gas and Oil Pipelines (EN-4)? d) The draft National Policy Statement for Electricity Networks Infrastructure (EN-5)?
No - for EN-5 we do not.
12. Do you agree with the findings from the following Appraisal of Sustainability reports: a) Appraisal of Sustainability report for the draft Overarching Energy National Policy Statement (EN-1)? b) Appraisal of Sustainability report for the draft National Policy Statement for Fossil Fuel Electricity Generating Infrastructure (EN-2)? c) Appraisal of Sustainability report for the draft National Policy Statement for Renewable Energy Infrastructure (EN-3)? d) Appraisal of Sustainability report for the draft National Policy Statement for Gas Supply Infrastructure and Gas and Oil Pipelines (EN-4)? e) Appraisal of Sustainability report for the draft National Policy Statement for Electricity Networks Infrastructure (EN-5)?
Yes, we believe that, for EN-5, this is the case.
13. Do you think that any findings from the following Appraisal of Sustainability reports have not been taken account of properly in the relevant draft National Policy Statements: a) Appraisal of Sustainability report for the draft Overarching Energy National Policy Statement (EN-1)? b) Appraisal of Sustainability report for the draft National Policy Statement for Fossil Fuel Electricity Generating Infrastructure (EN-2)? c) Appraisal of Sustainability report for the draft National Policy Statement for Renewable Energy Infrastructure (EN-3)? d) Appraisal of Sustainability report for the draft National Policy Statement for Gas Supply Infrastructure and Gas and Oil Pipelines (EN-4)? e) Appraisal of Sustainability report for the draft National Policy Statement for Electricity Networks Infrastructure (EN-5)?
No - for EN-5 we do not.
14. Do you have any comments on any aspect of the following Appraisal of Sustainability reports not covered by the previous questions: a) Appraisal of Sustainability report for the draft Overarching Energy National Policy Statement (EN-1)? b) Appraisal of Sustainability report for the draft National Policy Statement for Fossil Fuel Electricity Generating Infrastructure (EN-2)? c) Appraisal of Sustainability report for the draft National Policy Statement for Renewable Energy Infrastructure (EN-3)? d) Appraisal of Sustainability report for the draft National Policy Statement for Gas Supply Infrastructure and Gas and Oil Pipelines (EN-4)? e) Appraisal of Sustainability report for the draft National Policy Statement for Electricity Networks Infrastructure (EN-5)?
No - for EN-5 we do not.
15. Do you have any comments on the Habitats Regulations Assessment reports for the following draft National Policy Statements: a) Habitats Regulations Assessment report for the draft Overarching Energy National Policy Statement (EN-1)? b) Habitats Regulations Assessment report for the draft National Policy Statement for Fossil Fuel Electricity Generating Infrastructure (EN-2)? c) Habitats Regulations Assessment report for the draft National Policy Statement for Renewable Energy Infrastructure (EN-3)? d) Habitats Regulations Assessment report for the draft National Policy Statement for Gas Supply Infrastructure and Gas and Oil Pipelines (EN-4)? e) Habitats Regulations Assessment report for the draft National Policy Statement for Electricity Networks Infrastructure (EN-5)?
No - for EN-5 we do not.
16. Do you think that the Government should formally approve ('designate') the draft Nuclear National Policy Statement?
Yes - most definitely.
As previously noted, the full series of National Policy Statements is crucially important to securing a balanced and sustainable energy policy for the UK. Without the predictability of process which these Statements bring to the planning system, potential investors will be wary about the potential for planning applications to become long and drawn-out, as the UK has seen in the past.
In the case of nuclear energy in particular, predictability of timing is essential if new plants are to be delivered in time to replace the existing nuclear plants over the coming 10 to 15 years, retaining a significant fraction of UK electricity production from this low-carbon, reliable and affordable source.
17. Does the draft Nuclear National Policy Statement provide the Infrastructure Planning Commission with the information it needs to reach a decision on whether or not to grant development consent?
Yes.
18. Does the draft Nuclear National Policy Statement provide suitable direction to the Infrastructure Planning Commission on the need and urgency for new nuclear power stations?
Yes.
19. Do you agree with the Government's preliminary conclusion that effective arrangements will exist to manage and dispose of the waste that will be produced by new nuclear power stations in the UK?
Yes - most definitely.
It is important to recognise that the UK already manages all of its nuclear waste safely and effectively. There is now a clear policy for disposal of the higher-activity wastes which we currently have in the UK in a deep underground repository. This policy was developed with widespread public consultation and is consistent with international consensus and best practice. A process is currently underway to find a suitable location for such a repository.
Although the specifics of waste management from new nuclear power plants are a matter for the utility companies, it has been recognised that the volumes of waste produced from such plants are relatively small in comparison to the quantities already in existence. Furthermore, they have been shown to be capable of disposal in the same repository as legacy wastes, subject to that repository being suitably sized to accommodate them.
20. Does the draft Nuclear National Policy Statement appropriately cover the impacts of new nuclear power stations and potential options to mitigate those impacts?
Yes.
21. Do you agree with the Government's preliminary conclusion on the potential suitability of sites nominated into the Strategic Siting Assessment, as set out below? You can respond in general terms on the assessment as a whole, or against one or more specific sites. a) General comments The Government considers the following sites to be potentially suitable for the deployment of new nuclear power stations by the end of 2025: b) Bradwell c) Braystones d) Hartlepool e) Heysham f) Hinkley Point g) Kirksanton h) Oldbury i) Sellafield j) Sizewell k) Wylfa The Government does not consider the following site to be potentially suitable for the deployment of new nuclear power stations by the end of 2025: l) Dungeness
In general, we do agree with the Government's preliminary conclusion, and specifically we fully agree that the ten sites listed at (b) to (k) above are suitable for new nuclear build on the stated timescale.
We also believe that the issues identified in respect of the Dungeness site are not sufficient to warrant that site being eliminated from consideration. We feel that the site should be included on the list in the NPS and that it should be up to the potential developers of that site to demonstrate that they can mitigate against the various issues identified. We believe that a great deal of mitigation would be technically achievable and it should be left to potential developers to choose if they wish to invest in such measures.
22. Do you agree with the Government's preliminary conclusion that the three sites identified in the Alternative Sites Study, as listed below, are not potentially suitable for the deployment of new nuclear power stations by the end of 2025? You can respond in general terms on the sites identified in the Study as a whole, or against one or more specific sites. a) General comments b) Druridge Bay c) Kingsnorth d) Owston Ferry
We agree that these three sites are not ideally suited for deployment of new nuclear power stations by 2025, but we feel that they could well be suited to such development on a longer timeframe - as could many other UK sites.
23. Do you agree with the findings from the Appraisal of Sustainability reports for the draft Nuclear National Policy Statement?
Yes.
24. Do you think that any findings from the Appraisal of Sustainability reports for the draft Nuclear National Policy Statement have not been taken account of properly in the draft Nuclear National Policy Statement?
No.
25. Do you have any comments on the Habitats Regulations Assessment reports for the draft Nuclear National Policy Statement?
No.
26. Do you have any comments on any aspect of the draft Nuclear National Policy Statement or its associated documents not covered by the previous questions?
No.
27. Do you have any comments on the Impact Assessment report for the draft energy National Policy Statements?
No.
28. Does this package of draft energy National Policy Statements provide a useful reference for those wishing to engage in the process for development consent for nationally significant energy infrastructure, particularly for applicants?
Yes.
29. Do you have any comments on any aspect of the draft energy National Policy Statements or their associated documents not covered by the previous questions?
No.
January 2010 |