Memorandum submitted by Kirksanton Action Group (NPS 84)
The purpose of this document is to review the DECC engagement and consultation process in relation to the proposed new nuclear build on the Greenfield site of Layriggs within the village of Kirksanton West Cumbria. There is a need for careful review of the original Screening and subsequent Strategic Siting Assessment documentation regarding this Greenfield site.
What are the implications:-
i. First knowledge of potential Greenfield site nomination was broadcast by Radio Cumbria at 0730 on February 26th 2009. This was a 'Shock' announcement to those Kirksanton residents that received the radio programme.
ii. It is our understanding from documents including Kate Barkers report that "Nominations must not be a shock to a local community" noting not all residents heard the report the actual nomination was then made public via residents who had received the transmission. Question Define Local Community?
iii. Following a local news paper headline dated Monday 2nd March "Tell us the site" RWEnpower response was that no actual site decision had yet been taken.
iv. A hand delivered letter to the Kirksanton residents arrived Tuesday 3rd March detailing a potential nomination and subsequent meeting opportunities
v. Following the aftershock residents of Kirksanton tried to follow through the original siting process but as a na´ve community the only tool we had was intuition. Our limited review and subsequent understanding of the Jackson report on nuclear siting was that an assumption for new build would be on or adjacent to existing sites. From outputs of SSA consultees and stakeholder meetings it appears also to have been an assumption.
vi. It was not until the published Towards a Nuclear National Policy Statement in January 2009 - introduction section 3) "Whilst the white paper on nuclear power expected that applications for building new nuclear power stations were likely to focus on areas in the vicinity of existing nuclear facilities anyone can nominate a site and all nominated sites will need to be assessed under the strategic siting Assessment (SSA). Was this the first time the government announced it was changing its widely held view that all new build would in the first instance be on or near existing nuclear power stations? Was this position clear when consulting on the SSA in July of 2008?
vii. It is understood that these changes took place following industry challenge that any site could be nominated; perhaps industry could see financial opportunity afforded and the importance of Greenfield sites. Who would have expected a Greenfield site some 21 miles south of an existing infrastructure facility, namely Sellafield, to have been chosen?
viii. We cannot find reference to differentiated process between Greenfield and Brownfield sites in the current SSA. Once established that Greenfield sites were allowed into the process did DECC consider requesting any inputs into the SSA to accommodate Greenfield sites being entered into the equation?
Our own differential analyses of Greenfield vs. Brownfield have shown a number of anomalies; Greenfield would be rural DECC must be aware that a rural site away from established developments and infrastructure would pose particular problems rural proofing being one example A differential analysis (based on statistical analysis) would be evacuation of site. Existing sites have well rehearsed plans. Sizewell enquiry wanted the evacuation plan days 54-60 based an establishment.
If a Tool Kit is created that deals with a Greenfield site that has been delineated from the process and use this as a site specific measure, not as a sub regional AoS as has been done, it shows that you would need an understanding of site specifics and its immediate surroundings in our case Millom. RWEnpower would be looking to evacuate 4-5km from site boundary therefore trying to evacuate the only population in a 100sqkm for which there is no where to go.
DECC say there are no other sites in the country yet RWEnpower took a helicopter ride North and South of Sellafield to find Kirksanton and Braystones is this credible to put to the British public where Atkins could not find sites?
Would this then suggest the process is duly flawed in relation to this site?
ix. First Public Information Meeting.
A public information meeting was made available on 24 March 2009 Site Maps were made available with documentation quoting 180acres (also noted on RWEnpower web site). It was clear to local residents that the 'Site Map' showed a considerably larger area than 180 acres indeed it is over 300 acres.
The evening Q&A session (Kirksanton Village Hall) was attended by 140 people who arrived to find the Head of Copeland Borough Council in the Chair along with a Senior Manager representing West Lakes Renaissance, RWE were in attendance to the side of the room. More importantly the village hall does not allow seating for such numbers, fire exits blocked, public refused admittance an appalling lack of duty of care to attendees and to Health and Safety.
A question was this meeting part of the process? Whose meeting?
x. Prior to the meeting, 8 March 2009, one resident sent an email to RWEnpower with a 4 page attachment requesting specific information however, RWEnpower did not respond until March 24th 2009 @ 22.40 we feel this is significant as the meeting ended at 2200 hours it is in our considered opinion that RWEnpower withheld sending this information until after the meeting ended.
xi. We understand this to be a serious allegation to be making however when the law lords state: "whether or not consultation of interested parties and the public is a legal requirement, if it is embarked upon it must be carried out properly"
xii. A number of other characteristics occur to do with the monitoring and policing of this process and we say "DECC may not have understood their role as facilitators" an example at the recent Heysham DECC event Q&A Mr P McDonald stated "Citi Group did not understand the complicated set of NPs documents that had been released". If DECC know this and there is a problem of understanding what has been done to help communities understand?
We finally draw your attention to EN6 page 168 5.11.8. And offer the following statement from Cumbria Vision and a reminder of current site usage
Nuclear renaissance across the world offers us significant incremental business opportunities, and is certainly highlighted in our strategy. We are however agnostic as to where any new developments will be sited, as those decisions will be made in line with the process dictated by Government, and ultimately local communities through local democracy. The Sellafield site, recently purchased by the Iberdrola/Scottish/GDFSuez consortium currently satisfy those conditions and are supported. I would also like to make clear this is the site put forward for nomination under the Britain's Energy Coast initiative. The RWE Npower nominations for Kirksanton and Braystones have been separately submitted by the company.
Simon Sjenitzer - Strategy Director Cumbria Vision .........Leading on Economic Development in Cumbria
Kirksanton is home to one of the oldest wind turbine farms in the country generating renewable energy along with this we house HMP Haverigg who also wish to further develop turbine development we then appear to have a conflict of energy generation interests and await your review of this document.