Other TASC Consultation Responses
TOGETHER AGAINST SIZEWELL C RESPONSE TO BRADWELL B FIRST CONSULTATION June 2020
TOGETHER AGAINST SIZEWELL C RESPONSE TO BRADWELL B FIRST CONSULTATION
The request for ‘feedback’ on the proposed Bradwell B nuclear plant development makes the presumption, like consultations around Hinkley and Sizewell, that the project will go ahead. This renders the views of respondents who are opposed to any nuclear development redundant, in that the time for criticism of the ‘nuclear renaissance’ proposals was at the policy development stage.
Developers like CGN and EdF can and do conveniently hide behind a planning process which excludes public participation or influence. Policy is made by a small cabal of senior politicians advised by generally ill-informed and nuclear-sympathetic consultants. That policy, after an entirely inadequate period of scrutiny by Parliament (in the case of the energy policy enshrined in EN1, there is no evidence of any non-nuclear option having been put to MPs), is then turned into a national policy statement (NPS) which is effectively inviolate.
Despite the requirement on developers to undertake multiple consultations, despite National Planning Inspectorate scrutiny and despite the best efforts on local opposition groups, the development can legitimately be characterised by proponents as ‘inevitable’, thereby demanding of opposition groups a counter-offensive which is required to become Herculean in order to gain any traction. And at the end of the process, it is the government in the form of the Secretary of State, which has the final say: there at the beginning to set the policy and, just to ensure it has the casting vote, there at the end as well. Once enshrined in a national policy statement, the only way that such a fatally flawed policy as that on new nuclear build can be overturned is by government ditching it and running the political gauntlet of ridicule that generally comes with policy U turns.
All the proposed nuclear developments are presented to communities as ‘done deals’. The questions posed to the public in requests for feedback make this assumption and thereby render comments about the need for nuclear, safety of nuclear, health impacts of nuclear, its carbon footprint and the range of other damaging characteristics attached to the technology irrelevant to the consultation responses as they have already been decided by what passes for a democratic process which lacks one important thing – any voice from local democracy. What CGN/EdF’s consultation processes amount to is a request for local preferences as to how the deckchairs on the Titanic should be arranged. No-one has ever been asked in the areas which are to be burdened with unnecessary, gigantic developments if they want to embark on the Titanic at all.
Lack of policy infrastructure
Despite the elaborate Parliamentary process by which Public Inquiries have been replaced by the national planning statement procedure, ostensibly to reduce the time between conception of a policy and its implementation, what has been lost is democratic scrutiny. Moreover, the current NPS which covers the nuclear component of the energy policy, EN6, is entirely unfit for purpose as it gives policy authority only to those nuclear plants which can be deployed before 2025. None of the current plants which have entered the race in the south – Hinkley, Sizewell or Bradwell – will be generating electricity by that date and therefore the EN6 policy document is null and void. Its replacement is still undergoing review and will depend heavily on the financing arrangements the government can agree to in order to remove the need for a bankrupt EdF to fork out for it. Instead, the government is exploring novel ways in which to lay the burden for financing a highly dangerous, untried and tricky capital venture, which has more to do with bailing out the French nuclear industry than producing electricity for British consumers, on the public purse. So much for ‘no subsidy’ nuclear, but in policy terms, it is entirely scandalous that Hinkley C is being built, that plans for Sizewell C are now with the planning inspectorate and CGN/EdF are consulting on plans to build Bradwell B when there is no policy architecture to justify and legitimise any of this work or progress. EN6 has fallen as a legitimate policy statement for new nuclear build but that does not seem to have any effect on the way the French and Chinese backers of new nuclear in the UK are required to act. Legal challenges to this situation are being explored.
Need for nuclear
The justification for the ‘nuclear renaissance’ as expressed by Tony Blair when, in 2006, he made his U-turn on the previous policy of promoting renewable sources, was that new nuclear would increase energy security and reduce greenhouse gases. Neither claim is true. The UK has no domestic deposits of uranium and is reliant on imports for its nuclear sector. The energy security issue that Blair disingenuously used as his reason for ‘putting nuclear back on the agenda with a vengeance’ was that the lights were due to ‘go out’ in 2017 unless replacement generating capacity could be deployed. In the 11 years between his statement and ‘D’ for darkness day in 2017, no new nuclear plant was deployed, electricity demand fell by over 10% and the lights stayed on. In fact, rather than realising the predicted increase in electricity demand of 15% to 2020, demand has fallen by 16% overall, making predictions more than 30% in error.
Despite the repeating of the mantra by nuclear apologists that nuclear is either ‘carbon free’ or ‘low carbon’, the fact is that it is not. The two Hinkley C base-plates alone each weigh in at ~ 49,000 tonnes of concrete. Embedded carbon burden in the entire new nuclear build enterprise, from the considerations of the uranium life-cycle which take it from being extracted from the ground to spent fuel being stored and then disposed of in a notional geological facility, to the carbon footprint of the concrete, steel, transport needs and operational requirements on a daily basis, nuclear power plants are neither carbon free nor low carbon.
New nuclear is simply not required. Even the National Infrastructure Commission says the government ‘should not agree support for more than one nuclear power station beyond Hinkley Point C before 2025’. It is the most expensive technology, the slowest to deliver electricity, the most disruptive to local communities, the most environmentally damaging and could yet be shown to be very bad for health, especially the health of children. Moreover, nuclear power is intergenerationally inequitable as it passes a huge institutional control burden to generations who will have had no say in the choice for nuclear power and will have received none of its putative benefits. Neither Hinkley C, Sizewell C nor Bradwell B are necessary to keep the lights on. They have more to do with keeping the French nuclear industry afloat and allowing the Chinese a foothold in Europe for their own reactor design than they have with the well-being of the British public.
Of all the issues which make nuclear a bad energy supply option, the perennial and possibly intractable problem of nuclear waste is the most persistent. It is astonishing that any government can pursue a policy of new nuclear build when the 500,000 cubic metres of waste from the previous programme of Magnox, AGRs and the Sizewell B PWR still languish in ‘temporary’ storage facilities at nuclear stations and facilities all over the country. Despite fifteen years of effort originally by the Liabilities Management Unit, then the Nuclear Decommissioning Authority and its off-shoot Radioactive Waste Management Limited, the UK is no nearer to identifying the location, the methodology or the processes by which a repository will be provided for the existing legacy waste.
Spent fuel from new build reactors will be far hotter and more radioactive than the existing legacy spent fuel even from the Pressurised Water Reactor at Sizewell, yet the government has assumed that the contested recommendation from the Committee on Radioactive Waste (CoRWM) that disposal is the least worse option for the management of such material, is fit for new waste as well as legacy waste. Government has co-opted CoRWM’s majority decision for disposal as a catch-all for all nuclear waste when CoRWM’s remit was specifically to look at the best management option for legacy waste only. It seems that despite pointing this out forcefully in their final 2007 report, government has simply used the recommendation for disposal as suitable for EPR fuel and waste from the new build programme when the more volatile nature of the hotter and more radioactive spent fuel from EPRs demands careful attention to technical and engineering variations to safely store it deep underground for tens of millennia.
Perhaps even more damning is government’s apparent disregard for the ethical and moral issues thrown up by the creation and management of new build waste. Legacy waste was created in the period of time when the UK was desperately keen to keep itself in the big league of nations which possessed weapons of mass destruction. On its own admission, at that time in the early 50’s, the nuclear industry was so preoccupied with producing plutonium for nuclear weapons that waste management was the last thing on its mind. The Magnox programme had more to do with the imperative of plutonium production than the generation of electricity and the AGR programme which followed, as well as the Sizewell PWR, were products of misguided policies developed by ministers in thrall to nuclear power. But dealing with this legacy waste was an imperative: it exists and has to be dealt with by the generation which reaped its so-called benefits.
The same cannot be said about the waste arising from a new build programme. We are now deliberately planning to build plants which will not meet the energy security nor the greenhouse gas requirements which were used to justify them but which will, nevertheless, generate waste for which there is currently no safe and secure management and for which there is unlikely to be such for the foreseeable future. This is the height of irresponsibility and disregard for the well-being of future generations.
CO2 and nuclear
To argue, as do nuclear proponents on a routine basis, presumably on the assumption that if a falsehood is repeated enough times, it will either become true or that people will accept it as the truth, that nuclear is ‘carbon free’ or ‘low carbon’ is wrong. According to the Intergovernmental Panel on Climate Change, IPCC, for every tonne of cement produced there is a one and a quarter tonnes of CO2 released. Just one of the ~49,000 tonne bases for the Hinkley C station alone will therefore be responsible for the generation of more than 60,000 tonnes of carbon: that’s 360,000 tonnes of carbon across the proposed southern fleet. Steel produces circa 1.8 tonnes of carbon for every tonne of steel. At every step of the development of a nuclear plant, which takes over a decade to complete, there are examples of embedded carbon burden. Transport at every phase, the accommodation of a three thousand strong construction workforce, the huge carbon debt generated by the uranium fuel cycle and the unknown carbon cost of managing the spent nuclear fuel and other long lived nuclear detritus not only adds to the overall carbon burden associated with nuclear power but a degree of uncertainty which can only lead to one conclusion: nuclear is neither ‘free’ from carbon nor is its burden ‘low’ when compared to other emerging or renewable technologies.
Even at the point of ‘burning’ the uranium in the reactor, the nuclear technology does not compare well to other technologies. Professor Benjamin Sovacool, at the Science Policy Research Centre at Sussex University, examined 103 different studies of the uranium lifecycle and concluded nuclear power plants produce electricity with a mean of 66 grams of carbon per kilowatt hour compared to 9.5 – 38 grams for renewables.
In 1983, Yorkshire TV screened a programme called, ‘Windscale, the nuclear laundry’, which detailed the work carried out at the giant Cumbrian plant, renamed Sellafield in 1981. Sellafield is a nuclear fuel reprocessing plant: it chemically and mechanically separates unburnt uranium and plutonium from spent nuclear fuel rods. In the process, it generates large quantities of low, intermediate and high level waste, both in liquid and solid forms. Two million gallons of contaminated water are discharged daily to the Irish Sea, carrying trace elements of radioactive particles. Some of these are heavy metals, notably plutonium, which settle around the outfall of the discharge pipe and, over the years, are driven back to shore by the tides, dried by the sun and dispersed by the winds. The YTV programme identified a ten-fold excess of childhood leukaemia in the village of Seascale, a few miles from the Sellafield plant. Management argued that the doses received by the children from the plant were too low to have any responsibility for their illnesses.
In 2008, a German report called Kinderkrebs in der Umgebung von Kernkraftwerken (KiKK; Childhood cancer in the vicinity of nuclear power plants) showed that children under five years of age, living within 5kms distance of German nuclear stations suffered a 1.6 to 2 fold increase in the national incidence for leukaemia. Similar evidence was found in several further reports and in 60 such studies, the expected and predicted impact of exposure to ionising radiation, as expressed in cancers and genetic malformation, has been massively surpassed by the evidence of harm.
A recent report (http://www.llrc.org/children.htm) funded by the charity Children with Cancer UK, examines some of the evidence presented by those 60 studies. It concludes that cancer and genetic malformation rates in communities living in close proximity to nuclear facilities or those which have been exposed to ionising radiation from nuclear weapons fallout or as a result of accidents such as Chernobyl, are invariably much higher than those predicted by contemporary science. The report calls into question the accuracy of the maxim that the effects of exposure are linear. The link between dose and risk which has for decades formed the basis of authorisation for discharge limits from nuclear facilities is considered by the authors, based on the evidence compiled in the report, as redundant. Even very low doses of ionising radiation or alpha emitting ‘hot particles’, for example, such as those found on beaches and which are incapable of detection or removal by existing technology, can damage tiny areas of a cell or group of cells in the body with potentially devastating effect.
The conclusion of this compilation of evidence from around the world, which includes evidence from the aftermath of Chernobyl and examines the flaws in the evidence gathered from the Japanese A-bomb victims, is that neither the nuclear industry, its supporters, governments nor regulators know enough about ionising radiation exposure to declare that current discharges from nuclear facilities are at safe levels. Indeed, it is universally accepted that there is no safe level of exposure to radiation. Regardless of these known unknowns, we continue to develop a nuclear revival in the UK when elsewhere around the world, the industry is in decline.
The Windscale Fire in 1957, Three Mile Island, Chernobyl and Fukushima, along with the 32 recorded ‘significant’ nuclear accidents since 1952, all share a common characteristic – they were unforeseen, as will be the next nuclear accident. There is no effective protection from such events and the local authority emergency and resilience plans, as much as they are well intentioned, are largely unimplementable and futile in protecting people from exposure to radiation in the event of a major nuclear event. Evacuation of a vulnerable community from the path of a cloud of radioactivity from a stricken plant is as more a matter of luck than judgement as much will depend on the wind direction, the time of day or night and other conditions, not the least of which is the local transport and road infrastructure. As we know, more often than not, nuclear plants are sited in remote areas which are, by definition, serviced by a road network which is adequate and often strongly defended by locals but which is ineffective when it comes to organising a mass and swift exodus. The fact is that emergency plans and achieving the objective of removing even moderate numbers of people from an area remains more a matter of hope over expectation. It is no co-incidence that nuclear plants which generate electricity for use largely in huge conurbations such as London are not sited on the Thames: better to risk the lives of a smaller number of people in a remote area.
There are degrees in bad decisions when it comes to proposed sites for nuclear stations but the idea of building an untried, highly complex twin HPR1000 plant at Bradwell is perhaps the height of ridiculousness. Mersea Island is a few kilometres to the north. It has a population of 7,000 people and is only accessed by a pontoon which floods twice a day. Marooned Mersea inhabitants would be unable to evacuate for several hours should the accident occur at an inconvenient time even if the road system allowed them to do so in an orderly and timely manner. The proposed site abuts an estuary which supports highly profitable and long-established oyster beds. Discharges from the proposed plant will concentrate in filter-feeding oysters, threatening the profitability and viability of the industry.
Building any nuclear facility in coastal environments in an age when climate change is predicted to cause rapidly changing and increasing sea level rises over the next century is quite simply foolhardy. The idea that Bradwell could be built on a raised platform to protect it from extreme flooding is preposterous when UK Climate Predictions 18 expects a sea level rise on the east coast of between 0.29 and 1.15 metres and when the collapse of the West Antarctic Ice Sheet, known to be extremely sensitive to climatic conditions and even small amounts of warming – could cause a 6 metre rise and when the entire Antarctic ice sheet has the ability to raise sea level by a staggering 57 metres. The rate of ice-loss from the West Antarctic Ice Sheet has tripled in the last 25 years.
The Bradwell B plans are doomed. The Blair ‘nuclear renaissance’ of the early 21st century is reminiscent of the Thatcher dream of the ‘80s when she came up with the deluded plan to build one PWR a year for ten years. Financially, environmentally, socially and technically, such a plan was flawed from the start and did not see the light of day beyond the Sizewell B PWR before the entire enterprise collapsed. The same will happen today with the impossibly ambitious and un-realisable scheme to deploy a fleet of untried and untested EPR and HPR reactors largely for the benefit of the French nuclear industry and Chinese geopolitical ambitions, reactors which are unsuited to modern electricity supply networks, which take more than a decade to construct and which will leave a lasting legacy of lethal waste. Hinkley is indeed the only plant actually under construction but there is hope that even this plant will never be fully deployed.
Bradwell is a bad idea, in an unsuitable location and should be shelved forthwith.
TASC June 2020
EDF's DCO Pre Application for Sizewell C
TASC response to the news that EDF intend to move to the next stage in the planning process A PDF of the response can be downloaded here
We would like to encourage those of you who have similarly found the planning process to be unsatisfactory to send your personal comments noting your disquiet about the 4 Consultations held by EDF. It would be good if they were your personal experiences. Lack of info, no one to answer your inquiry, missing information, especially if it is near where you live and you do not have enough info ie Yoxford A12/ A1120 junction management. or if you feel the information was misleading or constantly changing.
The TASC email to the Planning Inspectorate:
Pre Application for Sizewell C: Observations, comments and dissatisfaction on lack of information and detail during the EDFE 4 Consultations and before Development Consent Order (DCO).
TASC feel it is important at this stage in the proceedings and before any DCO is submitted to the Planning Inspectorate to voice our disquiet at the inadequacies of the Consultations carried out by EDFE. The lack of detail and evidence on very many matters leaves us concerned as to how the many varied issues will be dealt with when brought to the Planning Inspectorate. We are concerned that it will entail the Planning Inspectorate imposing a great many conditions. We have featured just a few such concerns in the content of this Paper.
We were told that the new method of considering Infrastructure Applications would hasten the proceedings and the developers would provide enough information during the Consultation Process so as to achieve a comprehensive well considered plan before the DCO was submitted.
This most certainly is not the case with this EDFE Sizewell C (SZC) Plan,
TASC has pointed out at every stage of this process that we do not have the information or evidence for EDFE’s claims. Consultees are still left without even the most basic of information in many instances.
We submit that this renders the process inadequate and invalid.
It would appear that EDFE has not read the Guidance on Pre application Process 2008 and definitely has not adhered to the openness and transparency which allows for Consultees to make proper judgement.
When EDFE does submit its DCO, it is hoped that the Planning Inspectorate takes into consideration our deep dissatisfaction at the way EDFE have avoided the many in-depth questions which have been submitted by many consultees.
We are also worried that many studies which are required to substantiate EdFE’s claims regarding the development have not been available to members of the public.
The process began on November 21st 2012. We have responded to all four Consultations, the last of which was held July to Sept of 2019. Many of the issues we have raised during that time have been raised by others, including Statutory Authorities, NGOs and individuals.
We have attended all exhibitions, and made many requests for additional information. Some of the suggestions and matters in the Consultations have been considered and some changes made but in total, these changes do not substantially alter the fact that information across all four consultation stages has been sparse and insufficient for informed decisions to be drawn.
Major requests and concerns have been ignored or brushed aside. This is particularly true on environmental matters, including the EIA which we are told we will see at DCO stage. To make a proper appraisal, the facts and evidence are key; without them it is just guesswork. It is the developer’s responsibility to provide the consultees with proper researched facts to make sure all matters can be considered thus enabling a good judgement to be made. Many such matters have still not been addressed.
TASC requested better mapping which should include ordnance survey grid lines, road numbering and contour lines. It has been difficult to fully comprehend where roads, rail lines and suggested storage facilities and off site lay-up areas are sited without the proper mapping.
This has never been addressed
We have stated many times that this site is unsuitable because of its situation in the AONB, SSSI and other designations, the proximity of the SZB station and the encroaching North Sea. The policy in NPS EN6 states it that Sizewell is a “potential site”. It is TASC’s belief that, to date, EDF have not proven that the site is suitable. In fact quite the reverse. To build the two EPR reactors and all other buildings required for its operation on a 32 hectare site means the situation is intolerable in this unique position. Even when operational it will appear cramped and a blot on the landscape.
The fact that some SZB buildings which are on the SZC land have to be demolished is proof that every centimetre of land is required. It was hoped that EDF would recognise this for themselves after the 2nd Consultation when it became clear just how much land would be needed to create two nuclear reactors in such a remote area of East Suffolk. Instead they have continued to try to make it plausible by taking more of the SSSI and pushing the eastern berm nearer to the North Sea.
This ignores any due regard to the sensitivity of the main SZC Nuclear Site and the area it will occupy. We can have no comprehension of the total area required for such a massive undertaking without a visible floor plan, indicated by a substantial map, Without such a map, it leads to major concern about development creep. We have asked EDF many times for such a plan and have recently been told by SCC that they, too, have not had sight of a comprehensive plan.
EDFE say that such a plan will be available for DCO. But how are we to judge what proportion of AONB and SSSI will be lost if this information is not available now in the pre application period? It indicates to us that EDFE have little knowledge of how the site will be set out to contain all the buildings and facilities during the build program and subsequently when the station is completed and operational.
Where is the Dry fuel store to be placed? Where is the new sewage works, how is the sewage to be managed and where is its discharge point? The same questions apply to the dewatering of the site. The four pylons which will scar the landscape and which are apparently necessary to feed into the National Grid were not considered until Stage 3 of the consultation. We do not know the outcome.
It has been suggested that many such details can be wrapped up in the ‘Rochdale envelope’. We question this assumption.
This information must be made known to allow consultees to arrive at informed opinions. None of this type of crucial information should be allowed to be wrapped up in the Rochdale envelope at DCO stage.
The Duty of Regard for the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB) has not been taken into account and neither has the integrity of the Site of Special Scientific Interest (SSSI).
SZC Flooding and CO2
Since the Government has declared a Climate Emergency, TASC believes EDFE should have appraised consultees with facts and figures of likely scenarios for sea level rise, storm surge, unusual rain fall and weather patterns for both coastal and fluvial flooding using the latest predictions during the pre–application stage.
a)With its front loading of 12 years of CO2 emissions over the period of the 12 year of the building programme how is this helping the Government to achieve its target of zero CO2 emissions in the given time scales?
b) An in depth study of the worst case scenario of both sea and fluvial flooding should have been undertaken, we are told EDFE can build defences to protect their site. Without a full study of the East Coast north and south of SZC which is already under threat, we are once again guessing at the possible outcomes over the period of time the site has to be protected, particularly if it is by hard defences.
If protecting the SZC site means damage to the extended coast, we need the evidence to show how any further coastal erosion will be paid for and managed. Fiscal policy should be put in place so that damage to the coast caused by SZC defences is not a burden on the public purse.
Permanent Access Road 2.2kilometres
TASC has a major criticism of the project which is that of the proposed Permanent Access road. Its position is solely for the convenience of EDFE. No alternatives or options have ever been considered.
TASC asked that other options be considered at Stage 1 response. This request has never been addressed.
Some minor changes to the alignment to accommodate bats was undertaken. However, the concerns for the fragmentation of the AONB dissecting corridors for wildlife has never been considered by EDFE as a cause for a major change to the access route.
The access road in this position will lead to the SZC site via a new Culvert over the SSSI and water courses. This is in itself is a real concern for many consultees. The dual carriageway will carry all vehicles to and from the SZC site. At present the management of water on Sizewell Belts and Leiston River and on Minsmere Levels is pivotal at this location. This delicate management of water which is essential for both Sizewell Belts and Minsmere Levels is yet not understood or proven to be viable. We are aware that EDF requires the acquisition of 12 hectares of SSSI in this area.
EDFE should not be allowed to dictate their needs over the requirements of the precious habitats, they have not proven that what they intend to do will not seriously damage, disrupt and disturb these unique marshy areas. Much more investigation should have been undertaken. Mitigation is not an answer.
Other matters which emanate from the proposed permanent position of the Access Road which are totally inappropriate with the AONB designation are:
Lay up area close to RSPB Mismere 24/7
Batching Plant close to RSPB Minsmere 24/7
Rail line unsure of route
Borrow Pits routes to site unknown, quantites and qualities unknown
In total as far as we can ascertain the total land take for the above is 350 hectares, which may include land east of Eastlands Estate (LEEIE).
Whereas NPS EN6 states the nominated site area is 117 hectares.
It is a failing of EDF not to acknowledge that many consultees are gravely concerned by the implications of the damage which will be caused to the AONB SSSI and the high conservation value of this area.
Alternatives and Options should have been considered.
We have also asked for details on routes and quantities of the transportation of aggregates, steel, and all materials on and off the site. We still have had no satisfactory answers. EDF have as yet to tell us where the materials are to come from meaning there is no possible way of assessing which routes are to be used.
Lack of information
Sizewell Beach Area
TASC requested more information on how the route over the SAC (Bent Hills and Heritage Coast with vegetated shingle) was to be managed. The consideration for the jetty has been withdrawn.
However, any materials coming to the SZC site will still need a route from a beach landing facility to SZC site over this sensitive area. Sadly this is still a totally unknown factor including any lighting facilities.
This intrusion will compromise the Heritage Coast Path, soon to become the English Coast Path. This is an important matter for the many tourists and local people who use the area for quiet recreation.
More detailed information has never been given.
Further Observations and Unanswered Questions
Following on from Stage 3 and Stage 4 when so many questions were asked, More details are still not forthcoming (see TASC Response 4th Consultation page 6, and Response to Stage 3 requesting much more information).
These include the following
1)Total lack of EIA information. Not available till DCO.
2) Replacement mitigation for Fen meadow SSSI. Far too little information on either Site 1 or Site 2. No evidence to prove the assumptions.
3) Replacement habitats for Marsh Harriers. No evidence
4) The Fish entrainment at the cooling water intakes is still unknown. (Hinkley C proposals is still under discussion and not agreed.)
5) Potable Water quantity and source is still unknown and still under discussion.
6) Beach frontage. The Green Line as agreed for SZB is not being adhered to, the berm is too far forward of this agreed green line. How is this to be addressed?
7) Traffic Management Plan for Leiston Town. Traffic management and how to accommodate the influx of employees?
8) The socio-economic case only points out the perceived gains but says nothing of the loss particularly for a decrease in house and business values. Not enough detailed socio-economic information.
9) Town Water availability during build and operation. This information is crucial in this dry region, where water for farms may be restricted
10) Storage of Waste (Spent Nuclear Fuel)
11) Footpaths and Bridle ways
All of the above and many missing and unknown elements show that the four consultations undertaken have been inadequate and that not enough attention has been paid to the comments and concerns expressed by those who were consulted.
Many of these points have been raised in writing by TASC at the four stages of Consultation. None have been adequately answered.
We remain of the opinion that on the flimsy evidence so far revealed it still appears that the many dis-benefits which will accrue from the planned Sizewell C development far outweigh any perceived benefits.
TASC therefore respectfully request that when EDFE submits its DCO Application, PINS takes into consideration TASC’s concerns and unanswered questions and the inadequacy of the Consultations when undertaking its duties regarding the acceptance or rejection of the EDFE DCO.
Joan Girling Secretary for and on behalf of TASC (Together Against Sizewell C )
Cc EDFE Mr Paul Morton SZC Project Director firstname.lastname@example.org
East Suffolk Council, Suffolk CountyCouncil. Environment Agency.
TASC Response to the Nuclear Regulated Asset Base Consultation
Thank you to TASC members for this response
A PDF of the TASC submission to the Regulated Asset Base (RAB) Nuclear Consultation can be downloaded here
A PDF of the Appendix to theTASC submission can be downloaded here
Just one major problem with the Sizewell C plans is that nuclear new build projects have been largely a financial disaster. Almost every major nuclear project in the West has been plagued by delays and cost overruns: Some delays are in the order decades. Likewise, the cost overruns are of epic proportions. Some new-build projects have had cost overruns that run into billions.
Changing the funding method for the planned Sizewell C to a regulated asset base model would shift the risk of rising costs from EDF to consumers, and could lead to even worse project planning because the existing RAB model would offer little incentive for EDF to build on-time and on-budget. EDFs investment is safe regardless, and we wind up footing the bill no matter how incompetently EDF proceeds.
The RAB Consultation ends on MONDAY OCTOBER 14th 2019, so if you wish to submit a response, the link is here:
Working with Communities – Implementing Geological Disposal
TASC Response to BEIS EN6 National policy Statement consultation
There was an expectation that by now the ‘nuclear renaissance’ would be well underway. However, to date only Hinkley Point C has been granted a development consent order. It is possible that Hinkley will be online by 2025, but there is no chance that any of the other proposed sites will be anywhere near completion, if indeed any are started, by the 2025 deadline. Therefore the government has had to designate a new nuclear National Policy Statement to facilitate nuclear power stations at sites capable of deployment between 2026-2035. The current list of potentially suitable sites (including Sizewell) will be carried through to the new National Policy Statement subject to them meeting the updated siting criteria and environmental assessments.
The purpose of the consultation is ostensibly to seek views and suggestions to enable the government to develop the criteria to assess which sites should be included in the new National Policy Statement.
TASC has written a comprehensive response for the consultation. A pdf of it can be found here.
Tasc also wrote a preamble which can be downloaded here. The text of the preamble is as follows:
TASC Response to BEIS EN6 NPS 2026-2035 for Nuclear Power above 1GW
- TASC and others have demonstrated that there is no need for new nuclear.
- All objectives, ie. security of supply, cost and low CO2 can be met without new nuclear. TASC do not agree that nuclear is low carbon throughout its lifetime. TASC Documents proving this lack of need were sent to the Secretary of State in May 2017. Neil Crumpton and Andy Blowers paper of June 2017 and the BEIS/NGO policy forum paper 17 th July 2017.
- TASC remit is to oppose the construction of Sizewell C, however we have found it essential to address the whole policy because of many questions and unsubstantiated claims. Nuclear development, already, in our opinion, fails 19 out of the 20 criteria for environmental protection themes detailed in Scoping opinion page 22, making it completely unsustainable and totally unjustified.
- TASC submit EN6 should be revised in conjunction with assessment of need. This should occur with a revision of all other policy statements, EN1,2,3,4 and 5. We believe an assessment of carbon emissions for each technology for all aspects of construction, operation, decommissioning and waste management, should be made by an authoritative expert. This may also be a requirement of Directive EU2014/52.
- Special attention must be made to the importance and consideration of EN5 Grid connection, concurrent with both EN6 and any other large scale generation requiring new grid connections and/or use of interconnectors. We were interested to learn that the proposed Hinkley Point C grid connection has been declared unsustainable by National Grid. We also note that offshore wind may require DC current connections to the grid which may best be served by marine cable.
- The minister is required to ensure that policy is appropriate. (EN1 ref 1.6.1). As EN1 is the overarching policy to which all other policies refer it is essential that EN1 is revised. So that other policies are in accord with EN1, including use of hydrogen, biogas and digesters, smart technology, electric vehicles and use of smart connections, improved efficiency of other technologies especially wind, solar and tidal power. For example at EN1 2.2.20 it is claimed energy storage is not possible. This is now disproved. The use of electric vehicle batteries to back up local grids is also evolving and urgently needs an agreed specification.
- TASC recognise the need for a mix for electricity provision. It appears perverse not to progress technology for carbon capture, particularly for coal and gas. Carbon capture techniques are also beneficial for other manufacturing processes. This is an evolving technology and many papers are written on the benefits of capturing CO2.
- The special nature of nuclear requires full and unequivocally to conform with EU Directives particularly all of EU2014/87 EURATOM BSSD (which takes account of Fukushima) and EU2014/52 Environmental Impact Assessment. This should include all sub directives. Ionising regulations and other safety standards. Health records and the potential impact of multiple sites. The Justification under the Ionising Regulation should be carried out on a site by site basis.
- We do not agree with the statement that we have an effective and robust regulatory framework. We consider we need one regulator to fully conform to EU directive 2014/87 and they should not be bound by the existing “Regulators code”. Any Regulator should be open to scrutiny, peer review, independent qualified experts and allow full public consultation. We consider it is not unreasonable to call for cross referencing of EU directives in the revised NPS so as to ensure that all directive requirements are fully considered. The importance of this is because EU Directive 2014/87 which was the result of Fukushima, calls for the need for improved European co-operation and standards and resulted in a major action plan for the existing EDF fleet. The Japanese earthquake response programme is available at:-https://www.edfenergy.com/sites/default/files/japanese_earthquake_response_programmes_final_report_to_the_onr.pdfIt is not clear how or if the strengthened safety and siting criteria were transposed into the current EN6. The Emergency Response Centre constructed by EDF for Sizewell B in Leiston Suffolk, is intended to be available 24/7 to supply immediate safety response. It is unclear however if this is a site licence condition. The need for an Emergency response centre should be considered for each site. It is generally believed that Dungeness was removed from the list of original sites because of high flood risk allied to environmental impact. Eu Directive 2014/52 has been a major revision to the Environmental Impacts Directive, the first revision in 25 years. We will attempt to show in our response to the BEIS criteria where we would expect the EU Directives to be fully considered.
- TASC do not agree with the statement in the existing EN6 at 2.11.1“that effective arrangements will exist for the management and disposal of the wastes produced by new nuclear power stations” The use of high burn up fuel, necessary to ensure nuclear power is “cost competitive”, is believed to cause significant problems. The issues associated with use of high burn up fuel are outlined in the following paper by the late Hugh Richards:- http://www.no2nuclearpower.org.uk/reports/TooHottoHandle.pdfAt this stage we also believe there are sufficient concerns with legacy spent fuel (high level waste), in France and Sweden to question whether “disposal” is an option. Government were clearly warned about legacy waste problems in the Flowers report 1976 Conclusion 504 http://davidsmythe.org/nuclear/flowers%20commission%201976.pdf and referred to in volume 3 38.31 of the Layfield inquiry into Sizewell B held1983-85. We note that the UK regulators are unable to be certain how spent fuel from new nuclear could be safely disposed of or stored. See following link. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/301502/geho0510bsjt-e-e.pdf The reference in this link for the UK EPR, is Flamanville 3 which is delayed from going into generation and it may be that the characteristics of wet and dry storage of new nuclear spent fuel cannot be verified for some time. We believe that it is morally and ethically wrong to consider commencing nuclear new build when the spent nuclear fuel could have no safe disposal route. We submit that if costings for new nuclear are based on flawed assumptions about the type of fuel, allied to the use and ultimate storage and disposal of high burn up fuel, this needs a thorough investigation. The so called fixed price deal for waste and decommissioning may certainly prove to be underestimated, with a potential for great loss to the taxpayer.Additionally.
- The consultation for revised NPS must be in conjunction with all regulators, including the ONR, EA, DEFRA and PHE in a fully open and transparent manner as decreed by EU Law. Those regulators should be sufficiently resourced.
- Claims made in support of nuclear need to be readdressed in the light of new evidence including “low carbon” and “60 year lifetime”. These claims are so important that we consider there should be an independent inquiry into both claims as they are being used to justify a policy which has dis-benefits many of which outweigh any public good. Nuclear plants suffer from internal stress corrosion caused by high pressures, temperature and chemical attack.
- The sites which exist in the present EN6 should be re- considered beyond 2025. Some were only included because of the urgent need before 2025 This should therefore exclude Bradwell, Hartlepool, Oldbury and Sizewell for flood risk alone. Other environmentally damaging sites were justified because of the need before 2025. EU Directive 2014/87 http://www.onr.org.uk/documents/2017/council-directive-2014-87-euratom.pdfHelpful explanation of EU Directive 2014/52
Report From Together Against Sizewell C Requires New Secretary Of State To Review Nuclear Component In Energy Polic29 JULY 2016
Greg Clark, the newly appointed Secretary of State for Business, Energy and Industrial Strategy, has received a report compiled by members of Together Against Sizewell C (TASC), a Leiston-based organisation opposed to the construction of another nuclear plant at Sizewell in Suffolk, which clearly and unequivocally demonstrates that the nuclear component of the energy policy being pursued by the government is unnecessary.
The report argues that the data upon which the original policy was based has changed so fundamentally over the last few years that a review of the National Policy statement as expressed in EN1 is obligatory under Section 6 of the 2008 Planning Act. All government targets can be met without the nuclear component and TASC urges the Secretary of State to re-examine the policy and amend it to remove controversial, costly, dangerous and politically toxic nuclear power from the mix.
TASC’s report (Nuclear Power: New Evidence – A call for a statutory review of the Overarching National Policy Statement for Energy (EN-1) made pursuant to Section 6 of the Planning Act 2008) is accompanied by a letter from lawyers Leigh Day who are acting for TASC.
Pete Wilkinson, TASC’s Chairperson, said today, ‘We are putting the government on notice that it has an obligation to examine the energy situation in the UK very carefully. The years of uncertainty and controversy which have surrounded Hinkley Point C’s proposed development have left the country confused and bemused. Component paperwork falsification, terrorism, emergency evacuation concerns, health issues and a host of other problems which nuclear power faces must surely cause the government to doubt the wisdom of including nuclear over the rapid development of decentralisation, renewables, efficiency and renewables/appropriate technology.
‘TASC did what the former DECC has asked us to do: look at the ‘pathways’ section of its website and construct more sensible and workable energy options. We urge Greg Clark to read the report and come to the conclusions that we have: we do not need nuclear power and it is time to abandon nuclear.’
Secretary Of State Amber Rudd Faces Legal Challenge To Review Nuclear Decision
(the full submission can be downloaded here)
October 12th 2015
The legal requirement for the Secretary of State for Energy and Climate Change to review the original 2005 decision to include nuclear power in the UK’s future energy programme has been set out in a document prepared by members of Together Against Sizewell C (TASC), and has been delivered to Secretary of State Amber Rudd on two occasions over the past two months. At the time of writing, TASC has received no reply from Ms Rudd.
The document, (Nuclear Power: New Evidence: A call for a full-scale statutory review of the Overarching National Policy Statement for Energy (EN-1) made pursuant to Section 6 of the Planning Act 2008 – attached) demonstrates unequivocally that the Secretary of State has a legal obligation to review the policy which was derived using 2005 data and that the accuracy and importance of that data has significantly changed in the last decade to the point where it no longer justifies the choice of nuclear power as part of the energy mix. In fact, using figures from the Department of Energy and Climate Change’s own ‘Pathways’ website, TASC has shown that, far from helping to achieve government energy objectives, the inclusion of the nuclear component will:
- risk ‘the lights going out’;
- waste £billions;
- be less effective in meeting energy policy objectives than a more ‘demand-side-led’ strategy; and
- leave the ‘urgent need’ for new electricity supplies that the Government claims are necessary unmet.
TASC has undertaken and completed the task which DECC has now invited people to carry out: i.e. review its energy ‘Pathways’ options and to arrive at their own energy mix while meeting climate change, cost and infrastructure targets. The pathways constructed by TASC all avoid a nuclear component, the inclusion of which has been deemed essential by successive governments. The TASC pathways, based entirely on DECC’s own data, demonstrate that the reverse is true. Far from making government policy easier to achieve, nuclear power’s inclusion in the energy mix will hamper successful policy implementation.
The pathways identified by the TASC document, will, without exception:
- cost the country less than every single government Pathway;
- more successfully ensure energy security (‘keep the lights on’) than every government Pathway because they rely on less imported energy overall, less imported fossil fuels and less imported oil
and gas in particular;
- use less energy overall and less electricity in particular;
- involve a (slightly) greater diversity of energy supply;
- more successfully achieve the need to balance demand and supply of electricity at all times;
- achieve an 80% reduction in CO2 emissions by 2050;
- rely on less use of fossil fuels;
- ensure warmer homes at less cost;
- cause less air pollution and less damage to human health.
In a cover letter to Amber Rudd, TASC requested a reply to their document within two weeks of its delivery. TASC has received no reply from Amber Rudd to date.
Should the Secretary of State refuse to acknowledge the legal imperative conferred on her by Section 6 of the Planning Act 2008 to review the National Policy Statement EN-1, she will be in receipt of a letter from TASC lawyers asking her to justify her silence on this matter since the 7th July when she was originally sent the document.
Pete Wilkinson, Chairman of TASC, said today, ‘The government has a legal obligation to justify its increasingly bizarre and incomprehensible obsession with nuclear power which is undeniably a costly and environmentally damaging option which we can do without, as our document and as DECC’s own data demonstrate.
‘It has fallen to TASC to pursue Amber Rudd to ensure the government meets its legal obligations to review the National Policy statements for Energy. We expect a swift and constructive reply from Ms Rudd as we do not wish to invoke the force of the law. However, if required, we will do so in the interests of putting this country on a path to a sustainable, equitable, affordable and environmentally benign energy programme which will avoid further security risks such as the red alert status currently in force at Sizewell B and which will spare host communities the disruption caused by a protracted construction period, the prospect of leaving their homes in the event of an accident and the need to pass on to their children the nuclear waste legacy which we will create if we allow this misguided policy to come to fruition.’
TASC will send yet another copy of the report to Amber Rudd in the near future. It has also been sent to the Select Committee on Energy and Climate Change and is being widely distributed to opposition political parties, media and anti-nuclear organisations.