Fresh Water

The construction and operation of Sizewell C would require 2000,000 litres (2 ml)/day) of fresh potable water. This would be necessary throughout the operational lifetime of the plant and beyond, as some of this water is also needed to maintain the cooling ponds.

At each of the 4 stages of the public consultation process which spanned over 6 years (March 2013 to July 2019), concerns about where this water would be sourced from and the effects that this high level of abstraction would have on the environment and existing users were raised by many respondents including Leiston town council. However EDF omitted any mention of potable water in the consultation documents. This is in spite of the fact that EDF has an obligation under the governments National Policy Statement for Energy to submit an Environmental Statement (ES) as part of the Development Consent Order application. The Environmental Statement must provide details of the impact that taking this much water will have on existing water resources:

According to the national policy statement:

The ES should in particular describe: …existing water resources affected by the proposed project and the impacts of the proposed project on water resources, noting any relevant existing abstraction rates, proposed new abstraction rates and proposed changes to abstraction rates (including any impact on or use of mains supplies and reference to Catchment Abstraction Management Strategies)1 EDF is also required to set out their strategy for mains water use in order to comply with The Suffolk Ecology Principles for Sizewell C, which state:

“The anticipated levels of water use and a suitable potable water source for the development must be
identified to ensure there is adequate capacity and that this can be achieved in a sustainable manner
that will not have an adverse effect upon river flows or wetland sites.2

In order to provide an accurate overarching forecast of the major infrastructure projects and investments that will be needed to fulfil the future UK economic and social requirements, the government established a National Infrastructure Commission as an executive agency of HM Treasury in 2017. The remit of the NIC is to deliver fully costed projections and plans to meet the UK
infrastructure needs going forward. The NIC has made careful assessments of our available natural resources and calculated the impact of factors such as climate change and population growth on those resources. With regard to water, the NIC suggests that within the next few years we are going to run short of fresh potable water in the UK as a whole, and in East Anglia, the most arid region of the UK, in particular. With regard to England and Wales, it states that maintaining the current levels of
resilience to 2050:

“would require additional capacity of about 2,700-3,000 million litres per day (Ml/day) An additional shortage of between 600 and 800 Ml/day would result from a severe drought (0.5% annual probability), and between 800 and 1,000 Ml/day in an extreme drought (0.2% annual probability).” 3

Given that the water supply is so crucial, a variety of other studies, plans and projections have been undertaken. The Water Resources Long Term Planning Framework Water UK 2015-2065 published in 2016 took an overarching view of the water resource management plans of the different water companies in the UK. With regard to East Anglia it recognises that there will not be enough water in this region within the next few decades and the solution that has commonly been put forward is the
strategic transfer and storage of water from the River Trent.

The framework cautions that:

“There are a number of significant potential costs and constraints that would be involved in transferring, treating and storing water from the Trent that mean it is not currently possible to identify the most appropriate approach for doing this” 4

In line with the 2008 Climate Change Act, the UK Government is required to publish a climate change risk assessment (CCRA) every five years. The assessment sets out the risks and opportunities facing the UK from climate change. Concerns over maintaining the water supply were included in the Climate Change Risk Assessment published in 2017 (CCRA2) which suggested that risk of shortages in the public water supply, and for agriculture, energy generation and industry is the 3rd highest risk we face. (Flooding is the first)

The following is from the CCRA2: Updated projections for water availability for the UK Final Report:

“Summary Overview: The high level results indicate that in the present day, assuming that current EFI (Environmental Flow Indicators) thresholds according to existing regulatory approaches are met; levels of abstraction demand already exceed the available water resource in some catchments. This is particularly the case in the south and east of England” 5

“Under the upper bound scenario (high population growth and a high climate change impact) for the 2050s, without any additional adaptation, there is a widespread pattern of large deficits in the provision of public water supplies. In particular, large deficits are projected in the south-east of England”

This rather bleak scenario is echoed by the Environment agency. According to the East Suffolk abstraction licensing strategy 2017:

“The confined chalk groundwater in the East Suffolk area is fully committed and no further consumptive abstraction can be considered.” 6

It is evident that maintaining an adequate water supply in East Anglia, even with moderate climate change and population growth factored in, is going to be a difficult task, and one that may be physically and practically impossible to do.

Like all water companies, Essex and Suffolk Water (ES Water) are obliged to draw up a periodic Water Resource Management Plan (WRMP) outlining their resources and infrastructure plans. The Essex and Suffolk water Draft Water Resource Management Plan published in March 2018 acknowledges that there is little scope for more water abstraction from this area:

“The Essex and Suffolk supply areas are located within some of the driest areas of the country and as such face particular challenges including growing demand , uncertainty from climate change and a general lack of new intrinsic water resources” 7

ES Water also acknowledged that in order to maintain the environmental standards set out in legislation, they may be required to actually reduce the amount of water they are allowed to abstract

“Operating in the driest part of the country, with increasing demands on current supplies of fresh water and the potential for sustainability reductions being applied to the Company’s abstraction licences, ESW recognises that “new” water for potable supplies will be difficult to come by.” 8

It is clear that if new water sources are necessary these will be expensive and create a large carbon footprint:

“For some East Anglian region water companies, supply – demand deficits by 2060 will become more widespread, .. Since there are no resources available for year – round direct abstraction, options for developing these will be limited to winter storage reservoirs, water reuse schemes and aquifer storage and recovery. All of these have high CAPEX , OPEX and carbon requirements.”

(CAPEX is Capital Expenditure, OPEX is Operational Expenditure).

However, at that point ES Water were confident that they had no need to seek new water sources and that they had sufficient surplus to supply Sizewell C

“Distribution Input forecast includes the potential demand of ~2Ml/d from the proposed development… Suffolk Blyth WRZ baseline supply demand balance with proposed development. This shows that a supply surplus is still maintained across the full 40 year statutory planning period“ 9

In September 2018 ES Water published the Draft Water Resources Management Plan Statement of Response which contained feedback from consultees on the Draft Water Resources Management Plan.

EDF was one of the consultees and their response clearly states how much water would be required by Sizewell C as well as the proposed new nuclear power station Bradwell B station in Essex that EDF /CGN also plan to build. They wished to have both projects specifically included in the Water Resource Management Plan in order to be able to include the water source in the stage 3 consultation:

“EDF/CGN is proposing to construct and operate new nuclear power stations to be known as Bradwell B in the Essex WRZ and Sizewell C in the Suffolk Blyth WRZ within the 2020 – 2060 planning period. The developments will each require an estimated 2Ml/d supply of water. EDF/CGN request that the demand for Bradwell B and Sizewell C power stations be specifically identified within the WRMP. The inclusion will provide greater accuracy and assist at future stage when EDF/CGN undertakes further public consultation prior to submission of Development Consent Order applications to National Infrastructure Planning.” 10

So up until mid 2018 EDF believed that the water would be supplied from existing sources by ES water. Unfortunately for both companies, the Environment Agency (EA) disagreed with ES Water because the abstraction needed for Sizewell C would breach environmental standards set by the Water Framework Directive.

It is interesting to note that in their response ES Water acknowledge another recommendation made by the NIC, namely that only one new nuclear power station is planned for. EDF, of course, have plans for new power stations at both Sizewell and Bradwell.

ES Water Response to EDF’s feedback in the Draft WRMP:

“EDF and ESW met on 14 May 2018 and again on 15 June 2018 with the Environment Agency to discuss Sizewell C water supply and demand. The EA has highlighted that including the 2 Ml/d of additional demand from Sizewell C in our final plan distribution input forecast would mean that there would be a sustained increase in overall  abstraction. As the aquifers from which we abstract in the Blyth WRZ are not meeting the Water Framework Directive “good” status, we then would not be able to demonstrate compliance with the Water Framework Directive “No deterioration” test. The EA has asked that we illustrate, through an additional supply demand balance scenario graph, the effect of the additional Sizewell C demand but with the supply line (known as Water Available for use or WAFU) being based on recent actual abstraction (i.e. the maximum annual abstraction between 2005 and 2015). We have completed this work which shows (Section 11.3.2) that capping abstraction licence annual licensed quantities at recent actual levels causes a supply deficit and the need for a new supply scheme. Our view continues to be that there remains significant uncertainty regarding the start date and as such it would be wrong to include it in our final plan now. Our view is supported by the National Infrastructure Commission’s (NIC) recommendation to Government that there should only be one more nuclear power station constructed in the country… As the EA has said that for the purposes of the WFD no deterioration test we would have to cap our abstraction licences at recent actual volumes, we would not comply with the no deterioration test. Consequently, we would have to develop a new supply and or demand scheme albeit that the cost of this will have to be funded by EDF. We have communicated our position to EDF.” 11

EDF have an obligation to demonstrate where they will get the water supply from and an obligation to prove that it is sustainable and will not impact on the environment or water supply for other users. To date, they have completely failed to do this and have instead attempted to brush the issue aside and fob people off who have asked about it instead of admitting this problem in an honest and open way during the consultation.

The 2000,000 litres per day for Sizewell C would be in addition to the 800,000 per day that is already taken for Sizewell B which is obviously a huge commitment of our precious water resources. There have been instances in the past in times of drought when Leiston residents have complained about the quality of their water because of course, regardless of drought conditions or water shortages it is of primary importance to maintain the supply to Sizewell B in order to keep the fuel in the cooling ponds safe.

In Cumbria campaigners have claimed that the supply of good quality water from Ennerdale Water and Wastewater is taken by the Nuclear Decommissioning Authority for Sellafield’s cooling and processing, whilst the water supply for 6000 local people is mixed with poor quality borehole water that is, according to the locals, making people ill. 12

E S Water deny that if they were to supply the water to Sizewell C that there would be any impact on the water quality for the population. We can only hope that they are right, though trust in water companies is not high.

An article in the spectator in 2017 pointed out that privatised water companies

“promised to bring efficiency. Instead they have brought unsustainable levels of debt that, one way or another, the public will have to redeem. Researchers at Greenwich University say that in the past decade, the nine companies have made £18.8 billion of post-tax profits. Far from using the money to make the water system better, they have paid out £18.1 billion in dividends, and financed investment through loading £42 billion of debt on to consumers.” 13

For the past six years EDF have been extremely evasive in relation to questions relating to fresh water use, and so it is still at this late stage, unclear as to where the water will come from. It is essential that plans by ES Water and EDF are made available to the public and rigorously scrutinised prior to the granting of a Development Consent Order, and if a secure and plentiful water supply is not forthcoming, EDF should not be granted permission to continue with their plans for Sizewell C.