Overview of Concerns
The parishioners of Oldbury on Severn are not resourced to respond to a consultation of this style and nature. However, the significance of what is proposed by the policy statements, particularly EN6, on the day to day lives of our Parishioners (specifically Shepperdine) and adjoining parishes is of such magnitude that special effort has been put into our response. Considerable time, community involvement and analysis have been used to prepare the formal response in the hope that the consultation documents will be amended to reflect our concerns prior to designation.
The key issues of our concern include:
1. The way the consultation documents are written.
2. The possibility of dismissing valid reasons for refusing a development application
3. The lack of correlation between geographic power supply and demand in site selection
4. The “one reactor” basis for the Appraisal of Sustainability and Habitats Regulation Assessment
1. The way the consultation documents are written
We have little faith that the IPC process will result in an unbiased outcome. The NPS’s will be the prime documents guiding the IPC through the evaluation process, but they over emphasise the need for more Generating Capacity and advise that the presumption should be in favour of development.
2. The possibility of dismissing valid reasons for refusing a development application
Following directly from 1. above we are led to the conclusion that the IPC process could become more about mitigation, even stifling arguments which could show that adverse effects should preclude development. In this regard we note that the policy of Imperative Reasons of Overriding Public Interest can be applied to dismiss all other reasons for refusing a development application.
3. The lack of correlation between geographic power supply and demand in site selection
We feel that the SSA was not really strategic in so far as the sites were nominated by Commercial Interests. Whether or not the sites selected are the best choice we are not qualified to say, but there seems to be little correlation between geographic supply and demand.
Continued on page 5
4. The “one reactor” basis for the appraisal of Sustainability and Habits Regulation assessment
The assessments which provided the basis on which the SSA made its recommendations for Nuclear Sites were at a high level; so much so that its results must be considered as very questionable. EN6 admits that the Appraisals of Sustainability and the Habits Regulations Assessment were done on the basis of one reactor at most sites. This, we feel, is significant as it leaves it to the IPC to judge the suitability of the sites on this basis. With the guidance in the Policy being biased toward acceptance this is worrying when coupled with the issues the Policy states are not the concern of the IPC.
As far as Oldbury itself is concerned the main issues are as follows:-
Visual and Landscape impacts cannot be fully mitigated particularly because the use of an Indirect Cooling System involves the use of structures which cannot be hidden. Cooling Towers, whatever the design, will have negative visual impact. Oldbury is the only site requiring this technology. The footprint and mass of the proposed new Facility will be very significantly greater than the existing Magnox facility. Being the only estuarine site, Oldbury is unique in so far as the negative impacts can be easily seen from both the English and Welsh sides of the estuary which is in an area of Outstanding Natural Beauty and is classified as an area which has gained National and International recognition (RAMSCAR etc).
Flooding is a major concern. Again, the area is unique in so far as it is in Flood Zone 3 and has characteristics which have led the Parish Council on many occasions to try to persuade the local authorities to fund improvements. Whilst it is recognised that any threat from the River Severn should not be underestimated, it is Internal flooding caused by run-off from development which is our main concern. The fact that a new facility at Oldbury would be built up onto a higher level is a concern not only in terms of flooding but also because access roads would have to be raised accordingly. This again would have an adverse visual impact in this low lying area.
Infrastructure. In particular the local roads can be realistically described as inadequate and in need of repair, but going further afield to the M5, the vision is that everyday will be like a Bank Holiday (or worse) in terms of traffic and traffic congestion. The area is ill equipped to handle the potential volumes of traffic, irrespective of the possibility of a wharf. The adverse impacts resulting cannot be fully mitigated.
Arrangements for the disposal of radioactive waste are a concern, but it is also an area where we do not have the technical competence to address the issue in depth. Suffice it to say that locally there are serious concerns and doubts as to the arrangements as described in EN6, particularly relating to long term on-site storage and the Governments approach to final disposal. For example, we are aware that successive governments have signally failed to get agreement on a geological repository over nearly 40 years of trying.
Continued on page 5
How can we have any faith in the volunteering process that is now being considered? The fact that the IPC is not expected to consider storage as an issue during their assessment process is again a factor which reduces confidence in the IPC process.
Cumulative effects of other major infrastructure projects, all within the Bristol Channel/Severn catchments, have not yet been taken into account. We have serious concerns for the future of the estuary because there is still no clear understanding of what else may become part of the mix of energy sources, particularly in respect to tidal power. Power distribution for Nuclear and Tidal generated power will be a big problem.
The development of a new nuclear power station, if it goes ahead, will change the character of Shepperdine and the surrounding area out of all recognition. The adverse impacts during construction will be extremely difficult to bear, even with mitigation. This will not necessarily improve during the operational stage, as it is committing the local community to a different way of life, and, if Development is permitted, some form of compensation which recognises this must be forthcoming.
Thursday 18 February 2010
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