Rockhamptons Submission to DECC

ROCKHAMPTON PARISH COUNCIL




CONSULTATION ON DRAFT NATIONAL POLICY STATEMENTS FOR ENERGY INFRASTRUCTURE



COMMENTS SUBMITTED 18.02.10





Question 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?



Answer: No.



• The Statement does not provide any tangible criteria or Principles, against which the overall cumulative dis-benefit and/or risk associated with a proposed development can be weighed against the benefit.



This is of particular relevance to the proposed development at Oldbury, where significant dis-benefit/risk is apparent, and yet no specific or unique benefit of the site has been identified.



• The Statement does not set down any tangible criteria or Principles against which a justification not to pursue all potential mitigation measures can be assessed, eg a test of reasonable practicability, or gross-disproportion, with respect to the time, trouble and cost.



This is of particular relevance to the proposed development at Oldbury, where significant levels of mitigation might be required in respect of visual impact of cooling towers and likelihood of flooding.



• The Statement seemingly provides guidance to the IPC on the basis that each application is to be considered in isolation. Thus any dis-benefit accruing from overall development of the national energy infrastructure will not be minimised, and individual applications may be granted, or refused, on the basis of incomplete or partial information.



This shortcoming is of particular relevance to the proposed development at Oldbury, as there are several less sensitive/contentious sites elsewhere in the country that are not being actively pursued.



Question 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?



Answer: Yes, but the question is irrelevant.



• Decisions regarding the nature and pace of the development of new energy infrastructure are being and will continue to be taken by the generating companies on the basis of their commercial objectives.



Question 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?



Answer: No



• See the answer given to Question 2.



• Most of the direction/guidance given in relation to any ‘assessment princples’ is of a general, subjective, and qualitative nature, which leaves considerable scope for interpretation and judgement by the IPC. No guidance is given on how to consider the cumulative dis-benefit of any proposal, or on the weighting that should be given to each aspect.



• There is seemingly no requirement for the IPC to consider whether development of an alternative site would be in the public interest, or to seek Independent Specialist advice on impacts associated with the Discretionary criteria of the SSA.



Question 7: Do you have any comments on any aspect of the draft Overarching Energy Policy Statement not covered by previous questions?



Answer: Yes



• The Overarching Energy Policy Statement does not include any requirement to minimize, as far as reasonably practicable, the overall harm/cost associated with measures taken to secure reliable energy supplies for the country into the future. Decisions regarding the location, scale, scope and nature of individual energy infrastructure developments can therefore seemingly be made on the basis of arbitrary or commercial considerations, rather than on what is in the best interests of those affected by those developments.



This issue is of particularly relevance to the proposed development at Oldbury, which is being pursued in the absence of any visible consideration of alternative options (renewable of otherwise) that would provide secure electricity supplies.



Question 16: Do you think that the Government should formally approve (‘designate’) the draft Nuclear National Policy Statement?



Answer: No



• The Statement does not provide a clear strategy against which potential development of the collection of ten sites identified within the document can be assessed. The declaration that all ten sites are necessary is not consistent with the projected requirements for future generating capacity as set down in EN-1. The total requirement for all forms on non-renewable capacity has been estimated to be 25 GW; ten nuclear sites alone could generate up to 33 GW.



• The Statement does not include any requirement for the programme of additional nuclear capacity to be developed on the basis of minimum harm. The sites now being actively considered for development have been chosen by the generating companies, and reflect their commercial interests. A National Policy Statement produced by the DECC should be formulated such that priority is given to the interests of British public, rather than the profits of the generating companies.



Question 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?



Answer: No



• See responses to Question 2

• No guidance is given regarding the need to consider the relative merits of the ten identified sites. With typical output per site of 3.3 GW, and a number of practical constraints on the number of sites that can be developed at one time, those sites that attract the least dis-benefit should be developed in the first instance.



There are very significant dis-benefits associated with development of the site at Oldbury, and yet this site has been chosen for potential early development, ahead of sites at Hartlepool, Sellafield, Heysham, Bradwell, Braystones and Kirksanton.



Question 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?



Answer: Not in a manner that allows proper consideration of specific applications.



• See answer to Question 4.

• The Statement does not allow any meaningful assessment to be made of the importance or significance of proposed development at any particular site. No information or guidance is given with regard to the constraints or otherwise arising from present or future capacity of the grid. There are this no arguments or evidence to support the development of particular sites and not others.



This aspect is of particular relevance to the proposed development at Oldbury. The assessment of future grid requirements set down in EN-1 predicts an additional 3.3 GW of nuclear capacity from the South West, supplying load in the Midlands. The new plant at Hinkley Point could provide this capacity on its own, and planning for that development is already well advanced. On what basis therefore should development at Oldbury be pursued when there are other sites around the country that are far more suitable and which are not being actively developed?



Question 20: Does the draft Nuclear National Policy Statement appropriately cover the impacts of new nuclear power stations and potential options to mitigate those impacts?



Answer: Not in any meaningful way.



• See the answer to Question 2.



• The adoption of hyperbolic cooling towers at Oldbury would constitute a massive impact on the local environment. The adoption of other types of tower would introduce an unacceptable level of noise pollution, and have commercial dis-benefits for the operator. The Statement provides no methodology for assessing the balance of these arguments, and provides no Principles by which a decision can be made.



• Development at Oldbury will require major traffic/infrastructure developments and will pose potential threats of increased likelihood of flooding. Although numerous guidance documents are identified within the NPS, no methodology is set down that allows the inevitable unavoidable dis-benefit of such development to be weighed against the (unique?) benefits of this site.



• The NPS does not tackle the very significant issue of the obvious requirement to up-grade existing transmission lines and or provide additional transmission lines to connect to the grid.



Question 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?



(h) Oldbury



Answer: No. Although we are not in a position to provide informed technical comment on the majority of SSA criteria, it is self-evident that the construction of even a single reactor at Oldbury would challenge the acceptance standards in a number of crucial areas. Taken together, the cumulative potential dis-benefit associated with the development of this site is considerable. Of particular concern are:-



D1: Flooding, storm surge and tsunami.



• The site does not pass either The Sequential Test or The Exception Test for flood risk, as set out in EN-1 when consideration is given to the availability of other around the country. The proposal to site a nuclear power station in Flood Zone 3 can be justified only on the basis that no alternative sites are available to provide essential power generation for the country. This is clearly not the position (there are several other sites around the country that are not being actively developed), and no arguments or evidence is presented in any NPS to suggest that this will ever be the case.



• Whilst technical assessments of flooding risk and the provision of appropriate flood protection will need to be completed in order to secure the Nuclear Site License from NII, the proposal to store radioactive waste on such a high-risk site for up to 160 years raises a fundamental issue. The approved design for Oldbury will need to be shown to be adequate for the lifetime of the plant, ie 160 years. Paragraph 121 of the NII document ‘Safety Assessment Principles for Nuclear Facilities (2006) states:- “If the external hazards over which the dutyholder has no control are judged to be too great to be accommodated by the design of the plant, the use of a site may be precluded for its proposed purpose.” Although the flood risk assessments will attempt to take account of climate change effects, it is already apparent that existing climate change models cannot provide reliable predictions over such timescales, and thus the hazard must be judged to be effectively too great to be accommodated by the design.



• Notwithstanding the possibility of being able to make an acceptable deterministic case with respect to the flooding hazard, development of a nuclear site in a high flood-risk area, when other sites are available but not being developed, is contrary to the fundamental ALARP principle on which all safety cases for nuclear plant are founded. We would expect NII to review the Site License application on this basis.



• It is apparent that protection/mitigation of flood risk at this site will require the construction of very significant civil works and the movement of vast amounts of materials. There is no justification for the adoption of such extreme measures when consideration is taken of the fact that Oldbury is by no means an ‘essential’ site for development.



D8: Areas of amenity, cultural heritage and landscape value.



• Given the topographic and scenic qualities of the Severn Vale, the adoption of cooling towers of any significant height would be totally unacceptable. The adoption of forced draught or hybrid towers could present unacceptable noise pollution to the local area.



• The roads and infrastructure of the local area would require very significant development to support construction, effectively breaking up what is currently a quiet rural environment.



• The obvious requirement to either up-grade existing transmission lines, or construct additional ones, is likely to result in major visual impact. This aspect is not given any prominence in the SSA. We would expect details of all proposed transmission lines to be presented in the first phase of consultation.