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NATIONAL POLICY STATEMENT FOR NEW NUCLEAR POWER GENERATION BEYOND 2025RESPONSE BY THE MERSEA ISLAND SOCIETY

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This response is made by the Mersea Island Society. It was formed in 1963 to preserve, safeguard and promote the characteristics of Mersea Island for the benefit of all, to arrange open discussion whenever it appears necessary to obtain a consensus of public opinion and to provide opportunities to gain factual knowledge from lectures, visits and discussion.

Mersea Island is famed for its unique coastal environment on the estuaries of the River Blackwater and River Colne in North Essex some 60miles from London and 8 miles from the City of Colchester.

The Wikipedia entry states ‘Mersea’ comes from old world word meresig,

meaning "island of the pool.” “The island has been inhabited since pre-

Roman times. It was used as a holiday destination in Roman Britain for

occupants of Camulodunum (Colchester). Fishing has been a key

industry on the island since then, particularly oysters, and along with

tourism makes up a significant part of the island's economy.”

The Society has a long standing interest in the Nuclear Site at Bradwell

due to proximity to the island and the potential for it affecting the

environment that is very much valued for its marine and wild life.

It values the opportunity to present views to the Government on the

future of the nuclear power not only on behalf of its members but in

recognition that the island is greatly valued by the thousand of visitors

that regularly make use of it for recreation and holidays. It believed that

approaching 2,000 persons make use of caravans and static sites on the

island. The population at the latest census states it in excess of 7,000.

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GENERAL COMMENT

• •

• • •

SPECIFIC COMMENTS

MIS offers the following:

On the change from a strategic approach to one that is developer led and criteria based.

This is not supported. It will not produce a timely and rational approach with developers having different criteria and understanding of local issues we agree with the view the smaller, new reactor designs require a separate siting assessment process that is strategic and not developer led.

On the retention of the six undeveloped sites:

We do not support the continuation of the Bradwell site due to there being no resolution of the land investigations, the future impacts of Climate Change at a site vulnerable to flooding, storm surge and coastal processes and lack of public support. The latter is believed at

The Society is opposed to any consideration of AMR’s or SMR’s being

located on, or near, the Bradwell site. It does so out of concern for:

the impact of such sites on the local environment and the estuaries

of the Blackwater and Colne;

out of concern for the rise in sea levels and the risk of flooding;

the proximity of the site to residents and visitors being barely

3 miles away;

that Mersea being an island and that it is joined by a causeway

called the ‘Strood’;

concern that evacuation of the resident population of over 7,000

and in excess 20,000 in the summer months would be impossible;

the impact of the construction of SMR’s on the estuary and

surrounding area.

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overwhelming and the local MP, Colchester City Council, Essex County Council and other local authorities in the area are aware of this.

On the criteria regarding siting:

MIS supports an overall framework approach not developer led.

Proposed changes to the Planning Act 2008 to support a new nuclear NPS

MIS supports the current requirement that enables stakeholders to engage and able to make comments.

On detailed consideration of specific site assessment criteria Flooding, tsunami and storm surge and coastal processes

MIS supports the BANNG’s submission namely:

“Disagreement with the government’s conclusion that this shouldnot be ‘an exclusionary criterion, ruling out the highest risk zones due to climate change’. Rather, we consider this criterion should be exclusionary. .....reasons set out in BANNG Paper 34: “Where a site is liable to be inundated within the period that the power station is operating or being decommissioned then, in our view, it must be excluded.”

This must certainly apply to sites, like Bradwell, which are substantially in Flood Zone 3 where Sequential and Exception Tests have demonstrated this is the only available site. The time-scale from the beginning of operations, through generation, decommissioning and waste management, will extend well into the next century. Given uncertainties about future control and management of sites and methods of waste management it is realistic to conclude that these sites will remain as nuclear waste stores and decommissioning facilities for the indefinite future.

We think it is unlikely that developers will be able ‘to confirmthat they can protect the site against flood risk throughout the lifetime of the site. We do not support the idea that developers must first consider

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alternative sites or solutions whether at national or regional or local levels for two reasons. One is that we doubt whether developers will possess the time, resource, motivation or expertise to undertake a comparative evaluation of alternative sites. The other is that flooding etc. must be an exclusionary criterion; consequently, each site must be considered on its own merits and whether it is unsuitable.

We also believe that, in cases such as Bradwell, a site should be excluded very early in the process, probably before a developer has expressed interest in the site. The regulators should assess the potential suitability of a site, especially those from EN-6 and rule out thosewhere the impacts of flooding, tsunami and storm surge are at high risk of becoming unviable during the lifetime (around 200 years) of nuclear operations. We support the view that early engagement ‘will reduce the risk for developers and reduce burdens on the regulators’

Therefore, in order to reduce the burden on potential developers and remove anxiety from local communities, sites at high risk of flooding, tsunami, storm surge and coastal processes should be excluded by the regulators (ONR and EA) at a very early stage in the siting process. This applies especially to former EN-6 sites in coastal locations prone to the severe and accelerating impacts of Climate Change.”

On locational characteristics and population densities

MIS supports the view of BANNG namely:

“For each new development there must be a detailed risk assessment and analysis of the impact and consequences of a release of radioactivity. The public must be informed of the risks to health and environment that may be faced and how to react in the case of a nuclear emergency. While there is a need for reassurance, public information must also be realistic and recognise that in the event of a low probability/high consequence accident, the consequences could be devastating. The current approach to emergency planning based

on demographic criteria should be abandoned. Emergency planning must be site specific based on rigorous assessment of risks by ONR and the specification of emergency zones and evacuation procedures by the relevant Emergency Planning Authorities.”

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On Climate Change

MIS supports a separate review that should link with issues of concern such as sea levels, flood protection and evacuation.

Also, there should be an overriding climate change criterion.For this reason it supports the view in the BANNG submission that , “existential threat, societal change, adaptation, mitigation and resilience, an overriding criterion of Climate Change should be included in the site assessment criteria. The Climate Change criterion must be exclusionary. Related criteria such as flooding and coastal processes should remain separate but contributory assessments.”

On groundwater

MIS supports that there should be areas of Groundwater Protection and ensures the adequate supply of potable water to meet the demands of all potential consumers for the lifetime of nuclear operations at a site.

On marine environment

MIS welcomes marine environment is incorporated in thecriteria covering nationally and internationally designated sites of ecological importance. Among the designations covering the coastal areas are the Marine Conservation Zones.

But believes that an additional exclusionary criterion should be included in the new NPS ruling out new nuclear development in coastal and estuarine areas that would disrupt, destroy or damage the integrity of marine ecosystems.

On waste management

MIS supports scrutiny of proposals of adaptive management and understanding of potential conditions of site integrity with an assessment of future risks.

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On social acceptance

MIS refers to the opposition to any new proposals being considered for the Bradwell site. It has noted that there have been statements that infer priority will be given to communities that would welcome proposals being considered.

MIS would support that Social Acceptability should be introduced in EN- 7 as total concept. The implications of nuclear provision in the view of MIS needs to be viewed against the very long time scales involved with management issues that arise. The view of local populations should be a significant factor in the determination of sites.

On access to suitable sources of cooling

MIS supports the view of BANNG namely: “We strongly believe that access to cooling water should be an exclusionary criterion. Development of new nuclear power stations must be ruled out in conditions where: there is insufficient volume of water, for

example, in estuarial locations; there is a severe risk of detrimental impact on marine life and environment; access to cooling water is technically difficult to achieve, for example, by long pipelines to the sea; cooling towers would totally destroy the landscape and amenity.”

On ownership of sites

MIS supports the view of BANNG namely: “There must be no presumption in favour of landowners willing to sell land for nuclear development. New nuclear siting must be based on assessment of site suitability, not on friendly land ownership. Also, no presumption should be made on whether local communities are willing to have nuclear development in their backyard. Presumed support for nuclear development should not be offered as a reason for site selection.”

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CONCLUSIONS

MIS has a very keen interest in the future of nuclear industry as can be seen by the attention MIS continues to give to the Bradwell site.

It maintains for numerous reasons that this it is not a sensible site for consideration. The framing of the Government’s future policy remains of central concern to the Society and it would like to present views on a constructive basis in order that the Government, agencies, and companies can understand the heartfelt and rational reasons it has taken this view.

John Akker MBECommittee MemberText as agreed by the Mersea Island Society 3rd March 2024

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