Representation by Paul Naylor
- Date submitted
- 23 September 2020
- Submitted by
- Members of the public/businesses
As proposed, Sizewell C Power Station’s biggest impact on the environment will be its intake of seawater for cooling. The proposed seawater intake is massive, with a flow greater than the average flow of any river in England or Wales. Only one British river (the Tay in Scotland) is larger than the Sizewell C intake. Millions of fish would be sucked in and killed every year in the Sizewell C cooling water intake as proposed by the developer. A low velocity intake will not protect fish without a deterrent providing a behavioural cue for the fish to swim away. The proposed fish recovery and return system for Sizewell C would, at best, protect a fraction of the most robust fish species. Even for those fish, however, return to the sea through such a long and convoluted system in a state where they are capable of long-term survival and reproduction is uncertain. The fish recovery and return system will offer no protection at all to many fish species, including those that are most numerous. For example, all sprat, herring and similar fish that enter the cooling water intake will be killed. If they are not fatally harmed by pressure changes in the intake tunnels, they will die on the intake screens. Killing millions of fish (sentient vertebrate animals) in this way is morally wrong, damaging to vital ecosystems and incompatible with Government objectives for protecting and improving the environment, such as those in its 25 Year Environment Plan. Killing millions of fish also runs contrary to the overall objective of new nuclear power, which is to help safeguard the environment. Comparisons of fish kill in the intakes of new nuclear power stations with the impacts of fishing are misleading. Fishing impacts can be adjusted and regulated on an ongoing basis in response to environmental, societal or other changes. There will be no way to reduce fish kill in a power station intake once operating. The killing will continue unchecked for the power station’s 60-year life. Direct seawater cooling of large power stations must only be permitted if effective fish protection measures can be applied. They are currently not proposed for Sizewell C. The developers of Hinkley Point C, a similar station to Sizewell C and now under construction, maintain that additional fish protection measures such as an acoustic fish deterrent are impractical on a large nuclear power cooling water intake. This is disputed but, if it is the case and proper environmental protection cannot be applied, an alternative method of cooling must be employed for Sizewell C. I am a marine biologist, underwater photographer, writer and conservationist. I have worked in environmental regulation.