Representation by Blackwater against New Nuclear Group (Blackwater against New Nuclear Group)
- Date submitted
- 25 September 2020
- Submitted by
- Members of the public/businesses
The Blackwater Against New Nuclear Group (BANNG) wishes to be represented as an Interested Party at the Examination of the application for development consent of Sizewell C for the following reasons: 1. We are fundamentally opposed to development of major infrastructures on the vulnerable East Anglian coast. We consider the site for Sizewell C to be unsuitable and unviable and should be opposed in its own right and in terms of the precedent it would set for future coastal sites, including Bradwell B. 2. We have opposed the development of Sizewell C at Stage 1 and Stage 2 Pre-Application stages and do not consider the application has satisfied our objections. We therefore wish to present our fundamental objections at the Examination. BANNG objects to the proposed development as a whole. We understand the choice of the site is determined by the Government and is not open to question at this examination. However, we would point out that the Sizewell site was identified as a ‘potentially suitable’ for deployment of a new nuclear power station by 2025. Therefore, the potential suitability of the site is a fundamental issue to be explored at the Examination. We do not consider the site to be potentially suitable because: 1. The site is unsustainable. It lies on a vulnerable coast and is subject to the impacts of coastal processes, erosion, storm surges and flooding. In the longer term but within the operating, decommissioning and waste management lifetime of the plant, the impacts of climate change are indeterminate and the condition of the site unknowable. In deteriorating circumstances, sea defences and mitigation measures may be unable to sustain the site. Therefore, the project should be abandoned. 2. Radioactive waste is unmanageable. It is intended to store spent fuel and highly active wastes on site until well into the 22nd century, perhaps indefinitely, if a repository does not become available. BANNG believes it both impractical and unethical to store dangerous wastes indefinitely on a site where conditions could become unmanageable. In the absence of evidence and credible plans for the long-term management of wastes the proposals should not proceed. 3. The site is unacceptable. Sizewell C would be operating in close proximity to substantial population and in its wider hinterland is a densely populated rural area and several major towns including Ipswich. It is, therefore, imperative that credible and implementable emergency planning processes are in place before a permission is granted. BANNG intends to challenge the adequacy of arrangements. 4. The site is unsuitable. The scale of the proposed new nuclear power station will result in irreparable harm to environments and have a detrimental impact on the well being of local communities. The proposals will intensify and consolidate the wholesale transformation of the area from a peaceful, rural environment with exceptional assets of habitat, landscape and coast into a massive, intrusive and alien nuclear industrial complex. BANNG believes the long-term environmental degradation and continuing radioactive legacy will impose a detrimental burden of risk, cost and effort on present and future generations which will far exceed any short-term economic benefits. BANNG will support these objections with detailed criticism of the proposals and evidence confirming its view that the proposed Sizewell C nuclear power station should be refused Development Consent. We attach our earlier responses to pre-applications which indicate the scope of our interest and objection to the proposals: Response to Stage 1 Pre-Application Consultation (BANNG Paper 18, 2 February 2013); Response to Stage 2 Pre-Application Consultation (BANNG Paper 32, 7 February 2017)