Nuclear siting criteria unchanged despite fears

The government has not upgraded the importance of flooding and nature conservation in its site selection guidance for new nuclear power stations, despite concerns raised during consultation.

The government has refused to change the criteria for selecting new nuclear sites, despite criticism that they are not stringent enough to prevent environmental damage.

In its response to last year’s consultation on strategic siting assessment (SSA) for new nuclear power stations, the government has continued to categorise flooding and internationally and nationally designated ecological sites as discretionary.1

Discretionary criteria could make a site unsuitable for new power stations, but need to be "carefully considered". The Department for Energy and Climate Change (DECC) will look at whether the developer has shown that environmental damage can be mitigated or, if not, whether the site should be ruled out.

But the government also says it does not expect to form a conclusive view on the viability of mitigation proposals or the extent of potential environmental damage. This will be up to the Infrastructure Planning Commission to decide when a proposal for a power station is submitted.

Most of the UK’s existing nuclear power stations are within or next to national or international nature conservation sites. Most are by the coast or an estuary.

A study released with the consultation concluded that the government’s criteria mean "adverse impacts cannot be wholly ruled out". But it also says the criteria are "likely to lead to outcomes which are, on balance, broadly in line with the principles of sustainability and environmental protection", and the criteria relating to environmental protection are "consistent" with UK and EU legislation. An updated study published with the government’s response retains this view.2 But the Royal Town Planning Institute has questioned this. In its consultation response, it says some criteria do not reflect current policy, particularly around flooding and nature conservation, which should be "exclusionary" criteria - in other words, those that will categorically exclude a site from consideration.

The Royal Society for the Protection of Birds also called for the criteria on nature conservation to be exclusionary. Natural England pointed out that existing nuclear power stations were built before the designation of internationally important nature conservation sites and growth in understanding of the impacts of climate change. Several existing sites might therefore be unsuitable for nuclear power stations, it said.

It warns that the consultation could give a misleading impression that risks can always be mitigated through engineering. This may not always be possible, or it may be too expensive, or could result in a loss to ecosystem services, bringing extra costs to future generations.

The Environment Agency is also concerned about flooding. It stressed that flooding assessments must cover the lifetime of a site, from construction to decommissioning. But it is "generally satisfied" that the criteria for protecting designated sites are adequate.

Andrew Blowers, a visiting research professor at the Open University and a former member of the Committee on Radioactive Waste Management, slammed the SSA process as "an elaborate means of achieving premature legitimation for a predetermined policy". The proposed criteria mean none of the existing sites will be automatically ruled out.

The government’s response reveals little has changed in the consultation process. The presence of a seismic risk or fault on a site will no longer exclude it from consideration. Instead, the risks will be assessed locally because the government does not believe it is possible to do this adequately before developers put forward proposals and extensive investigations are carried out.

The only criteria that remain exclusionary are proximity to large centres of population or military activities.

The government wants the construction of new nuclear power plants to be market-led and so has invited companies or organisations to nominate sites for development. The deadline for nominations is the end of March. DECC will then assess all potential sites and consult on a draft list as part of the consultation of the draft Nuclear National Policy Statement, which it hopes to have designated by spring 2010.

Meanwhile, an updated impact assessment for the Planning Bill states that the cost of meeting the target to cut CO2 emissions by 80% by 2050 would be an extra £3-11 billion a year if nuclear power is not included.3

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