Response to Consultation on the UK Government's Policy Framework for New Nuclear Build, submitted on 31 October 2006
About Scientists for Global Responsibility
Scientists for Global Responsibility (SGR) is an independent UK membership organisation of approximately 850 science, design and technology professionals. We work to ensure that science, design and technology contribute to social justice, environmental sustainability and the reduction of conflict. The issues raised by the policy framework for new nuclear build are thus of great concern to us.
We object to the way this consultation paper has been presented and believe it premature as the decision to support new nuclear build has been taken without “the fullest public consultation” as promised in the 2003 Energy Review. We are concerned that the failure to follow proper process in arriving at this decision may render it unlawful.
The detail of the consultation paper also raises serious concerns. We especially object to the proposal that the public inquiry process for nuclear reactors should only consider local issues, while leaving the assessment of wider issues to regulatory bodies with minimal public input. We believe this is very likely to circumvent proper examination of many important issues, e.g. safety, radioactive waste management, security and resource management.
Our specific views on this are as follows:
We object to the proposed decision-making framework. We do not believe it to be an acceptable substitute for the rigorous and open examination of evidence at a public inquiry.
We do not have confidence in the procedures proposed for allowing prior public comment on aspects of the overall regulatory process for decisions on reactor design, siting and operational competence.
We believe that, in the interests of transparency, the Government must confirm that all parts of the licensing and siting processes will be open to full public scrutiny. Resources must be provided to allow the public and local authorities access and time for consultation at all stages.
It is not clear to us that proposed framework is consistent with the requirement for strategic environmental assessments of major projects under the Environmental Assessment of Plans and Programmes Regulations 2004.
We believe that the Government should provide for a joint public inquiry based on the powers contained in Regulation 17 Justification of Practices Involving Ionising Radiation Regulations, Section 14(1) and (2B) Health and Safety at Work Act 1974, Section 24(2) Radioactive Substances Act 1993 and Schedule 8 Electricity Act 1989.