From Greenhouse to Green House

EXAMPLE RESPONSES TO THE UK GOVERNMENT'S NUCLEAR CONSULTATION, 2007

August 2007

Please note: When you first go to the UK Government's online consultation on "The Future of Nuclear Power", you will be asked to log in. To do this, you will first need to register by clicking on the 'Registration' button near the top of the page. However, there is a bug in the system that means that, when you first click on the Registration button, you will get a page telling you that you cannot log in to the consultation because you do not have cookies enabled. Just ignore this page and click on the Registration button again. Then you will get the registration page. After you have registered, you will be able to log in.

Another point to bear in mind is that, with the online consultation, each answer is limited to 3000 characters or less. All the suggested answers below are within this limit. If you edit the answers, take care not to exceed the limit. Of course, in the spirit of unbiased enquiry that does not pre-judge the issue, the Government has allowed itself much more space to put its case than it is giving to members of the public :-)

1. TO WHAT EXTENT DO YOU BELIEVE THAT TACKLING CLIMATE CHANGE AND ENSURING THE SECURITY OF ENERGY SUPPLIES ARE CRITICAL CHALLENGES FOR THE UK THAT REQUIRE SIGNIFICANT ACTION IN THE NEAR TERM AND A SUSTAINED STRATEGY BETWEEN NOW AND 2050?

Yes, these are critical challenges but they can certainly be met without using nuclear power.

There are many problems associated with nuclear power (see http://www.mng.org.uk/gh/no_nukes.htm) and many of them are serious. No other source of electricity has so many drawbacks.

If there was no alternative, we might have to consider using nuclear power. But there is now abundant evidence in several different reports that our current and future needs for electricity can be met from renewable sources with sensible conservation measures, and without using nuclear power. Recent reports to that effect are listed on http://www.mng.org.uk/gh/scenarios.htm with summaries and links for downloading. Those marked 'UK' describe scenarious that are directly relevant to the UK but other reports in the list are also relevant to considerations of future energy supplies in the UK.

Currently, Germany gets 13% of its energy from renewable sources, the sector is booming and Angela Merkel would like to commit Germany to a target of 27% by 2020 (see http://www.guardian.co.uk/environment/2007/aug/13/renewableenergy.energy). By contrast, the UK obtains only 2% of its energy from renewable sources and, with current policies, is unlikely to achieve more than 5% by 2020 (ibid.). It does look as if we need to adopt some of the policies that have proved effective elsewhere.

If nuclear power was much cheaper than the alternatives, we might need to consider using nuclear power. But the weight of evidence is that, when all the hidden costs are added in, it is one of the most expensive sources of electricity (see bullet point 4 in http://www.mng.org.uk/gh/no_nukes.htm). This relative disadvantage of nuclear power is likely to increase as the costs of renewable sources of energy are brought down by economies of scale and refinements in technologies.

If nuclear power provided greater security of supplies than the alternatives, we might need to consider using it. But the evidence points in the other direction. Contrary to what Malcolm Wicks MP has said, nuclear power is not a 'home grown' source of power: all nuclear fuels are imported into the UK. The vulnerability of nuclear plants and nuclear transports to terrorist attack has implications for security of supplies. In the non-nuclear low-carbon scenarios described in the TRANS-CSP report from the German Aerospace Center (see http://www.trec-uk.org.uk/reports.htm), there is an overall *reduction* in imports of energy into Europe compared with the situation now, an overall *increase* in the diversity of sources of electricity, and a corresponding *increase* in the resilience and security of electricity supplies.

Nuclear power currently enjoys a large hidden subsidy in the form of limitations on liabilities arising from Chernobyl-style disasters, or worse (see answers to Question 4). This subsidy is not acceptable and should be removed forthwith.

2. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON CARBON EMISSIONS FROM NEW NUCLEAR POWER STATIONS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

* Significant amounts of CO2 are released by the nuclear industry: in the construction of nuclear power stations and in mining uranium ore, in transporting and processing uranium ore to make nuclear fuel, in transporting the fuel, transporting nuclear waste, processing it, and disposing of it. It is a long way from being a zero-emissions source of electricity, as claimed by the industry. Helen Caldicott (in "Nuclear power is not the answer", ISBN-13 978-1-59558-067-2) quotes research showing that "The use of nuclear power causes, at the end of the road and under the most favourable conditions, approximately one-third as much carbon dioxide (CO2) emission as gas-fired electricity production." The use of poorer ores as a source of fuel for nuclear reactors "would produce more CO2 emissions than burning fossil fuels directly." In other words, "nuclear reactors are best understood as complicated, expensive, and inefficient gas burners." (p. 6).

* In the light of the evidence presented by Helen Caldicott, the claim that CO2 emissions from nuclear power are "similar to the carbon dioxide emissions from wind power" (para 44 of the preamble) is, frankly, not credible. Any confidence that we might have in such claims is undermined by the nuclear industry's long history of misleading the public about costs, safety and other aspects of nuclear power.

3. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SECURITY OF SUPPLY IMPACT OF NEW NUCLEAR POWER STATIONS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

* All nuclear fuel is imported: nuclear power is certainly not a 'home grown' source of energy as Malcolm Wicks has suggested.

* The vulnerability of nuclear plants to terrorist attack (and likewise for trains and ships carrying nuclear materials) has implications for the security of electricity supplies from nuclear sources.

* The TRANS-CSP report from the German Aerospace Center has described in detail how Europe could meet all its needs for electricity, make deep cuts in CO2 emissions and phase out nuclear power at the same time. In the scenarios that they describe up to 2050, there would be an overall *reduction* in imports of energy compared with the situation now (notwithstanding their proposals to import solar energy), there would be an overall *increase* in the diversity of sources of energy (notwithstanding their proposal to phase out nuclear power), and there would be a corresponding *increase* in the resilience and security of electricity supplies. The report may be downloaded via links from http://www.trec-uk.org.uk/reports.htm .

* Regarding the statement that "Nuclear power is most economic when run continually, so it is well placed to meet the need for baseload capacity in the UK", a much better alternative is concentrating solar power (CSP) with heat storage and the use of gas a stop-gap source of heat (see http://www.trec-uk.org.uk/csp.htm). It can provide any combination of baseload power, intermediate load or peaking power -- which means that it is much more useful in matching supplies to constantly varying demands than an inflexible source like nuclear power.

4. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE ECONOMICS OF NEW NUCLEAR POWER STATIONS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

* When all the overt and hidden subsidies are taken into account, nuclear power is much more expensive than any other source of electricity. Some figures on costs from the New Economics Foundation are quoted in "Is it all over for nuclear power?" (http://www.mng.org.uk/gh/renewable_energy/NS_nuclear_article.htm). The source of those figures is the NEF report "Mirage and oasis" (http://www.mng.org.uk/gh/scenarios/nef_energy_june_2005.pdf, PDF, 1.2 MB).

* There is a very full account of costs in Helen Caldicott's book (ISBN-13 978-1-59558-067-2). To be competitive with other sources of power, nuclear power requires permanent support from tax payers or permanent support by means of market mechanisms or hidden subsidies. By contrast, most renewable forms of energy need temporary support until costs are reduced by economies of scales and refinement of technologies, and no further support after that.

* One of the biggest of several hidden subsidies for nuclear power is that it is only required to pay a small fraction of the cost of insuring fully against claims from a Chernobyl-style disaster, or worse: "... in the United States, the Price-Anderson Act limits the nuclear industry's liability in the event of a catastrophic accident to $9.1 billion, which is less than 2% of the $600 billion guaranteed by the Congress. In any case, $600 billion is considered to be a gross underestimate ..." (Helen Caldicott, p. 32). There are similar limitations on liabilities in other countries around the world, including the UK.

* "In France, if Electricité de France had to insure for the full cost of a meltdown, the price of nuclear electricity would increase by about 300%. Hence, as opposed to conventional wisdom, the price of French nuclear electricity is artificially low." (ibid., p. 32). Full insurance against nuclear disasters would completely demolish any economic case for nuclear power.

* Other hidden subsidies include:

- The costs of providing protection against terrorist attack for nuclear plants, and for trains and ships carrying nuclear fuel and nuclear waste.

- The costs to us all arising from the fact that any such protection can only ever be partial.

- The cost of decommissioning nuclear plants. An estimate in 2006 by the UK Treasury for the cost of decommissioning the UK's old nuclear power stations was GBP 90 billion.

- The costs born by national governments in that ultimately they must underwrite the risk that any nuclear company may fail, as evidenced by the way the UK government had to bale out British Energy in 2005 at a cost of GBP 5 billion.

- The costs arising from nuclear waste that will be dangerous for thousands of years. These costs will be born by future generations but they will receive no compensating benefit.

5. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE VALUE OF HAVING NUCLEAR POWER AS AN OPTION? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

* The preamble to this question lays stress on risks and uncertainties about the way the world and energy markets may develop with corresponding uncertainties about which sources of energy will be most appropriate in the future. Those kinds of uncertainty are a very good reason for using technologies with short lead times and avoiding a technology like nuclear power which has, as the Government acknowledges, very long lead times. By the time a nuclear power station has been built, it may easily be a white elephant. Renewable sources can be brought on stream very much more quickly, which means that there is much less chance that any one installation will turn out to be a costly embarassment.

* Regarding the point about security of supply in para 69 of the preamble:

- As previously mentioned, the TRANS-CSP scenarios provide for a *reduction* in imports of energy into Europe compared with current systems, they provide for *greater* diversity of sources of electricity than what we have now, and there is a corresponding *increase* in the resilience and security of electricity supplies.

- As previously mentioned, the vulnerability of nuclear plants and nuclear transports to terrorist attack has implications for security of supply.

* With regard to the point about reducing carbon emissions in para 69: as previously mentioned, it is abundantly clear from several different reports (see http://www.mng.org.uk/gh/scenarios.htm) that we can achieve the necessary deep cuts in CO2 emissions *without* using nuclear power. The nuclear power cycle produces far more CO2 than is claimed by the industry. There are several other sources of electricity with much lower CO2 emissions.

* With regard to para 70, it is nonsense to suggest that "By excluding nuclear as an option ... meeting our carbon emissions reduction goal would be more expensive." When all the hidden costs of nuclear power are properly accounted for, it is already one of the most expensive source of electricity. The gap will widen as the costs of renewable sources of electricity fall.

6. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SAFETY, SECURITY, HEALTH AND NON-PROLIFERATION ISSUES? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

* If the nuclear industry believes that the risk of catastrophic accidents is acceptably low, then it should be prepared to take out the full cost of insuring against such accidents, without the limitations on liability that currently apply. The Government should ensure that ***full insurance against accidents without any limitations on liability is a requirement for every nuclear plant and all associated operations***.

* If the risk of a catastrophic nuclear accident is indeed as low as is suggested in para 74, then it hard to explain why there was a core meltdown at the EBR fast breeder reactor in the USA in 1955, a partial core meltdown at the Fermi fast breeder reactor in the USA in 1966, a partial meltdown at Three Mile Island in the USA in 1979, a catastrophic explosion and release of large amounts of radioactive materials at Chernobyl in 1986, a near meltdown at the Greifswald nuclear power plant in Germany in 1989, and a near meltdown at Sweden's Forsmark nuclear power station in late July, 2006.

* Human error is unavoidable and all current safety systems rely on humans.

* It is highly misleading to say that "The UK has not had an incident at a civil nuclear power station where there has been an offsite release of radioactive material". Radioactive releases are a recurrent feature of the plants needed to run the nuclear industry even if they are not always 'civil nuclear power stations' and the releases are not always 'offsite'. Several such releases are listed under the first bullet point in http://www.mng.org.uk/gh/no_nukes.htm .

* Radioactive contamination of the environment has been shown to correlate with increased rates of childhood leukemia and other kinds of cancer (see answers to Question 11).

* In February 2005, British Nuclear Fuels Ltd reported 30kg of plutonium as 'unaccounted for' during the last financial year in its annual audit of nuclear materials. We have no means of knowing whether this was merely an 'accounting error' as suggested by BNFL or a genuine loss of nuclear material. Either way, it is clear that slack controls provide ample scope for highly-dangerous radioactive materials to find their way -- via bribery, theft or hijacking -- into the hands of terrorists or unfriendly foreign governments.

* The technology for nuclear power has much in common with the technology needed for the production of nuclear weapons. The "Janus-like character of nuclear energy" (Kofi Annan) adds to the problem of reducing the number of nuclear weapons in the world or preventing their proliferation. If we are trying to persuade countries like Iran to give up nuclear power, we are in a very weak negotiating position if we have nuclear power (and nuclear weapons) ourselves.

7. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE TRANSPORT OF NUCLEAR MATERIALS? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

* Terrorists can easily create a 'dirty bomb', dispersing large amounts of radioactive materials over a large area, by exploding a conventional bomb close to a body of nuclear fuel or high-level radioactive waste. Since these materials are carried on railway trucks throughout the UK, it is not possible to provide all-time protection against that kind of terrorist attack. As a bare minimum, it would mean placing an armed guard on every nuclear transport and somehow ensuring that no bombs could be planted anywhere on or near the tracks where those transports run. Given that terrorists only need to succeed once but the authorities have to succeed all the time, it is surprising that terrorists have not already taken advantage of this large and unpluggable hole in security.

* The inadequacy of current systems was demonstrated very clearly when, in July 2006, a reporter from the Daily Mirror managed, very easily, to plant a fake bomb on a flask of nuclear waste in a railway siding (see http://www.mng.org.uk/gh/renewable_energy/daily_mirror_nukes1.htm).

8. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON WASTE AND DECOMMISSIONING ? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

* Some radioactive waste will remain dangerous for 10,000 years or more. ***No human institution has ever survived that long.*** It is impossible to guarantee safe management of this material for that length of time.

* Radioactive waste is one of the 'hidden' costs of nuclear power: it is a subsidy paid by future generations to us now, with no offsetting benefit for those people who are yet to be born (see also the answer to Question 10).

* In Chapter 5 of "Nuclear power is not the answer", Helen Caldicott describes in some detail the totally inadequate nature of proposals to store nuclear waste in Yucca mountain in the USA. Problems of corrosion, leakage, ingress of groundwater, and the long-term instability of all geological formations are the same throughout the world, including the UK.

9. WHAT ARE THE IMPLICATIONS FOR THE MANAGEMENT OF EXISTING NUCLEAR WASTE OF TAKING A DECISION TO ALLOW ENERGY COMPANIES TO BUILD NEW NUCLEAR POWER STATIONS?

Since there is no satisfactory solution to the problem of storing existing nuclear waste for thousands of years, it is quite unacceptable to add to that problem (see answers to Question 10).

10. WHAT DO YOU THINK ARE THE ETHICAL CONSIDERATIONS RELATED TO A DECISION TO ALLOW NEW NUCLEAR POWER STATIONS TO BE BUILT? AND HOW SHOULD THESE BE BALANCED AGAINST THE NEED TO ADDRESS CLIMATE CHANGE?

There is no way of storing high-level nuclear waste safely for thousands of years and it is totally immoral to bequeath this legacy to hundreds of generations into the future.

The preamble to Questions 8, 9 and 10 suggests that the fight against climate change may provide a justification for creating more nuclear waste. This line of reasoning is entirely false because there is abundant evidence that we can make the necessary deep cuts in CO2 emissions without using nuclear power (see answer to Question 1).

Likewise, the argument that nuclear power would provide a relatively inexpensive way to cut CO2 emissions is spurious. When all the hidden costs are added in, nuclear power is one of the most expensive sources of electricity (see answer to Question 1).

11. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON ENVIRONMENTAL ISSUES? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

* With regard to para 103 of the preamble, it is highly misleading to make a comparison between the amount of land needed for a nuclear power station and amount of land needed for a wind farm with similar capacity. Only a small fraction of the land occupied by a wind farm is actually needed for the wind turbines and most of the land can continue in use for grazing or other kinds of agriculture. The tracks needed for access to wind turbines are frequently the same as the tracks needed by farmers to move farm machinery around their land. In any case, many wind farms are being and will be built out at sea.

* In the preamble to this question, there is no mention of the persistent leakage into the environment of radioactive materials from nuclear installations. Sellafield discharges two million gallons of radioactive water into the Irish Sea every day at high tide. This includes a cocktail of over 30 alpha, beta and gamma radionuclides. BNFL admits that radioactive discharges in the 1970’s were 100 times those of today. As a result of these discharges, which include around half a tonne of plutonium, the Irish Sea has become the most radioactively contaminated sea in the world. Caesium-137 and Iodine-129 from Sellafield have spread through the Arctic Ocean into the waters of northern Canada and are having a bigger impact on the Arctic than the Chernobyl accident. Sellafield’s gas discharges of Krypton can be measured in Miami.

* There is evidence that in areas affected by radioactive contamination from the nuclear industry there have been statistically significant increases in the incidence of childhood leukemia and other kinds of cancer (see http://www.llrc.org/health/subtopic/menai.htm).

* This kind of contamination of the environment with radioactive materials is totally unacceptable. Given the nuclear industry's record of mismanagement and accidents (see answers to Question 6), there is no guarantee that there will not be similar releases of radioactive materials into the environment in the future.

12. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SUPPLY OF NUCLEAR FUEL? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree:

* It has been calculated that, if enough nuclear fission reactors were built to meet most of the world's demand for electricity, exploitable sources of uranium would be exhausted in about fifteen to twenty years (see Energy Beyond Oil by Paul Mobbs, Matador, 2005, ISBN 1-905237-00-6). If countries like India and China start using nuclear power on a large scale -- and there are good indications that this will happen -- it likely that the UK would experience increasing difficulties in obtaining the nuclear fuel needed for any new nuclear power stations that may be built.

* Nuclear power may consume more energy than it produces. "Even utilizing the richest ores available, a nuclear power plant must operate at ten full-load operating years before it has paid off its energy debts. And ... there is only a finite supply of supply of uranium ore containing reasonable concentrations of uranium 235. When this concentration falls below 0.01%, the costs of energy production from nuclear power can no longer cover the costs of extraction of uranium from the earth, at which time the nuclear fuel cycle will produce no net energy; below a certain uranium content, nuclear power produces less energy than is needed to build, fuel, and operate the reactor and to repair the environmental damage." (Helen Caldicott, p. 16).

* Unless or until the energy inputs required for all parts of the nuclear cycle are provided without the use of fossil fuels, increases in those inputs will mean increases in CO2 emissions.

13. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON THE SUPPLY CHAIN AND SKILLS CAPACITY? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

Disagree. Ever since the Chernobyl disaster there have been very few nuclear power stations built. Most of the people with the necessary knowledge to build and run new nuclear power stations are near to retirement or already retired -- and there have been few younger people entering the industry. It would be folly to try to build and run new nuclear power stations without the necessary reservoir of skills.

14. DO YOU AGREE OR DISAGREE WITH THE GOVERNMENT'S VIEWS ON REPROCESSING? WHAT ARE YOUR REASONS? ARE THERE ANY SIGNIFICANT CONSIDERATIONS THAT YOU BELIEVE ARE MISSING? IF SO, WHAT ARE THEY?

We don't need any of this dirty, dangerous and expensive technology - and that includes reprocessing.

15. ARE THERE ANY OTHER ISSUES OR INFORMATION THAT YOU BELIEVE NEED TO BE CONSIDERED BEFORE TAKING A DECISION ON GIVING ENERGY COMPANIES THE OPTION OF INVESTING IN NUCLEAR POWER STATIONS? AND WHY?

A major plank in the argument for building new nuclear power stations in the UK is that, notwithstanding the evidence presented in the answer to Question 2, nuclear power is thought to provide a route towards the deep cuts in CO2 emissions that are needed to fight climate change. Before any decision is made to permit the building of new nuclear power stations, we need to consider whether there may be better ways of achieving those deep cuts in CO2 emissions whilst maintaining supplies of electricity.

As indicated in the answer to Question 1 and elsewhere, there is abundant evidence from several different reports that we can meet all our needs for electricity from low carbon sources without using nuclear power. But if we are to catch up with the achievements of Germany and other countries that are ahead of us in bringing renewable sources on stream, we need to be prepared to adopt key instruments such as Feed-In Tariffs that have been used with great success elsewhere.

In addition:

* The Government should introduce a vigorous programme of zero-carbon eco-renovation of existing buildings to bring down emissions of CO2 from space heating and water heating (see http://www.mng.org.uk/gh/renewable_energy/ecorenovation.htm). This is really 'low-hanging fruit' in the bid to cut CO2 emissions but, so far, very little of this potential has been tapped. In principle, it is possible to upgrade most buildings to a standard that is comparable with that of a German "passive house". With high levels of insulation (much higher than the levels of insulation that are normally used in the UK) and with other measures, it is possible to make very large reductions in the fuels required for heating.

* Since gas is the dominant fuel for space heating and water heating, a programme of zero-carbon eco-renovation should achieve substantial reductions in demand for gas. In addition, since some space heating and water heating is still done using electricity, there should also be reductions in the demand for electricity.

* Some of the gas that is saved by this programme of zero-carbon eco-renovation may be used to generate backup supplies of electricity in case there is a shortfall from other sources. These backup supplies of electricity should put at rest any worries about possible shortages. It is likely that only a small proportion of the gas saved by the upgrading of buildings would be needed for the generation of electricity and there would still be substantial overall savings in gas consumption.

This two-pronged strategy -- a substantial speed-up in the introduction of renewable source of electricity coupled with a vigorous programme of zero-carbon eco-renovation of buildings -- will enable the UK to make deep cuts in CO2 emissions and provide robust and sufficient supplies of electricity at the same time. It would also enable us to avoid all the many headaches of nuclear power.

16. IN THE CONTEXT OF TACKLING CLIMATE CHANGE AND ENSURING ENERGY SECURITY, DO YOU AGREE OR DISAGREE THAT IT WOULD BE IN THE PUBLIC INTEREST TO GIVE ENERGY COMPANIES THE OPTION OF INVESTING IN NEW NUCLEAR POWER STATIONS?

For all the reasons given in answers to previous questions, I strongly disagree. Here are some other reasons:

* Rising sea levels:

- All of the UK's existing nuclear power stations are on the coast and it appears that the nuclear industry favours building new nuclear power stations on the same sites. Thus any significant rise in sea level could have disastrous consequences both for existing power stations (even after they have ceased producing electricity but are still 'hot') and any new ones that may be built nearby. Significant rises in sea level may seem unlikely but, in a recent article ("Huge sea level rises are coming – unless we act now", New Scientist, issue 2614, 25 July 2007), James Hansen, Head of NASA's Goddard Institute for Space Studies in New York, argues there could be a "runaway collapse" of the Antarctic and Greenland ice sheets leading to rises in sea level that are much bigger than current IPCC predictions. Since climate scientists have already been surprised by the speed with which floating ice shelves in the Antarctic have broken up, it would be unwise to assume that there could not be similar surprises in the speed with which land-based bodies of ice disintegrate.

- "Nuclear power stations on the British coast will experience storm surges up to 1.7 metres (5½ft) higher by 2080 because of global warming, a study suggests. The research, commissioned by British Energy, the nuclear plant operator, suggests that new coastal defence strategies may be needed to protect sites from a combination of more extreme weather and higher sea levels. All of Britain's 15 nuclear plants are near the coast, and the prospect of rising sea levels has raised questions about whether the sites will be suitable if a new generation of reactors is built." (Mark Henderson, The Times, 2007-01-24).

* Nuclear power stations built inland would not necessarily fare any better. In recent heat waves, nuclear power plants have been shut down owing to shortages of cooling water and unacceptable damage that would be caused by the discharge of hot water into the environment (see http://www.iht.com/articles/2007/05/20/africa/nuke.php and http://www.huffingtonpost.com/joel-makower/our-nuclear-summer_b_27112.html). This kind of problem is likely to become worse as global temperatures rise.

17. ARE THERE OTHER CONDITIONS THAT YOU BELIEVE SHOULD BE PUT IN PLACE BEFORE GIVING ENERGY COMPANIES THE OPTION OF INVESTING IN NEW NUCLEAR POWER STATIONS? (FOR EXAMPLE, RESTRICTING BUILD TO THE VICINITY OF EXISTING SITES, OR RESTRICTING BUILD TO APPROXIMATELY REPLACING THE EXISTING CAPACITY)

No, there should be an outright ban on any new nuclear power stations.

18. DO YOU THINK THESE ARE THE RIGHT FACILITATIVE ACTIONS TO REDUCE THE REGULATORY AND PLANNING RISKS ASSOCIATED WITH SUCH INVESTMENTS? ARE THERE ANY OTHER MEASURES THAT YOU THINK THE GOVERNMENT SHOULD CONSIDER?

We don't need any facilitative actions or other measures to smooth the path for nuclear power. The Government should be facilitating the development of the many good alternatives.