Lake District National Park Authority
Authority: 22 July 2015
Agenda Item: 11
Page 1
RESPONSE TO STAGE 1 CONSULTATION FOR THE PROPOSED MOORSIDE
NUCLEAR POWER STATION NORTH OF THE EXISTING SELLAFIELD SITE IN
CUMBRIA
1
SUMMARY
1.1
A Development Consent Order application for a new nuclear power station at
Moorside (north of Sellafield) will be submitted to the Secretary of State for Energy
and Climate Change in 2017 by NuGen. Prior consultation is required before
submission. The first stage consultation is now underway. This report outlines the
process and details of the consultation and asks you to agree our consultation
response.
Recommendation that: a
Agree the Authority response as shown in Annex 1.
2
BACKGROUND
2.1
In 2011 the UK Government undertook a Strategic Siting Assessment (SSA) for new
nuclear power stations. The conclusion of the SSA was that land adjacent to the
Sellafield Site was potentially suitable and the site is to be known as Moorside. The
Moorside Project is a nationally significant infrastructure project and will require a
number of consents for it to be constructed. The Development Consent Order (DCO)
application will be submitted in 2017 and the Planning Act 2008 requires that prior
consultation is undertaken. This is in two stages. Stage 1 is a Strategic Issues
Consultation starting in May 2015 and Stage 2 is the Proposed Scheme Consultation
starting in May 2016. We are a consultee and we are now in the Stage 1 consultation
period. We are required to make our response by 25 July 2015.
2.2
The Stage 1 consultation is focused on Strategic Issues including NuGen’s
requirements and approach, broad locations and search areas for Associated
Development (supporting development both temporary and permanent works such
as construction workers accommodation and related facilities, transport and logistics
centres). It also covers preliminary environmental information which covers the
following topics:
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2.3
transport,
noise and vibration,
air quality,
radiological issues,
soils, geology and land quality,
freshwater environment,
marine physical environment,
landscape and visual,
historic environment,
biodiversity,
countryside recreation,
socio economics and human population,
climate change.
At a meeting of our member Nuclear Task and Finish Group on 25 June 2015 it was
agreed that we focus our comments on those issues which we are primarily
concerned about, namely transport, landscape and visual impact, countryside
recreation, historic environment, and socio economics and human population. These
are issues potentially affecting the setting of the National Park both in landscape
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terms and infrastructure. We appreciate the other issues can be dealt with by other
regulatory authorities that have specific responsibilities for such issues including
Natural England, Office for Nuclear Regulation, Copeland Borough Council and
Cumbria County Council Environmental Protection. However we will assist other
consultees where appropriate.
3
POLICY CONTEXT
3.1
The 2030 Vision for the English Lake District is that it will be an inspirational example
of sustainable development in action. The Vision is fundamentally based on the
premise that the spectacular landscape, wildlife and cultural heritage are the reasons
for the National Park designation. But the Vision also recognises that these assets
can only possibly be sustained and protected if the living, working places that have
created it, and which continues to evolve, are able to thrive.
3.2
A key outcome of the Vision for the Lake District National Park 2006–2030 is a
landscape which provides an irreplaceable source of inspiration, whose benefits to
people and wildlife are valued and improved.
3.3
Our Partnership’s Plan; The Management Plan for the English Lake District 20152020, as submitted to Dept of Culture, Media and Sport as part of the WHS
nomination dossier, includes a strategy relating to major industries and provision of
infrastructure outside the Lake District. Strategy PE6 states:
Our strategy is to recognise the importance of nuclear and energy industries in West
Cumbria and other major economic investments in Cumbria. Where they do not
prejudice the Lake District, its setting, Special Qualities and attributes of Outstanding
Universal Value, or visitor economy we will assist with the development of proposals
for associated infrastructure.
4
OPTIONS
4.1
Members have the following options:
a) To agree the response as set out in Annex 1 and provide delegated authority to
the Director of Sustainable Development to make minor additions and
amendments to the responses to reflect further views received before the
consultation deadline;
b) To agree the response with changes; or
c) To not agree the response.
5
PROPOSALS
5.1
This consultation is important as it will set the context for determining the
Development Consent Order near to this National Park. Members were briefed by
NuGen, as part of their consultation exercise, at June Authority. Additionally a
member’s Nuclear Task and Finish Group has been convened and has assisted
officers in drafting the attached response.
5.3
Given the above the Members are asked to agree Option a)
6
BEST VALUE IMPLICATIONS
6.1
The Best Value implications are:
a) Challenge – We have only dealt with those aspects which we think are particularly
pertinent to the National Park. We appreciate the need for Government to meet
future UK climate change targets and to seek national security of energy supply.
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Agenda Item: 11
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b) Compare – Other Local Authorities are engaging in this process and we need to
ensure that our views are represented.
c) Consult – We have worked with Cumbrian partners during the process of the
preparation of the Environmental Impact Assessment.
d) Compete – We need to respond in order to ensure our views are considered along
with other consultees.
7
FINANCE CONSIDERATIONS
7.1
There are no significant financial considerations as a result of the recommendation.
8
RISK
8.1
There are implications for resources for getting involved in this consultation but there
is also a risk that if we don’t, we will have lost the opportunity to influence the scope
of the information submitted to assess the development and are not able to ensure
the best possible outcome for the setting of the National Park and it’s local
communities. The Directorate’s Service Plan will need to be kept under review and,
as and when necessary, reprioritised.
9
LEGAL CONSIDERATIONS
9.1
There are no legal implications as a direct result of this report..
10
HUMAN RESOURCES
10.1
The Authority will have a regulatory role, as a local planning authority, particularly in
responding to utilities’ proposals for new nuclear power stations and associated
infrastructure. The cost of this work could be considerable in terms of officer time.
The opportunities for funding to offset some of these costs are being explored. We
have requested that the LDNPA be party to a Planning Performance Agreement or
similar Memorandum of Understanding to enable us to fund the necessary resources
for this consultation process and be able to respond within the required timescales.
However at present there is no certainty of such funding.
11
DIVERSITY IMPLICATIONS
11.1
There are no diversity implications as a direct result of this report.
12
SUSTAINABILITY
12.1
The consultation sets out how the Government can meet future UK climate change
targets and contribute to national security of energy supply whilst ensuring protection
of social and environmental qualities.
Background Papers
Author/Post
Date Written
Mairi Locke, Area Planner
1 July 2015
Lake District National Park Authority
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Agenda Item: 11
Annex 1 Page 1
ANNEX 1: OUR RESPONSE TO THE STAGE I CONSULTATION
Proposal: - a proposed 3.6GW Moorside Power Station delivering up to 3.4GW of
electricity, and other temporary and permanent works required referred to as
Associated Development (which includes construction workers accommodation and
transport infrastructure works). The project will also involve creating a marine offloading facility and highway works.
This consultation does not include National Grid’s electricity transmission line upgrade to
serve the site.
Given the present unfortunate lack of any arrangement with NuGen on resource assistance
we have concentrated on those more significant issues potentially affecting the setting, and
future management, of the National Park both in landscape terms and infrastructure. In
terms of your consultation headings these are:
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Transport;
Landscape and visual impact;
Countryside recreation;
Historic environment; and
Socio economics and human population.
Other environmental issues will be addressed by the other regulatory authorities that have
specific responsibilities for those issues such as Natural England, Office for Nuclear
Regulation, Local Council and County Council Environmental Protection but we will
however assist where appropriate.
Our response reflects the structure of your consultation questionnaire.
1
Strategic issues, including need and potential benefits
1.1
We support the principle of a new build nuclear power station adjacent to Sellafield.
The proposal would continue the long tradition of the nuclear industry in Cumbria
and benefit the national and Cumbrian economy. And, our support, is consistent
with that offered in 2011 when this Authority commented on the National Policy
Statement for Nuclear Power Generation (NPS EN-6)
1.2
We welcome the extensive consultation undertaken as part of Stage One, including
the involvement of our members.
1.3
Whilst we support the principle we offer the following comments, which are further
expanded on in our Preliminary Environmental Information section:
Transport;
1.4
We support and applaud the travel hierarchy proposed for Moorside, with an
emphasis on sustainable travel. A site specific travel plan, adopted by the site
management and employees, will be essential to avoid considerable adverse
impacts on local communities along commuting routes and damage to the
environmental capacity of the road network. The Environmental Impact Assessment
(EIA) will need to be clear on the transport impacts and extent of mitigation.
1.5
The emphasis on improving rail infrastructure is supported, albeit we ask that NuGen
fully understand the need for resilience to this infrastructure at all times. We also
would like assurance that the southern part of the West Coastal Cumbrian line
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Annex 1 Page 2
between Carnforth and Barrow is of similar quality as any improved northern route to
accommodate the anticipated weekly patterns of commuting from central and
southern England. The interchange hubs along this length of line are also suitable to
accommodate potential additional users. Upgrades along this length of line, and at
interchanges, would also ensure that part of the legacy of this development secures
a better accessed world class tourism destination in western Lake District opening it
up to/from the international southern gateways, including Manchester and the
London airports.
Landscape and visual impact;
1.6
We are pleased that the proposal will be considered with regard to The Cumbria
Landscape Character types and the LDNPA Areas of Distinctive Character and
special qualities of the LDNP. And we note that more work is to be undertaken on
understanding tranquillity and the western part of the LDNP. Our main concern lies
with the possibility of cooling towers and emphasise our desire for off-shore cooling
tunnels.
Historic environment;
1.7
We are pleased to note reference is now made to the pending English Lake District
World Heritage designation, the nomination dossier of which is soon to be submitted
to Dept for Culture, Media and Sport. Whilst we do not see this as a concern we do
need it to be considered.
Socio economics and human population;
1.8
We strongly urge that the project includes consideration of future skills and training
to allow local people to take advantage of the potential employment opportunities.
This will be an important legacy for this development for West Cumbrian
communities. A firm commitment is needed to working with local schools and further
and higher education colleges and universities to further develop a skills base to
meet the needs of the nuclear industry.
2.
Strategy for the permanent development and operation
2.1
The stage 1 consultation sets out the elements which are permanent, such as the rail
spur, workforce station and freight sidings, marine off-loading facility and heavy haul
road.
2.2
The construction strategy of reusing the excavated material from site preparation on
the site is to be encouraged as this will involve a significant amount of material and
where it needs to be removed from site should be used as locally as possible or
transported by rail.
2.3
Some associated development, particularly workforce accommodation, will take
place off site but outside the National Park; two sites at Whitehaven (accommodating
up to 4,000 each), one at Egremont and one at Cleator Moor (up to 1,000 at each
site). Transport to and from the site would rely on rail or coach transfers. Given their
location outside of the National Park we do not intend to comment. We would
however ask that NuGen, in their development proposals consider making best use
of land allocated in Local Plans, including our own Allocations of Land Local Plan,
such as Well Bank at Bootle or Greengarth near Holmrook.
Strategy for the temporary construction phases;
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Authority: 22 July 2015
2.4
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Annex 1 Page 3
We agree with the strategy approach for the temporary construction phases and
welcome means to encourage public transport use with improved rail links and coach
transfers and so discourage private car use particularly from settlements south of the
National Park. Whilst the proposal has potential to improve rail services and
infrastructure there would also be an increase in vehicular traffic which if following
current trends through the National Park, could have implications for local
communities along those routes and the environmental capacity of the road network.
Nuclear related licensing;
2.5
This is subject to other regulatory authorities and therefore we do not wish to
comment on this.
3.
Preliminary environmental information.
3.1
An Environmental Impact Assessment (EIA) is required due to the scale and type of
development. This is will be refined during the on going EIA process. This will
consider a range of issues.
3.2
The stage 1 consultations sets out the potential environmental effects and potential
measures for future mitigation. We have had discussions with NuGen’s
representatives on the initial content of the EIA and this is attached for information as
annexe 3. Further work and consultation has taken place, see annexe 4.
3.3
The preliminary environmental information covers the following topics:
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transport,
noise and vibration,
air quality,
radiological issues,
soils, geology and land quality,
freshwater environment,
marine physical environment,
landscape and visual,
historic environment,
biodiversity,
countryside recreation,
socio economics and human population,
climate change.
Transport;
3.4
We recognise that the existing Sellafield site produces significant traffic through the
National Park from urban populations to the south of the National Park. NuGen
needs to understand this and the issues it creates. And we encourage NuGen to
approach Sellafield and other major employers in the area to see if a co-ordinated
travel plan for this wider area can be developed, in addition to NuGen’s ownPlan.
3.5
We fully support the intended travel hierarchy being promoted by NuGen. We
support the need to minimise the use of the private car, both during construction and
operation phases of the development. The strategy rightly recognises a number of
concerns including delays to road users, deterioration of road infrastructure,
community and amenity effects including severance and we expect these to be
addressed. We are reassured that NuGen is going to engage with us on the matter
of transport issues and recognises that a transport assessment is required to cover
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impacts of the location of worker accommodation, travel to work behaviour, method
of transportation for construction materials and the need for a site specific travel
plan.
3.6
We support the promotion and improvements of rail connections to the site. We note
the potential for increasing the capacity of the existing track to accommodate
movements associated with the Moorside Project such as utilisation of sidings,
passing loops or increased rolling stock. Also new rail links to temporary construction
workers accommodation which would hopefully be retained for the operation of the
power station. We would welcome more information on means of reducing car usage
during operation of the site and the need for a site specific travel plan and how the
transport hubs will work in terms of additional car parking.
3.7
We are however concerned about the resilience of the rail network during adverse
weather and high tides. We would seek assurances that this is considered and the
route upgraded to weather proof the line if necessary, including the single line
between St Bees and Sellafield, and that element of the southern track around
Foxfield.
3.8
Whilst we note the consultation is emphasising the importance of the rail link from
Barrow to Carlisle we urge NuGen to recognise the importance of the southern link
from Carnforth to Moorside. Whilst we commend NuGen’s proposals for addressing
daily commute we remain concerned that the weekly commute patterns may not be
fully addressed. Access to Lancashire, the Midlands and beyond will be incredibly
important with, we believe, significant influx/exodus patterns. The importance of the
southern rail access should not be underestimated and we ask NuGen to future
proof this line to ensure it too is adequate to serve the needs of this development.
Otherwise we fear serious congestion and environmental damage, including to the
fell routes. This rail link also serves as an important southern entry to the Western
Lake District, particularly from Manchester and London. Improvements to this line
would also have the significant benefit of contributing to a tourism industry legacy.
The scope of the improvements to the rail network should be extended to include the
southern West Coast Cumbrian line as far as Carnforth. This should also address
the adequacy of interchange hubs to accommodate commuter traffic. In addition to
extending the travel plan scope to consider necessary upgrading of the southern
West Coast Cumbrian line we are also interested in knowing whether NuGen have
explored, or are interested in exploring, a new line connecting Workington to Penrith,
via Keswick?
3.9
Emergency plans need to be in place should the rail link be compromised to avoid
overloading the capacity of the local road network at such times. We would expect
NuGen to investigate the resilience of the A595 particularly south of Sellafield to
Holmrook.
Noise and Vibration;
3.10
The consultation document indicates the scope of the noise and vibration issues
from construction phase, traffic, rail and operation of the power station and these will
be addressed in the Environmental Impact Assessment. We are not intending to
specifically comments on this issue as this will be addressed by other regulatory
authorities and statutory guidelines.
Air Quality;
3.11
Air pollutants arise from combustion of fuels by mobile and stationary vehicles, plant
and dust from site preparation and construction activity and from stand-by diesel
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Annex 1 Page 5
generators during operation of the proposed power plant. There is legislation
(Directive 2008/50/ EC on Ambient Air Quality and Cleaner Air for Europe (EU
2008)) which provides a new regulatory framework for fine particulate matter as well
as Air Quality Standards Regulations 2010 etc. Air quality will be addressed in the
EIA and the consultation indicates engagement with the appropriate regulatory
authorities. We are not intending to specifically comments on this issue as this will be
addressed by other regulatory authorities and statutory guidelines.
Radiological Issues;
3.12 The consultation document sets out the proposed scope of the assessment relating
to radiological issues, including the assessment of potential effects on humans and
non-human species. There is legislation relevant to the assessment of these effects
such as for example, Environmental Permitting ( England and Wales) Regulations
2010, SI 2010 No 675, The Ionising Radiations Regulations 1999 SI 1999 No 3232,
Nuclear Installations Act 1965, and the Conservation of Habitats and Species
Regulations 2010. This will be addressed in the EIA and the consultation indicates
engagement with the appropriate regulatory authorities. We are not intending to
specifically comments on this issue as this will be addressed by other regulatory
authorities and statutory guidelines.
Soils, geology and land quality;
3.13
The consultation document sets out the strategy for assessing the potential effects
on soils, geology and land quality. Land quality is taken to mean land contamination.
There is a raft of legislation to prevent land and ground water contamination such as
The European Liability Directive as implemented in England by the Environmental
Damage (Prevention and Remediation ) Regulations 2009 (SI 2009/153), Water
Environment (Water Framework Directive) (England and Wales) Regulations 2003,
and Environmental Protection Act 1990 Part 2A and Contaminated Land (England)
Regulations to name a few and including Town and Country Planning Act 1990. The
assessment sets out the potential impacts in terms of contamination from
construction works, change in soil structure and potential receptors that could be
subject to likely significant effects. This will be addressed in the EIA and the
consultation indicates engagement with the appropriate regulatory authorities. We
are not intending to specifically comments on this issue as this will be addressed by
other regulatory authorities and statutory guidelines.
Freshwater Environment;
3.14
The consultation document sets out the proposed scope of the EIA relating to
potential impact on the Freshwater environment. This looks at the areas of potential
impact, topography and watercourses, hydrology, flood risk and water quality and
potential receptors. There is a raft of relevant legislation such as the Water
Resources Act 1991 and other legislation referred to in the sections above. This will
be addressed in the EIA and the consultation indicates engagement with the
appropriate regulatory authorities. Whilst this issue will be addressed by other
regulatory authorities and statutory guidelines we will assist other consultees on this
matter.
Marine Physical Environment;
3.15 The consultation document sets out the strategy for assessing the potential effects
on marine and coastal physical environment, such as water quality and identifies
potential receptors from proposed works such as the Marine Off Loading Facility,
intake and outfall structures. There is a raft of legislation covering protection of the
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water environment. The potential impact will be addressed in the EIA and the
consultation indicates engagement with the appropriate regulatory authorities. We
are not intending to specifically comments on this issue as this will be addressed by
other regulatory authorities and statutory guidelines.
Landscape;
3.16
We are pleased that the proposal will be considered with regard to The Cumbria
Landscape Character types and the LDNPA Areas of Distinctive Character and
special qualities of the LDNP. We have agreed the location points for the viewpoints
and photomontage proposals and have held discussions with NuGen’s
representatives on identifying those sites and important night time views for a lighting
assessment. The methodology to be adopted to assess that impact is appropriate.
3.17
We note that more work is to be undertaken on understanding tranquillity and the
western part of the LDNP. The tranquillity of the fells, valleys and lakes gives a
sense of space and freedom. There is an opportunity for spiritual refreshment a
release from the pressures of modern day life and a contrast to the noise and
business experienced elsewhere. We will engage with NuGen on this matter to
ensure least possible impact on the setting of the National Park,
Visual;
3.18
We note the proposed scope of the assessment relating to visual effects that could
be caused by the Moorside Project and the specific guidance on visual impacts of
nuclear generation in National Policy EN-6. This indicates there is the potential for
long term effects on visual amenity because of the proximity to the Lake District
National Park, and recognition that cooling towers may increase a nuclear power
station’s visual impact on the landscape. The information currently available
indicates that two solutions to cooling water are being considered, direct cooling
which uses sea water or closed cooling which would include cooling towers within
the site and information on this would be made available at the Stage 2 consultation.
From a landscape perspective we would encourage direct cooling rather than closed
cooling as cooling towers would be visually more intrusive on the setting of the
National Park.
3.19
We welcome the engagement by NuGen on the matters of visual assessment. We
are pleased that the study area for visual impact has been extended to the 22km
radius to take account of users of PRoWs and open access land within the LDNP.
We agree the methodology for the evaluation of visual effects.
Historic environment;
3.20
We have commented on the effect on the historic environment in the past in relation
to this site (see annexe 4) but consider this is now covered by the County Council
Archaeologist. We are pleased to note that now there is mention of pending World
Heritage designation and that potential effects on the proposed World Heritage site
of the Lake District will be considered with reference to the existing technical
evaluation of the nomination. We will need to comment on this in the future.
Biodiversity;
3.21
We note the proposed scope of the assessment relating to impact on biodiversity
that could be caused by the Moorside Project and covers marine, terrestrial and
freshwater environments. We recognise survey work which has been undertaken
and engagement with the appropriate regulatory authorities and others
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organisations and groups such as Cumbria Wildlife Trust. We have previously
provided some comments on biodiversity (see annexe 3) and scope of the EIA. We
consider the approach and strategy is appropriate. The potential impact on
biodiversity will be addressed in the EIA and as part of the Habitats Regulations
Assessment. Whilst this issue will be addressed by other regulatory authorities and
statutory guidelines we will assist other consultees on this matter.
Countryside recreation;
3.22
On countryside recreation no potential environmental effects have been identified
and assessed as part of the EIA. We have previously commented that an
assessment of impact on users of the rights of way on the high fells made popular
from the Wainwright guide books should be considered (see annexe 4). We note that
views from the fells are considered in the landscape and visual assessment but the
implications for countryside recreation should also be considered.
Socio economics and human population;
3.23
The potential socio economic impacts of major energy infrastructure include creation
of jobs, additional local services and improvements to local infrastructure, effects on
tourism, and impact on influx of workers on demand for services and facilities. The
impact on housing seems to have focused on Copeland and Allerdale Local Planning
Authorities and not included the LDNP as a planning authority responsible for
identifying land for housing. Whilst most of the housing provision could be met within
the settlements outside the National Park there will undoubtedly be some pressure
on housing within the National Park as occurred with the development of the existing
Sellafield site.
3.24
There is a concern that unless the project includes consideration of future skills and
training for local people to take advantage of the potential employment opportunities,
then there would not be the expected employment legacy for local communities.
Therefore there needs to be a firm commitment to working with local colleges,
schools and Cumbria University to ensure that there is appropriate training available
to meet the needs of the nuclear industry.
3.25
The potential effects on tourism image and perceptions are concluded as not being
significant and do not require further assessment. However the section on
countryside recreation acknowledges that long distance walkers and cyclists would
be affected by severance of long distance route during construction and the potential
deterrent effect on users of the National Trail. Given this has been identified as a
potential issue then the impact on tourism image and perceptions should be
reviewed for temporary impact and long term impact.
Climate Change;
3.26
The scoping report considers the potential effects on the climate and some elements
of the Moorside Project may be designed for climate change adaptation purposes
such as a requirement for enhanced flood control measures because of predicted
sea level rise. The strategy considers there may be opportunities for decreasing
greenhouse gas emissions when selecting alternatives for different aspects of
construction of the project such as when planning the transportation of construction
materials and we would encourage further investigation of this not just for reducing
greenhouse gas emissions but also reducing pressure on the local highway network
and we would encourage use of rail for transportation rather than road.
Our involvement;
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3.27
Agenda Item: 11
Annex 1 Page 8
You will be aware that, despite our requests, we are not party to the Planning
Performance Agreement between NuGen and the Planning Authorities. We do not
believe this is acceptable given our level of involvement, albeit on specific matters.
Our primary concerns relate to the effect of the proposal on the setting of the
National Park and also the impact of infrastructure, both on the setting but also
potentially direct impact. We ask that NuGen recognises the level of resources that
our involvement in these matters may require and enters into some form of
agreement to recognise this.