The Sizewell B nuclear plant rises above RSPB's Minsmere nature reserve. Now, where's Sizewell C's 1,600 m3 a day of extra mains water demand going to come from? Photo: Tony Sutton via Flickr (CC BY-NC-ND).
Sizewell C consultation: EDF 'forgets' to mention 600,000 m3 a year of mains water
23rd January 2017
In its second consultation for the EDF's planned Sizewell C nuclear power station there's a strange omission, writes Peter Lux: that the plant would use 1,600 m3 of mains water a day, adding to stresses on important local wetlands like RSPB's Minsmere reserve. The omission is not just strange - it's also illegal and could make the entire exercise invalid.
The fact that EDF have completely ignored the question of mains water use despite it being queried by respondents in the first consultation and as early as 2010 shows that EDF have a complete lack of respect for the consultation process and local people.
One 23rd November EDF launched its Second Consultation Document over its proposed Sizewell C nuclear power station on the Suffolk coast.
But here's a funny thing. The 321-page document makes no mention at all about the use of mains water.
When I asked a Sizewell 'expert' during the Stage 2 Consultation roadshow, he was unaware that Sizewell C would require 1,600 m3 of mains water per day, and thought that I was asking about water that would be used to make tea and flush the toilets.
When I explained how much water would be required, he suggested that it was not EDF's problem as they would just buy the water from the water company and let them work out where it is to come from.
That answer was wrong: EDF has an obligation under the government's national policy statement for energy to submit an an environmental statement which includes details of how much water in intends to abstract and what impact this will have on existing water resources:
"5.15.3. The ES should in particular describe ...existing water resources affected by the proposed project and the impacts of the proposed project on water resources, noting any relevant existing abstraction rates, proposed new abstraction rates and proposed changes to abstraction rates (including any impact on or use of mains supplies and reference to Catchment Abstraction Management Strategies)" 
EDF is also required to set out their strategy for mains water use in order to comply with The Suffolk Ecology Principles for Sizewell C, which state:
"The anticipated levels of water use and a suitable potable water source for the development must be identified to ensure there is adequate capacity and that this can be achieved in a sustainable manner that will not have an adverse effect upon river flows or wetland sites." 
Twenty percent of Sizewell's local water resource for the power plant
Sizewell B currently uses around 800 m3 of mains water a day, which is 7% of of the total demand of the local catchment area, which includes a number of important wetlands among them RSPB's iconic Minsmere nature reserve. 
The twin-reactors of Sizewell C would require at least 1,600 m3 of mains water per day in order to cool various parts of the plant including the primary and secondary circuits of the reactor, which means approximately 20% of the water from the local catchment area would be taken by the power plant.
The East Suffolk Catchment Abstraction Management Strategies (CAMS) covers an area of 1,364 km2 and includes Felixstowe, Ipswich, Woodbridge, Wickham Market, Stowmarket, Saxmundham, Halesworth, Southwold and Kessingland. 
Households in Suffolk are being asked to conserve water because it is recognised that this is one of the driest regions in the country and there is little scope for abstracting more water from local water sources. 
The committee on climate change report 'UK Climate Change Risk Assessment 2017'  cites "Flooding and coastal change risks to communities, businesses and infrastructure" as the biggest threat that comes with climate change the top six risks also includes "Risk of shortages in the public water supply, and for agriculture, energy generation and industry."
The report goes on to say: "Climate change is projected to reduce the amount of water in the environment that can be sustainably withdrawn whilst increasing the demand for irrigation during the driest months. At the same time the growing population will create additional demands on already stretched resources in some parts of the country. Even low population growth and modest climate change scenarios suggest severe water supply deficits." 
A shocking disrespect for process and local people
The impact that Sizewell C will have on the mains water supply was recognised and flagged up during the Stage 1 Consultation by individuals and in the response from Leiston Town Council:
"9.5 There are serious issues concerning Leiston-cum-Sizewell Town Council regarding potable water. It is unclear from the information provided what the actual intake of water associated with Sizewell C is going to be, and how much will be needed for the reactors. Leiston-cum-Sizewell Town Council has been informed that, with the intake of Sizewell B, the potable water situation in the area is currently only just in balance." 
And now (25/01/17) a reader has written in with important further information. Emma Bateman contacted Essex and Suffolk water to find out where reference to Sizewell C's water appears in the Essex and Suffolk Final Water Resources Management Plan 2014, which gives a forecast of local water use up to 2040.
Section 4.8 details new customers requiring over 10,000 cubic meters of water per year. This should include Sizewell C as it would need about 1,600 cubic meters per day. But according to the report "no new identified customers will open during the forecast period."
On the 20th of January Bateman spoke to Julie Maxwell, developer team leader at Essex and Suffolk water, who said:
- she knew nothing about Sizewell C and its possible demand for mains water;
- she had not been contacted by anyone from EDF or Sizewell;
- and EDF have made no application for mains water or even indicated that they might need any for Sizewell C.
The fact that EDF have completely ignored the question of mains water use despite it being queried by respondents in the first consultation and as early as 2010  shows that EDF have a complete lack of respect for the consultation process and local people.
Furthermore they have an irresponsible blasé attitude to where the water will come from over the next 60 years.
Christmas: a good time to hide a consultation
The Stage 2 Consultation for the proposed Sizewell C nuclear power station runs from 23rd November 2016 until 3rd February 2017 . As with the Stage 1 consultation this runs over the Christmas / New Year period.
In effect this significantly cuts the consultation period due to the disruption caused by the extended holiday period.
The probability of the 72 day consultation period starting by chance before 25 December is 72/365 which is a about 20%. The probability of this happening twice by chance is 20% x 20% which is about 4%.
Well we could just be unlucky.
As indicated above I am currently looking at local water resources. Interestingly we also received an email from Northumbrian Water Group (NWG) on the 6th December about their consultation which ran from the 6th December 2016 until 6th January 2017 . Again this runs over the holiday period.
Initially I searched for Essex and Suffolk Water which I now know is part of NWG. While I was looking I found another consultation, this time by Essex County Council which runs from 16th December 2016 until 31st January 2017. 
It is impossible to draw any firm conclusions but this does make me suspicious that some consultations are being deliberately run over the Christmas holiday period.
Private Eye  claim that the Department for Business, Energy and Industrial Strategy release 51 energy documents on Christmas Eve. Again this could just be a coincidence but it does make you wonder ...
Peter Lux writes on a variety of themes on plux.co.uk.
1. Overarching National Policy Statement for Energy (EN-1), Department of Energy and Climage Change UK), July 2011 (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/47854/1938-overarching-nps-for-energy-en1.pdf)
2. Suffolk Sizewell C Ecology Principles, Suffolk Coastal Council, January 2014 (http://www.eastsuffolk.gov.uk/assets/Planning/Sizewell/JLAG-Final-SZC-Suffolk-Ecology-Principles-24-01-14.pdf)
3. Sizewell C ‘threat to water supplies', Beccles and Bungay Journal, 8 March 2010 (http://www.becclesandbungayjournal.co.uk/news/sizewell_c_threat_to_water_supplies_1_555834)
4. East Suffolk Abstraction Licensing
Strategy, Environment Agency (UK), February 2013 (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/289827/LIT_7741_616823.pdf)
5. UK Climate Change Risk Assessment 2017, Committee on Climate Change (UK), July 2016 (https://www.theccc.org.uk/wp-content/uploads/2016/07/UK-CCRA-2017-Synthesis-Report-Committee-on-Climate-Change.pdf) page 2.
6. UK Climate Change Risk Assessment 2017, Committee on Climate Change (UK), July 2016 (https://www.theccc.org.uk/wp-content/uploads/2016/07/UK-CCRA-2017-Synthesis-Report-Committee-on-Climate-Change.pdf) page 4.
7. Sizewell C Stage 1 Consultation Response, Leiston-cum-Sizewell Town Council, 30 January 2013 (http://www.leistontowncouncil.gov.uk/
8. EDF Energy's proposals for a new nuclear power station on the Suffolk coast, EDF (http://sizewell.edfenergyconsultation.info/szc-proposals/stage-2/).
9. Draft Assurance Plan Summary, Northumbrian Water Group (NWG), (http://communicatoremail.com/FS/1448/Documents/PC 0171 Assurance Plan Summary 2017-18 OR FINAL.pdf)
10. Primary School Places in Colcheste, Essex County Council, December 2016 (https://www.essex.gov.uk/Education-Schools/Schools/Delivering-Education-Essex/School-Organisation-Planning/Documents/Primary_places_in_Colchester_consultation.pdf).
11. Keeping The Lights On, Private Eye 1435.
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