P-05-837 Green Energy for the Wellbeing of Future Generations in Wales, Correspondence – Petitioners to Committee, 11.11.19

PO Box 90. Llandrindod Wells. Powys LD1 9BP info@wana.wales


                                                                                      November 11th 2019


 “ Green Energy for the Wellbeing of Future Generations”

We call on the National Assembly for Wales to urge the Welsh Government to Invest in green renewable energy sources thus reducing the need for fossil fuels and nuclear energy in Wales.  …….. ……(AN UPDATE)


WANA presented evidence in relation to the above petition in October and again in November 2018, we also wrote to the then Chair - Mr Rowlands AM on January 22nd 2019 (in light of the postponement of Wyla Newydd ) asking the Petitions Committee to ask Welsh Government to :

·         step-up actions to invest  more in low carbon renewable technologies NOW as Wylfa Newydd has been a costly distraction,.

·         ensure  money allocated to Wylfa is made available to develop a job intensive conservation and renewable energy programme for Wales,

·         take the opportunity to revise the Welsh Government’s energy strategy, take control and ensure the resources are re-invested into  renewable energy programmes that directly benefit  Wales.(Westminster has visibly failed in making good choices whilst holding the energy portfolio.)

 Since then the Welsh Government has declared a Climate Change Emergency and has outlined measures to tackle this in Wales, which we applaud.



Climate change is the most important issue facing us today. We know we have to cut our emissions and move towards a green energy future, and the Welsh Government is taking steps to do this. However, the people who signed this petition take the view that nuclear power has NO part to play in a low carbon future for Wales. 


We contend that Wylfa Newydd and any talk of Advanced Nuclear Technologies(ANTS) / Small Modular Reactors (SMR’s) are :

1.    Not low carbon options

2.    Are a costly distraction to meeting climate change targets

3.       Likely to be located where climate change may have dire consequences

4.       Are at variance with Welsh Government policy


There is now substantial evidence that Wales can become 100% self –sufficient in energy without any input from nuclear. Both the Institute for Welsh Affairs (IWA) and Zero Carbon Britain show how it can be achieved.


Wales should follow the lead of the Scottish Government which has stated its …” continued opposition to new nuclear stations under current technologies. And is moving ahead with ambitious targets to cut emissionshttps://www.gov.scot/publications/scottish-energy-strategy-future-energy-scotland-9781788515276/


WANA recently received a letter from The Secretary of State (Dept.Business, Energy & Industrial Strategy) regarding the Planning Inquiry into Wylfa Newydd. The letter asks for comments on the Application and notifies us of the Secretary of State’s decision to set a new date for the determination of the Application  - EN010007. WANA will be making the following points under Item 36 ie. . Welsh Planning Policy & Climate Emergency Declaration : 


1. Nuclear power is not low carbon.


The nuclear fuel cycle is a filthy, dangerous and unhealthy process leaving a legacy of radioactive wastes at all stages; from fuel production to decommissioning. Uranium the vital fuel component for nuclear reactors is a finite resource, its production is energy intensive and it travels an average distance of 2,500 + miles before it reaches us. Greenhouse gases are emitted at all stages of the nuclear cycle and no solution has yet been found for nuclear waste disposal .


In January 2019 the Welsh Government released its summary of responses on the consultation on “ Geological Disposal of Radioactive Waste - Working with Communities” . As a result 86 county, city, town and community councils in Wales have passed motions declaring their total objection to nuclear waste disposal in their communities despite financial bribes. It is immoral for us to go ahead and produce  more nuclear waste when we are unable to take responsibility for existing  waste.


2.  Nuclear plans for Wales are a costly distraction to meeting our climate change targets


According to the latest research we have 12 years to act on climate change before it becomes seriously problematic. Currently Wales generates no energy from nuclear and the most optimistic scenario for new nuclear generation at Wylfa Newydd was 2027 so why waste time we need to act now.

The Institute of Welsh  Affairs Report “ The Economic Costs and Benefits of Renewable Energy Transition in Wales “ shows that the development of an energy system that can enable Wales to become 100% self-sufficient in renewable electricity by 2035, requires around £25bn of investment in renewable electricity generation, and £5bn in domestic energy efficiency interventions. This analysis also shows that some 40% of renewable electricity  spending could potentially be captured by Wales, along with 70% of domestic energy efficiency  spending. In addition these investments could support some 20,150 jobs annually across Wales during the investment period . AND there is no need for nuclear power



The Zero Carbon Britain Project offers hard data and the confidence required for visualising a future where we have risen to the demands of climate science. It shows we can provide a reliable energy supply for the UK with 100% renewable energy sources and flexible carbon neutral back up - without fossil fuels, nuclear power, or gambling on the promise of future technology



The Future Generations Commissioner for Wales White Paper:  “Ten Point Plan to Fund Wales Climate Emergency”  (June 2019) outlines  10 areas for investment. Under Point 6 The Report suggests that £200 million be set aside in the next budget (2020-21) for renewable energy. https://futuregenerations.wales/resources_posts/10-point-plan-to-fund-wales-climate-emergency/


Estimated costs of building Wylfa Newydd lie in the region of 15 -20billion and rising and that does not include waste management and decommissioning. In January 2019 work at Wylfa was suspended by Hitachi due to rising costs and in July 2019 accounts filed by Horizon Nuclear Power Ltd cut the value of the land and equipment by 1.2 billion as it is not intending to build at Wylfa. Even so there is still a lobby to push ahead with nuclear developments in Wales with little evidence of progress.

In July 2019 a Report – “ NCG / NFLA report – Prospects for Small Modular Reactors in the UK and Worldwide” was published. This Report outlines in detail the  huge obstacles to overcome. Some of these are technical, others are around building up an effective supply chain, while the financing of such schemes will only be possible with significant and large subsidy from the public purse.

…” Spending so much time and effort pursuing such an uncertain technology, at a time when the ‘climate emergency’ has now reached the political and public lexicon in requiring urgent attention, does not appear to be an effective use of taxpayer resources. Abundant evidence shows that renewable energy supply, storage, distribution and management technologies are being developed ever cheaper and swifter at a time when real urgency is required across society and government to mitigate the worst effects of climate change. SMRs are no answer to creating low-carbon economies by 2030 or close to that date.” ……..



3. Concerns  about the actual Wylfa Newydd site re. climate change


On January 11th 2019 at the Issue Specific Hearing re. Granting Development Consent for Wylfa Newydd  (Item on Climate Change). WANA asked for reassurance that up- to- date data on sea level rise had been incorporated into the Application for Wylfa Newydd – we were shocked to hear that   2009 data had been used to estimate the likely flood / sea level rise for the site.

A number of reports published in 2018 suggest that climate change will impact on coastal nuclear plants earlier and harder than the industry, governments or regulatory bodies have expected, and that the safety standards set by national nuclear regulators and the IAEA, are out of date and take insufficient account of the effects of climate change on nuclear power. https://www.nasa.gov/feature/goddard/2018/new-study-finds-sea-level-rise-accelerating

Sea level rise data for 2018 is available  and it shows a significantly worse picture than the 2009 data SO both Horizon and NRW are  taking a view that is dated and possibly  inaccurate. 

Flooding at a nuclear site can be catastrophic as was shown at the Fukushima Daiichi plant in Japan. This was as a result of the March 2011 tsunami which caused severe flooding damage to several of the plant’s reactors. Further flooding in October 2019 brought by Typhoon Hagibis  led to 2,667 bags stuffed with radioactive contaminants being released into a local stream.(Taiwan News)


4. Any new nuclear development s in Wales are at variance with Welsh Government Policy and the Climate Emergency Declaration.


4.1 Devolution

In relation to the Welsh Government energy policy has not been totally devolved but things have recently altered. In April 2019 the Welsh Government received greater permitting and consenting powers which are expected to a)  allow Wales to exercise more influence over levels of emissions and b) expand Welsh Ministers’ decision-making remit from 50MW onshore to 350MW (on and off shore for the power sector).


4.2 The   “Wellbeing of Future Generations Act (Wales) 2015” .

Any new nuclear developments in Wales, in our view, are at variance with the    “Wellbeing of Future Generations Act (Wales) 2015” . This flagship legislation offers a huge opportunity to make long-lasting, positive changes for future generations around clean energy. Any new developments will increase our legacy of radioactive waste that future generations will have to manage .


A key theme of “Prosperity for All – A Low Carbon Wales” …..”Our climate change ambitions also have wider implications such as improving the health of our nation and resilience of our natural environment….” Substantial evidence was provided by NGO’s in North Wales at the Wylfa Planning Inquiry about the effect of such a huge nuclear development on the nature reserves and SSI’s on Ynys Mon.  We believe that upwards of 750 acres of such land will be destroyed.


4.3 Planning Policy Wales 

Planning Policy Wales (PPW), which was launched in December 2018, will underpin all future planning decisions onshore…….

…..”  PPW will help to ensure that the planning decisions taken in Wales, no matter how big, or how small, are going to improve the lives of both our current and future generations. It will support changing the way we live and work, and the buildings and environment of Wales, today, building a better environment to accommodate current and future needs.” 

 It puts an emphasis on people and places and will ensure developments built today leave a legacy of well-designed, sustainable places that improve lives. Planning is a key lever for Wales in determining the sources of fuel for power generation.



4.4 Section 6 Duty  – Biodiversity and resilience of ecosystems duty

Part 1 of the Environment Wales Act 2016 outlines the Section 6 Duty which introduced an enhanced biodiversity and resilience of ecosystems duty for public authorities in the exercise of functions in relation to Wales. The S6 duty requires that public authorities must seek to maintain and enhance biodiversity so far as consistent with the proper exercise of their functions and in so doing promote the resilience of ecosystems. http://www.legislation.gov.uk/anaw/2016/3/contents/enacted