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Former US President George W. Bush Snr may have famously said that ‘the human being and fish can coexist peacefully’, but the UK/Ireland Nuclear Free Local Authorities believe that EDF Energy’s plan to scrap the commitment to install acoustic fish deterrents at its new Hinkley Point C plant will end that peaceful co-existence with billions of fish being endangered.
Responding to a public consultation launched recently by the Environment Agency seeking views on a proposal by French nuclear power developer EDF Energy to scrap the deterrent mechanism at Hinkley, Councillor David Blackburn, Chair of the NFLA English Forum called it an ‘enormous tragedy’. A plant like Hinkley Point C ‘hoovers up’ millions of gallons of water daily to cool its reactors, discharging the heated water back out to sea. Unfortunately, with the intake of the water will come the fish, and although EDF is proposing to install some mechanisms to prevent the ingress of fish and marine life into the plant, it has consistently made plain its opposition to the installation of acoustic fish deterrents.
Councillor Blackburn is, like local campaigners, concerned that without Acoustic Fish Deterrents, alongside other measures for marine life preservation, millions of fish will be killed every day, and the group Stop Hinkley, which is opposed to the construction of the plant, has estimated that up to 11 billion fish could die through operations there over the course of its expected 60-year lifespan.
Councillor Blackburn said: “The Bristol Channel and the adjoining Severn Estuary represent an important and protected aquatic habitat in the UK for migrating and spawning fish, yet this environment is fragile with declining stocks.
“The NFLA believes that the consequences of any concession by the Environment Agency to EDF Energy to remove the acoustic fish deterrents will be catastrophic for the local fish population and marine environment.
“EDF Energy could have chosen to ‘do the right thing’ and conceded that they needed to take a financial hit and incorporate their installation within the plans for the development of the plant, but instead they still want to circumvent the agreed terms of their operating permit to save time and money.”
The NFLA is urging all people and organisations opposed to EDF Energy’s plan to make plain their objections by the closing date of 2nd March by sending an email to psc-waterquality@environment-agency.gov.uk or logging online to the consultation portal at https://consult.environment-agency.gov.uk/psc/ta5-1ud-nnb-generation-company-hpc-limited-v005
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For more information, please contact Richard Outram, NFLA Secretary by email to richard.outram@manchester.gov.uk or by mobile phone on 07583 097793
Notes to Editors
The letter submitted to the Environment Agency by Cllr Blackburn dated 6 February reads:
Objection to variance of operational water discharge activity permit applicable to NNB Generation Company (Hinkley Point C) – Ref EPR/HP3228XT/V005
As Chair of the English Forum of the UK/Ireland Nuclear Free Local Authorities, I wish to place on record our organisation’s strong objection to the application made by nuclear power generating company, EDF Energy, to vary the permit applicable to the operation of the future Hinkley Point C nuclear power plant by removing the requirement that an Acoustic Fish Deterrent be placed upon each of its two offshore massive cooling water intake heads.
The developer is seeking once more to vary the operational Water Discharge Activity permit, which included incorporating three mitigation measures to protect aquatic life within the cooling water system: an Acoustic Fish Deterrent, Low Velocity Side Intakes and a Fish Recovery and Return system. For a second time, EDF Energy is attempting to browbeat the Environment Agency into conceding to their demand for the removal of the Acoustic Fish Deterrent, despite this requirement being upheld by a highly qualified inspector and reaffirmed after a full reconsideration of the Secretary of State of the Environment.
EDF Energy could have chosen to ‘do the right thing’ and conceded that they needed to take a financial hit and incorporate their installation within the plans for the development of the plant, but because Hinkley Point C is, like the company’s other headline nuclear projects at Flamanville and Olkiluoto, massively over budget and behind schedule, they have chosen instead to seek to shirk their responsibility to the natural environment. We contend that rather than any concession on this matter being ‘essential’ ‘for the delivery of this vital piece of national infrastructure’, as Chris Fayers, Head of Environment for Hinkley Point C, has claimed in a statement to the local media, that this resubmission for a variance is being made by EDF Energy to save money, save time, and set a dangerous precedent to also avoid any requirement for AFD at any future new development initiated by the company in the UK.
We believe that the consequences of any concession will be catastrophic for the local fish population and marine environment.
The Bristol Channel and the adjoining Severn Estuary represent an important and protected aquatic habitat in the UK for migrating and spawning fish, yet this environment is fragile with declining stocks. It is home to both common fish species (such as river lamprey, twaite shad, sprat, herring and the common goby) and rarer species (such as salmon, cod, anchovy, John dory, crucian carp, silver bream, and sea lamprey). These fish migrate from the Bristol Channel into nine adjoining rivers, the Ely, Taff, Rhymney, Ebbw, Usk, Wye, Severn, Avon, and Parrett.
Hinkley Point C will daily take millions of gallons of water from the Bristol Channel to cool the plant and then discharge this heated water back into the sea. Without Acoustic Fish Deterrents, alongside other measures for marine life preservation, millions of fish and other forms of sea life will also be sucked into the plant every day and killed. Unmitigated, operations at Hinkley Point C will also drastically reduce the number of eels successfully making the long journey back to the Sargasso Sea breeding grounds.
The campaign group, Stop Hinkley, representing local people with a concern for their natural environment, has estimated that 11 billion fish could be killed during the 60-year likely operating life of the Hinkley Point C nuclear power plant. Such a loss to our natural environment would represent an enormous tragedy.
Consequently, the NFLA does not believe that it is reasonable for the Environment Agency to remove the requirement that EDF Energy install Acoustic Fish Deterrents at its water intake heads, and therefore wishes to register its strong objection to any proposal to do so as part of this consultation.
Please publicly record us as an objector and notify us of the outcome of the consultation, by email to NFLA Secretary Richard Outram at richard.outram@manchester.gov.uk Thank you.
Yours sincerely,
Councillor David Blackburn,
Chair of the English Forum,
On behalf of the UK/Ireland NFLA Steering Committee
