Tuesday, 22 December 2020
Sizewell C documentation secrecy just a continuation of lack of transparency by the nuclear industry
Between 18 November and 18 December 2020, NNB Generation Company (SZC Co.) carried out a public consultation on the proposed changes (dated 23 October 2020) for an Order Granting Development Consent for The Sizewell C Project. The document launching this supplementary consultation noted: “In January 2021, SZC Co. will submit a formal application to change the Sizewell C DCO application, as well as some Additional Information (i.e. information that has been developed in response to continuing engagement with stakeholders and which adds to the detail available within the application (but does not change it)).” One of the supplemental documents submitted by SZC co. was on “Main Development Site Flood Risk Assessment,” a not inconsequential matter, in the context of climate change –induced sea-level rise, and greater perturbations in extreme weather ( storms, rainfall increase etc) over the time period SZC would operate, if ever built. (https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/EN010012/EN010012-001715-SZC_Bk5_5.2_Appx1_7_MDS_Flood_Risk_Assessment_Part_1_of_14.pdf) The new mini-consultation letter then added under the headline Information Redacted or Marked as Confidential, the following: “The Procedural Decision requested clarification on the reasons for redactions and confidential marking on a number of the application documents. A summary of reasons is provided in Table 2. SZC observes in these reasons for redaction that “comprehension of the report is not affected by this redaction.” The Planning inspectorate was no convinced by this assertion, and responded in a rejoinder letter on 22 December stating it was dissatisfied with “the extent and nature of the commercially sensitive aspect of these documents” and pointedly asked “why this could not be redacted without rendering them incomprehensible?” Here is the full section outlining the Planning Inspectorate’s disquiet with SZC Co’s secrecy. Request for further clarification and documents from the Applicant Confidential documents “The Applicant’s response letter dated 16 November 2020 [AS-006] to the ExA’s procedural decision [PD-005] sets out at Table 2 a summary of its reasons for redactions and confidential markings. For certain documents [APP-292 to APP-295], the Applicant states that: “As these reports are not required in order for the Examining Authority to examine the application, we therefore request that these reports are withdrawn from the application.” However, the commercial sensitivity of the investigations and data set out in these Environmental Statement (ES) Appendices is not immediately apparent. Furthermore, they comprise part of the ES which was submitted as part of the application and considered as such when the decision [PD-001] to accept the application was made. The Applicant is therefore requested to provide a further explanation in relation to: (i) The extent and nature of the commercially sensitive aspect of these documents and why this could not be redacted without rendering them incomprehensible; (ii) The justification for them not being required in order for the ExA [Examining Authority] to satisfactorily examine the application and to properly assess the basis for the related conclusions and findings in the main parts of the ES.” It adds: The additional information that is sought in respect of these confidential documents will assist the ExA to assess the potential implications of that course of action and reach an informed decision on the question of their withdrawal.” (National Infrastructure Planning, Planning Inspectorate, Document Reference: EN010012, 22 December 2020; https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/EN010012/EN010012-002699-Sizewell%20PD4%20-%20Rule%2017%20VE%20Q.pdf) This is just the latest of a very, very long line of unacceptable secrecy incidents by nuclear power plant operators, and demonstrates that notwithstanding their protestations as to transparency, they remain in fact addicted to secrecy.