The content of this e-journal was for the most part originally prepared for Nuclear Free Local Authorities (Scotland) and is reproduced, as adapted, with their permission but without liability for its contents.
3.0 The Energy Bill
1.1 Since the publication of the David Hume Institute report in April, which argued that nuclear power is half the price of wind power, (using costs from an earlier Royal Academy of Engineering (RAE) report) the debate on whether the UK should build new nuclear stations has continued. Professor James Lovelock, enlivened the debate with an article in The Independent in May, arguing that nuclear power is the only answer to climate change. The counter arguments are set out in the Nuclear Free Local Authorities’ New Nuclear Monitor No.7 June 2004. (not yet on the website http://www.nuclearpolicy.info/ so e-mail email@example.com for a copy).
1.2 Dr Catherine Mitchell of Warwick Business School and member of the Government’s PIU Energy Review Team, speaking at the Friends of the Earth “Meeting Scotland’s Energy Needs” Conference in Edinburgh on 21st May said:
"The PIU examined the cost of nuclear power, both current and future, in great depth. It concluded that the figures put forward by the nuclear industry are extremely optimistic and PIU’s own figures were much higher. Now, bodies such as RAE are giving the cost of nuclear power as those put forward by the nuclear industry without including other evidence based analyses, such as the PIU. It is extremely depressing that after 2 years of evidence based analysis by the Government, energy institutions continue to provide out of date and probably wrong information."
1.3 Tony Blair told the House of Commons Liaison Committee  on 6th July that he had:
“… fought long and hard, both within my party and outside, to make sure that the nuclear option is not closed off [but] we are going to have to do a lot more work on reassuring people both on the cost and on the safety grounds and we are going to have to have a debate in which people understand the science and … the difference between a nuclear power station and the development of nuclear weapons … I think within the next few years there are some very difficult decisions that we will have to take on this.”
Blair also disclosed that America is pressing Britain to look again at the nuclear option. Tony Juniper, Director of Friends of the Earth, said:
"It took months to hammer out a policy in the white paper and nothing has happened since to change the basics, which were that energy efficiency and renewables were the best bet. It would be 15 years before there was one kilowatt of energy from a new nuclear station."
1.4 Although Blair was doing little more than re-iterating current government policy, the Guardian’s reporting of his comments re-ignited discussions about new nuclear build in the UK.  Scotland on Sunday  is convinced that the Scottish Executive will repudiate the Scottish Executive Partnership Agreement in which the two coalition parties say they “will not support the further development of nuclear power stations while waste management issues remain unresolved”.  Quoting only what it called “a senior nuclear industry source”, it said Hunterston, Chapelcross, or even Torness, are possible sites.
1.5 An opinion piece in The Daily Telegraph, which concluded that nuclear appears to be the only viable option, because renewables are “unable to provide security of supply” and “reserves of gas and oil running out” was typical of other follow-up coverage.  Even The Observer asked “when does the government expect the lights to start going out round Britain?” and said we urgently need a commitment to a modest nuclear programme. 
1.6 John Vidal, in The Guardian on 12th August  summarised the recent debate. Some of what Vidal described as “Britain’s leading environmental thinkers” are calling for a debate about whether nuclear needs to be reassessed. Besides James Lovelock, he mentioned Sir John Houghton, former head of the Met Office and the UN’s intercontinental panel on climate change; Sir Crispin Tickell, former UK ambassador to the UN, who famously convinced Margaret Thatcher that Climate Change is a problem; and Paul Allen, development director at the Centre for Alternative Technology in Machynlleth. On the back of anti-wind power sentiment voiced by celebrities like David Bellamy and Sir Bernard Ingham, the nuclear industry is now working with the Bush administration to persuade governments to commission a new generation of stations. In Britain, the crunch will come in 2006 – if wind power is found not to be meeting targets then pressure to commission new nuclear stations will be enormous.
1.7 The counter argument is that nuclear stations would take eight to 15 years to build, and almost that long to start repaying their financial and carbon investments. Renewables and energy conservation can deliver the cuts immediately. All that is needed is the political will. Even if nuclear were the best option to tackle global warming, it’s likely to fail again on cost grounds, according to the Rocky Mountain Institute, the US energy consultant which advises governments and big companies. "Each dollar invested in electric efficiency displaces nearly seven times as much carbon dioxide as a dollar invested in nuclear power, without any nasty side effects. If climate change is the problem, nuclear power isn’t the solution. It’s an expensive, one-size-fits-all technology that diverts money and time from cheaper, safer, more resilient alternatives."
1.8 The obvious question is: ‘is the Government doing enough to promote energy efficiency and renewable technologies, or is it simply waiting until after the next General Election before it approves new nuclear construction?’ The Appendix gives a brief survey of what the Government is doing on energy efficiency and concludes that much more could be done.
1.9 On whether the Government is doing enough to promote renewable energy, a scathing report by the House of Lords Science and Technology Committee published in July  concluded that it could fall 40% short of its 10% renewable energy target for 2010. Chairman Lord Oxburgh, said it could not avoid the conclusion "that the government are not taking energy problems sufficiently seriously". It deplored the minimal sums going into research and development of renewable energy sources, pointing out that they were less than a twentieth of that spent in the US. The Committee singled out the Ministry of Defence for criticism, saying that some of its arguments around new wind farm developments were "extraordinary" and "implausible". Lord Oxburgh concludes: "The government seems to believe that market forces alone will prevent the lights going out – we’re not so sure." The committee said it "found almost no one outside government who believed the white paper targets were likely to be achieved", and too much emphasis is placed on wind farms when a more diverse portfolio of renewable energy is needed. It said "Government may have no option but to follow the lead of other countries and accept that new nuclear build might be necessary".
1.10 The Department of Trade and Industry recently announced a £50 million fund to make Britain the world leader in wave and tidal power technologies. However, private financiers and politicians have criticised both Westminster and the Scottish Executive for not going far enough to ensure the dominance of the UK’s fledgling industry, estimated to have the potential to create 7000 jobs in Scotland. Venture capital firm 3i, which has invested in Scottish firms Ocean Power Delivery and Wavegen, said the Government should have pledged between £100-150m. Britain has leading expertise in wave and tidal generation but Portugal, Spain and Ireland are pulling ahead because their governments are willing to back ambitions with far more cash.
1.11 Meanwhile, in a surprise move BNFL closed down the Chapelcross nuclear power station at the end of June. The station had not been due to close until next year, but BNFL said the 45-year-old reactors were too expensive to operate. BNFL is now negotiating with Edinburgh-based Scottish BioPower about using the generating turbines in a new bio-fuels plant to be built at the site. Initially it would burn a mix of wood and coal, but eventually it would be fired solely by fast growing willow. The new power station, which is expected to cost more than £30m, would create hundreds of construction jobs and about 70 full-time posts when operational. 
1.12 New Nuclear Monitor No.7 reported that the NII is maintaining “a watching brief” on BNFL’s favoured reactor-type, the Westinghouse AP1000, by staying in regular contact with the US Nuclear Regulatory Commission (NRC), which is currently undertaking a design certification process for the reactor design and has informally set a target date of December 2005 for completing its review. The NRC is already running workshops in China on AP1000 design certification issues, and is due to issue a final safety evaluation in September 2004; and give final design approval in October 2004. It says completion of the Design Certification Process by December 2005 is dependent on the extent of any design changes necessitating NRC staff review, additional regulatory requirements, and the duration of hearings.  It is unclear whether the nuclear industry will use the final design approval in October 2004 or completion of the certification process in December 2005 to declare the reactor design approved.
 Scotland on Sunday 11th July http://news.scotsman.com/scotland.cfm?id=793492004
 Observer 15th August http://observer.guardian.co.uk/comment/story/0,6903,1283376,00.html
 Sunday Times 8th August http://www.timesonline.co.uk/newspaper/0,,2761-1207181,00.html
2.1 The Environment Agency will implement new radioactive waste discharge authorisations at Sellafield from 1 October 2004. It says these will lead to reductions in radiation exposure at the authorised limits of 35% for liquid discharges and almost 60% for gaseous discharges. The Agency first published its proposals for the new authorisations in August 2002, after public consultation. Following submission of the proposals for ministerial review, the decision has been revised and the changes are set out in an Update document published by the Agency in August. 
2.2 A decision regarding the Agency’s August 2002 Proposed Decision Document has not been made by Ministers but the Government has indicated that it is content for the Agency to proceed, whilst reserving the right to intervene at a later stage if deemed necessary.
2.3 The two main changes since August 2002 are the success of the Technetium-99 (Tc-99) abatement process and the closure of the Calder Hall Magnox reactors. The Tc-99 limit has been reduced from 90TBq to 20TBq initially and 10TBq from 2006. This may be a disappointment to the Irish and Norwegians who may have expected the limit to go straight down to 10TBq. The closure of Calder Hall means that Sellafield no longer needs to discharge the radioactive gas Argon-41. This will lead to a reduction of about 70% in the dose to the critical group as a result of gaseous emissions – so is a major gain.
2.4 Other minor changes have resulted from an Agency inspection of Sellafield in April 2004 to review BNFL’s readiness to implement the new authorisation, and information supplied by BNFL in support of these minor changes. For example, the Agency has postponed until 2007 the introduction of a new site limit for the radionuclide antimony-125 in liquid discharges, pending more information from BNFL. There have also been various changes made to the annual limits for certain individual facilities, but none of the changes affect overall site limits.
2.5 Amongst the documentation issued by the Agency is a 49-page submission by BNFL arguing for the various changes. This report gives some valuable insights into why BNFL might ask for some increases in discharge authorisations during the decommissioning process. But it is noticeable that any BPEO processes undertaken at Sellafield to decide on the best methods of decommissioning do not appear to have involved public consultation as at Dounreay.
2.6 The EA’s update document fails to address gaseous discharges of Krypton-85 (Kr-85) – responsible for a large collective dose around the globe. BNFL is required to carry out on Kr-85 abatement "unless the company is able to satisfy the Agency that the currently projected lifetime [of THORP] is unlikely to be extended for a significant period beyond 2016".
2.7 None of the Agency’s changes affect the main criticism of the August 2002 proposals made by environment groups and NFLAs. Although the legal limits for many radionuclide discharges are being reduced, the proposals will allow BNFL to increase the throughput of both of its reprocessing plants, and hence actual radioactive discharges will go up. In fact, by 2003/4 the amount of spent nuclear waste fuel reprocessed at Sellafield had increased by 87% compared with 1998/9, when the UK originally agreed to make ‘progressive and substantial reductions’ in discharges, and this trend is expected to continue. As a consequence the overall level of discharges is likely to remain higher than 1998 until after 2012, when the Magnox reprocessing plants is expected to close, even after the reductions in Tc-99 discharges  and non-Tc-99 discharges could reach double the level of 1998. The Agency also leaves the door open for reprocessing in THORP to continue beyond 2020 when concentrations in the environment are supposed to reach ‘close to zero’. The UK is clearly flouting its international commitments.
 See for example Para 1.31 of the Environment Agency’s “Proposed decision for the future regulation of disposals of radioactive waste from British Nuclear Fuels plc Sellafield”:
3.1 The Energy Bill received Royal Assent in July, allowing the establishment of the Nuclear Decommissioning Authority (NDA) in time to begin full operation in April 2005. Attempts to amend the Bill during its passage through the Houses of Parliament to clarify objectives were rejected leaving several outstanding issues to be resolved.
3.2 Provisions in the Energy Bill allow the bail-out of future private nuclear operators if they fail to fully fund their liabilities.  The Government needs to explain how it will ensure the establishment of segregated funds for decommissioning and nuclear waste management before allowing operation of new facilities. British Energy (BE) failed to set aside enough money to cover its liabilities, and the Government failed to effectively monitor BE’s segregated fund.  As a result the Government is now proposing to pay £3.3bn over the next ten years for BE’s liabilities (as part of the restructuring plan for BE, which is currently being investigated by the European Commission under EU competition laws). Approval of proposals for new nuclear plant should be conditional upon the establishment of a segregated fund, otherwise the taxpayer could, once again, be saddled with a private nuclear operator’s liabilities.  Worse still, the provisions in the Bill could be a major incentive to private investors to build new reactors, because they know if they do not set aside enough money for liabilities (even while reaping profits) there is a mechanism to allow the Government to bail them out.
3.3 The Government announced in July that it intends to transfer the shares in Nirex currently held by the nuclear industry into a new company limited by guarantee, thus fulfilling its commitment of a year ago to make the nuclear waste agency independent.  Margaret Beckett told the House of Commons that funding would be “primarily through the NDA” although the company would “be separate from, and independent of, the NDA”. When CoRWM delivers its recommendations in 2006, the Government will decide policy for the long-term management of and also the longer-term future of Nirex. 
3.4 Although virtually all of BNFL’s and UKAEA’s assets and liabilities are being assumed by the NDA in April 2005, and the Government is proposing to fund some of British Energy’s liabilities, routing most of Nirex’s funding through the NDA could result in a significant breach of the ‘polluter pays principle’. A mechanism needs to be found for BE and any future nuclear operators to pay a fair share of Nirex’s costs without compromising its independence.
3.5 The Energy Bill allows the NDA to operate BNFL’s ageing, loss-making Magnox reactors, the Sellafield reprocessing plants and the MOX Plant (SMP). There is no provision in the Bill for the promised annual review of the rationale for keeping nuclear facilities open.  The NDA’s focus should be “squarely on [dealing with] the nuclear legacy”, not on generating new nuclear waste or income. A Ministerial decision on whether continued operation of the Magnox reactors is justified has been awaited since before December 2002.  An independent financial appraisal of these loss-making stations is long overdue.
3.6 BNFL told The Guardian in 2003 it would soon announce that the THORP reprocessing plant would close by 2010.  There has been no such announcement, and there have been rumours that the Treasury is keen for the reprocessing plant to accept more overseas reprocessing contracts to generate income. On 18th July, the Independent on Sunday reported that the Government is planning to allow BNFL’s overseas customers to leave their Intermediate Level Waste at Sellafield, in order to raise £200m extra cash to be injected into the NDA. This sets a bad precedent suggesting generating income is more important to the NDA than dealing with nuclear waste problems.
3.7 Alan Edwards, former head of the DTI’s Liabilities Management Unit, has expressed doubt over whether SMP will ever open.  A BNFL source said "despite everyone’s best efforts, the bloody thing does not work".  BNFL has recently been forced to subcontract a 4th MOX order to one of its European competitors because of difficulties in opening the plant. 
3.8 Energy Minister, Stephen Timms, says the NDA can only operate nuclear power stations pending their decommissioning.  But the NDA does have powers to operate facilities for waste treatment. BNFL has made plain its desire to build and operate one or two nuclear power stations, which would be fuelled by plutonium (plutonium-burning reactors). The legislation would allow the NDA to contract BNFL to build plutonium-burning reactors as waste management facilities thus giving it the opportunity to showcase its AP1000 reactor. The alternative to plutonium-burning reactors is immobilising plutonium as a waste form.
3.9 Very few amendments to the Energy Bill made in the House of Lords survived the Bill’s passage through the House of Commons. One amendment which did succeed requires the Secretary of State for Trade and Industry to prepare a strategy for the promotion of micro-generation in Great Britain.
 On 15 January 2004 Lord Whitty told the House of Lords (Column GC170) that “there may again be circumstances in which a private sector operator cannot meet its nuclear obligations … we must retain the possibility of the Government meeting such costs”.
 NAO, 6/2/04 http://www.nao.gov.uk/publications/nao_reports/03-04/0304264.pdf
 House of Commons Trade and Industry Committee 17th Report para 20. http://www.parliament.the-stationery-office.co.uk/pa/cm200203/cmselect/cmtrdind/968/96809.htm
 DTI (July 2002) Managing the Nuclear Legacy, para 5.27
 DTI (July 2002) Managing the Nuclear Legacy: A Strategy for Action, para 1.12
 The Environment Agency issued new discharge authorisations for BNFL’s Magnox reactors – effective from 18th December 2002
 Guardian 26th August 2003 ‘Sellafield Shutdown Ends Nuclear Dream’ http://www.guardian.co.uk/uk_news/story/0,3604,1029333,00.html
 Speaking at the 6th Irish and UK Local Authorities Standing Conference on Nuclear Hazards, Glasgow 25-26 March 2004.
 Independent, 16 May 2004, ‘£470m nuclear plant does not work, admits BNFL’.
 Nuclear Fuel (Vol29, No 15, July 19, 2004) “BNFL subcontracts 4th MOX order to make up for SMP delay”.
 House of Commons Standing Committee on 27th May (Column 193&4)
4.1 SEPA says the policy of transferring low-level waste from Dounreay to Drigg is driven by the recommendation of the 1998 HSE and SEPA Dounreay Safety Audit, which in turn was driven by the most recent government policy on the subject set out in 1982: A Guide to the Administration of the Radioactive Substances Act 1960. This says that if a suitable disposal route exists it should be disposed of as soon as possible: “…in order to prevent the unnecessary accumulation of waste requiring storage and surveillance at production sites”. However, it should be noted that the 1995 Review of Radioactive Waste Management Policy says that waste should be “… safely disposed of at appropriate times and in appropriate ways … in a manner that commands public confidence …” (emphasis added). It can be argued, that transferring waste to Drigg is not appropriate, because it undermines the BPEO process, and does not command public confidence. SEPA also pointed out at Dundee that it does not regulate transport and cannot consider transport impacts.
4.2 The UKAEA launched its latest public consultation exercise in June on reclassifying High-Level liquid reprocessing Waste (HLW) from the Prototype Fast Reactor (PFR) as Intermediate-Level Waste (ILW). The waste accounts for nearly 79% of the site’s radioactivity inventory. The UKAEA’s initial plan was to build a vitrification plant at Dounreay to seal the HLW in glass blocks, but it now says even the most recent PFR waste has cooled sufficiently not to need constant artificial cooling and could be reclassified as ILW and treated in a cementation plant – a very much cheaper option. A draft Best Practical Environmental Option study has been prepared, and examined by internal and external stakeholder panels. NFLAs were invited to attend the external panel, but unfortunately this was not possible. A final BPEO will be published for wider consultation before applications are made to regulators for permission to implement the chosen policy.
4.3 Previous public consultation exercises on Dounreay decommissioning projects have been strongly criticised – in particular by Shetland Islands Council and NFLAs who complained that their submissions on the proposed incinerator were totally ignored. Dounreay director Norman Harrison issued an apology to Shetland
Islands Council in August, and agreed to re-write the final consultation report and to re-issue it to stakeholders for comment. Of course, none of this will affect the decision to go-ahead with construction of an incinerator, but UKAEA confirmed that it has no intention of importing wastes for incineration at Dounreay and it anticipates that Highland Council will put a condition to that effect on planning permission. UKAEA said the alternative of treating radioactive solvents and oils to form solid ILW is not proven technology, especially for the oils, although the Americans are looking at the problem.
4.4 New lower limits on Dounreay’s radioactive discharges into the Pentland Firth have been issued by SEPA, but await Ministerial approval. The need for new lower limits was urgent enough, SEPA said, to force it to make the reductions without any public consultation. SEPA announced it was taking this action last August when it imposed new limits on discharges into the atmosphere. UKAEA has now submitted a new application for discharge authorisations covering the whole site which will be subject to normal consultation. The new authorisations show signs of a tougher attitude towards Dounreay after SEPA radically changed its regulatory regime following a highly critical independent report. The existing limits were set to meet Dounreay’s reprocessing work, which produced huge discharges – but with the end of reprocessing SEPA wants limits to reflect better the UKAEA’s actual requirements.
4.5 Buried deep in the details of the authorisation documentation is the information that Dounreay is the only nuclear site in Scotland with no final filtration of its liquid discharges. SEPA has obviously been aware of this for some time and has now decided to place a legal requirement on the UKAEA to produce plans for final filters on discharges. The lack of action by SEPA until now is especially surprising given the hugely controversial issue of radioactive particles contaminating the seabed, the foreshore and beaches.
4.6 The owners of the Sandside Estate near Dounreay have called on the UKAEA to build a semi-permanent dam or barrier across Sandside Bay in an attempt to stop more radioactive particles from reaching the beach. Over 50 particles have already been found on the beach by the UKAEA’s monitoring contractors, but the Sandside Estate is strongly critical of this work, saying it only covers a fairly small part of the beach and does not use the most modern equipment. The estate also won a court action in 2003 that the UKAEA was breaching Section 7 of the Nuclear Installations Act which requires that ‘no occurrence involving nuclear material [should] cause injury to any person or damage to any property.’ UKAEA says a temporary barrier across Sandside Bay is one of 18 options it has identified and which would go out for public consultation.
4.7 The UKAEA has applied for planning permission to build a new plant next to the Dounreay Fast Reactor to receive and package spent fuel rods that are stuck in the core and breeder blanket of the reactor. All the other spent fuel has already been removed. The spent fuel will be transported by sea to Sellafield for
reprocessing according to the UKAEA proposal. The UKAEA estimates there will be 30 lorry movements carrying the highly radioactive spent fuel from the site to Scrabster where it will be loaded onto a ship.
The proposal to send the spent fuel to Sellafield has not been subject to stakeholder consultation.
4.8 Balfour Beatty has been awarded a £10m contract to build a waste-handling facility to increase the site’s capacity for storing solid intermediate-level radioactive waste (ILW). It will also enable up to 300 drums of conditioned waste from commercial fuel reprocessed at Dounreay until 1996 to be returned to overseas customers. Subject to regulatory consents, construction will take two years to complete and is expected to begin later this year, creating 50 temporary jobs.
5.1 The European Commission has lost patience with the UK and will launch infringement proceedings for non-compliance of materials accounting procedures at BNFL’s old B30 spent fuel storage pond at Sellafield. Although the U.K. government submitted by the June 1 deadline an action plan on how it intended to comply with nuclear material accounting rules, the EC says the plan is unsatisfactory. It will now send a warning letter to the UK in the autumn. The 44-year-old pond facility contains 1.3 metric tons of plutonium, about 400 kilograms of which is contained in corroded spent fuel lying as sludge on the pond’s bottom. The EC describes this as a “clear infringement of essential Euratom safeguards requirements”. An EC spokesperson said if we expect Iraq to declare its fissile materials, we should be doing the same ourselves.
5.2 German utilities have also lost patience with BNFL. Under the nuclear phase-out accord all spent fuel they intend to have reprocessed at Sellafield must be shipped before 1st July 2005. Any plutonium separated out from should be converted to MOX fuel. The problems at SMP have compounded an ongoing dispute between the utilities and BNFL over cost increases for reprocessing that BNFL want to impose. As a consequence, the number of spent fuel transports to Sellafield is being cut. Remaining spent fuel will be dry stored in Germany.
5.3 The Parliamentary Office of Science and Technology published its long-awaited report assessing risks of terrorist attacks on nuclear facilities in July.  It says there is insufficient information available publicly to conclude how successful a terrorist attack might be, but adds that nuclear facilities were not built to withstand attacks such as a large aircraft impact. A successful attack would be highly unlikely to cause a large number of instant fatalities, but would have the potential to affect extensive areas of land and cause a large number of cancers.
6.1 The final report on the public consultation conducted by Lancaster University on behalf of the MoD into management of decommissioned nuclear submarines was published in May. It shows public rejection of all the sites suggested.  The MoD must now formally respond and announce its next move.
6.2 The report concludes that proposals would be more acceptable if reactor compartments are stored intact; and doses to workers and the public, discharges to the environment, and risks generally are minimised using the best means available. It says storage and cut out should take place at sites, which are not adjacent to centres of population, and no new nuclear submarines should be built, at least until a final disposal route for radioactive waste is available. There was also a call for the MoD to ‘take charge’ of the decision-making process and specify the best way forward, rather than inviting contractors to put forward proposals.
6.3 An MOD review of its 118 coastal sites to see which could potentially be suitable for the interim storage of intact reactor compartments was carried out following a request for site options from one of four industry bidders, SERCO Assurance. The review concluded that only Coulport was suitable. Coulport, has already been named in outline proposals from industry, along with four non-MOD sites at Rosyth, Sellafield, Devonport and Dounreay. This was an odd conclusion given the amount of public opposition already in evidence around Coulport, but means that Machrihanish has been ruled out as a candidate site.
6.4 The results of this Consultation on Industry Outline Proposals will inform the MOD’s evaluation of the outline proposals, leading to selection of potential bidders to be invited to undertake more detailed negotiations later this year. The timetable for the remainder of the process is as follows:
Consider and respond to Lancaster University’s report – end of 2004
Down select the current bids to a short list and Issue an invitation to negotiate – Spring 2005.
Public consultation on these more detailed proposals – 2005/2006.
Selection of preferred bidder – end of 2006.
6.5 The Nuclear Installations Inspectorate has published its review of the decommissioning strategy for Rosyth dockyard.  The NII generally approves of the plans although says it will review progress on storage of intermediate-level ion exchange resins and other waste issues. NII welcomes the plan to de-license the site by the end of 2009, with the exception of an operational store required for storage and treatment of waste for which there is currently no disposal route. NII says there are a few areas where Rosyth needs to develop its strategy before the next review in five years.
7.1 Some 10,000 drums of mixed graphite and uranium scrap may be shipped later this year from BNFL’s Springfields plant near Preston to Kyrgyzstan’s Kara-Balta uranium processing plant so that an estimated 60 metric tons of uranium can be retrieved and returned to the U.K. The shipments are waiting for an export license from the EU and permission from the Kygyzstan government, which is thought to be divided on whether to accept the waste. The waste will be taken by road to an east coast U.K. port, shipped across to the port of St. Petersburg by normal cargo ferry and then transported overland to Kara-Balta.
When the Government published its Energy White Paper in February 2003, the then Energy Minister, Brian Wilson, said:
"If renewables and energy efficiency can prove themselves over the next five years there will be no need for new nuclear power stations.”
Since then, Energy Minister Stephen Timms has said that the Government would review its position on nuclear new build in 2006, cutting two years off the time allowed for energy efficiency and renewables to become established. Philip Sellwood, Chief Executive of the Energy Saving Trust, is clear that:
“… the UK’s carbon reduction targets can be met through substantial improvements in energy efficiency and through the introduction of renewable energy technologies, without the need for additional nuclear capacity. Given the current uncertainties surrounding the problems of dealing with nuclear waste and the cost of its generation, decommissioning and disposal, we remain convinced that energy efficiency is the safest, cheapest and more realistic solution.” 
The question is: ‘is the Government doing enough to promote energy efficiency (and renewable technologies), or is it simply waiting until after the next General Election before it approves new nuclear construction?’ This brief survey of what the Government is doing concludes that much more could be done.
Both Cambridge Econometrics  and the House of Commons Environmental Audit Committee , [32, 33] say climate change targets will be missed "by a large margin" unless the government does more to cut carbon dioxide pollution by households, airlines and motorists. And the government could fall 40% short of its 10% renewable energy target for 2010, according to a scathing report by the House of Lords Science and Technology Committee.  The committee said it’s hard to avoid the conclusion "that the government are not taking energy problems sufficiently seriously". Consequently the "Government may have no option but to follow the lead of other countries and accept that new nuclear build might be necessary".
Energy Efficiency Plan
The Government launched its Energy Efficiency Action Plan in April  but was severely criticised for watering down its energy efficiency commitments. The Government’s declared aim is to deliver domestic energy savings of around 4.2 megatonnes of carbon (MtC) per year by 2010. In setting this aim, the Government has broken a whole series of previous commitments made to both Parliament and the energy efficiency industry to deliver 5 MtC of savings through domestic energy efficiency by 2010 – a staggering 16% cut in the target. The Association for the Conservation of Energy (ACE) described the new target as “wholly unacceptable”.  A majority of MPs have already signed Early Day Motion 96, backing the original 5MtC target.  The Energy Savings Trust told the Environmental Audit Committee that it does not agree with the new 4.2MtC target.
For example, at a Smith Institute Seminar at 11 Downing Street on 2nd May 2003, the then Energy Minister, Brian Wilson, told ACE that “the very clear objectives in paras 3.5 and 3.6 of the White Paper (ie that households should account for around 5MtC savings by 2010) are government policy, so your members should … invest accordingly”.
The Government has basically scrapped policies that could easily make up the extra 0.8MtC. The White Paper expected savings 0.4MtC from increasing the uptake of A-rated household appliances. This in itself was a reduction from the 1MtC suggested by the Energy Savings Trust.  In the Energy Efficiency Plan this was mysteriously dropped to 0.1MtC with no explanation.
Many builders are still installing inefficient household appliances in new houses, even when they have little or no cost advantage over more efficient models. Consultant, National Energy Services, is calling for this situation to be rectified in the current review of Building Regulations.  Similarly, the Government’s Efficiency Plan does not expect efficient gas condensing boilers to corner the market until 2009, despite the fact that the new Building Regulations are expected to require only A or B-rated boilers to be installed. The slow up-take appears to reflect an expectation that the new regulations will be weakly enforced.
In drafts of the Plan, a saving of 0.1MtC was listed for domestic combined heat and power (micro-CHP), but this was dropped from the final plan and policies to promote micro-CHP are listed as providing nil savings, despite the fact that the budget agreed to reduce VAT on micro-CHP. The BG Group is pioneering micro-CHP, which can produce around 50% of a households electricity needs as well as central heating and hot water. BG Group says micro-CHP could potentially achieve cuts of around 20MtC. 
The 2003 Energy White Paper said that local authorities have a ‘pivotal’ role in delivering carbon savings, but a Local Government Association survey has found that Whitehall is standing in the way of local authorities’ (in England and Wales) plans to tackle climate change. Four fifths of town halls reported that they do not have the resources to set up energy service companies while just 20 per cent have targets for the development of renewable energy in their area. The LGA claimed that councils are keen to do more for the environment, but ministers are hampering their own environmental goals by failing to adequately fund green schemes.  The LGA says that all councils need a dedicated officer and an elected member with responsibility for sustainable energy, but these functions are only found in around 40% of councils.  The LGA describes this as a “deadly cocktail” which could prevent the Government meeting its climate change commitments.
Barry Johnston, Managing Director of Solar Twin Ltd in Chester, who install a revolutionary solar water heating panel design, says “most of us in the renewables industry have contingency business plans collecting dust awaiting the day when we go mainstream. We are talking of growth factors of ten to hundred-fold in just five years. In the renewable energy industry, we are alarmed at how many simple and obvious solutions to cutting global warming are simply being ignored today”. 
A more coherent policy framework is needed for building-integrated renewables if they are to contribute significantly to long-term climate change targets. Hopes that this might now happen were boosted by the insertion into the Energy Bill at the last minute of a requirement on the Secretary of State for Trade and Industry to produce an annual plan for micro-generation. Speaking at the Building Research Establishment’s conference in June 2004, Philip Sellwood of the Energy Savings Trust said that plans to build 250,000 new homes in the near future represent “a massive generational opportunity for the Government to take the lead”. Many of the homes will be in the Thames Gateway.
Sebastian Berry of the Renewable Power Association told the conference that the Government’s approach to micro-generation has been “hugely disappointing”. However, firms like Solar Century, Corus (PV roofing material), Renewables Devices, Windsave and Wind Dam (roof-top wind turbines) are taking an international lead in building integrated renewables. 
The London Borough of Merton took the lead in October 2003 with a unitary development plan which expects renewables to provide 10% of the predicted energy requirements for all new non-residential development about a threshold of 1,000 square metres. And the new town of Bracknell has got itself funding from Europe for a ‘Renaissance’ project to bring the town into the 21st Century. The blueprint combines biomass, wind and solar with dramatic improvements in energy efficiency. 
Planning Policy Statement 22 (PPS22) on renewable energy was published in August 2004 by the Office of the Deputy Prime Minister. It sets out the Government’s planning policies for renewable energy, which planning authorities in England and Wales should have regard to when preparing local development documents and when taking planning decisions.  PPS22 contains clarification that local planning authorities may develop policies that require a percentage of the energy to be used in new developments to come from on-site renewable energy. This should be an enormous boost to those local authorities wanting to positively promote renewable energy in their area.  The Scottish equivalents (PPG 6 and PAN 45) now need to give clearer guidance so that local authorities are required to deal with planning for small-scale renewables separately in their structural and local plans. But it remains to be seen what impact this will have given the lack of resources in local authorities.
So, whilst there are a few beacons of hope, like Merton and Bracknell, it is difficult to avoid the conclusion "that the government are not taking energy problems sufficiently seriously". There are less than two years to go before the Government plans to re-visit the issue of building new nuclear stations. On current performance the situation may not improve fast enough for the Government to conclude in 2006 that energy efficiency combined with renewables will achieve its carbon targets. The tragedy is that diverting money, time, and political attention away from cost effective efficiency improvements to expensive nuclear power, will actually seriously damage our efforts to reduce carbon emissions.
 Sustainable Development International 8th July http://www.sustdev.org/industry.news/2004/08.07.04.html
 Cambridge Econometrics: UK Energy and the Environment: July 2004 http://www.camecon.com/whatsnew/prlist.htm
 Evidence to the Environmental Audit Committee 19th May 2004, Q371 http://www.publications.parliament.uk/pa/cm200304/cmselect/cmenvaud/
 “Call for energy-efficient appliances in new homes” ENDS Report 354.
 The Parliamentary Monitor December 2003.
 LGA Press Release 1st July http://www.lga.gov.uk/PressRelease.asp?lSection=0&id=SX8456-A7825612
 “Councils struggle on energy and climate” ENDS Report 254, July 2004.
 “Livingstone urged to take the lead in building-integrated renewables” ENDS Report 353, June 2004.
 “New Town Energy”, Green futures, July/august 2004.
 Town & Country Planning Association Press Release, 10th August 2004 “A positive framework for developing a renewable energy now in place, say TCPA”