13 February 2010
With public consultation fatigue sweeping the country like swine fever, here's another one that may seriously affect our descendants. It's on the strange term "Justification" of new nuclear build – or to give it its full title: The Justification of Practices Involving Ionising Radiation Regulations 2004, where the Secretary of State for Energy and Climate Change (DECC), as the Justifying Authority, must decide whether a new class or type of practice resulting in exposure to ionising radiation is justified by its economic, social, or other benefits in relation to the health detriment it may cause.
The Government is obliged to carry out this consultation under the terms of the Aarhus Convention drawn up by the United Nations Economic Commission for Europe (UNECE). The Convention, adopted in the Danish city of Aarhus, is a new kind of environmental agreement, which obliges partaking governments to allow access to information, public participation in decision-making and access to justice in environmental matters.
But the government breached Aarhus by failing to hold the consultation while the decision-making was still in a formative stage, so that public opinion might realistically influence the process. It is not appropriate for the Secretary of State to be also the Justifying Authority. Both he, the Prime Minister and DECC have already expressed their support for new nuclear reactors. Not only is the Department being its own judge and jury here it is also rushing the 'Justification' of new nuclear reactors and their radioactive emissions through an overcrowded and unsynchronised schedule, without giving members of the public a chance to respond by the closing date of . Most of the public are unaware there is a consultation going on at all.
There is still time to contribute to this important decision-making process.
The possible "health detriment" quoted above is the risk of cancer from the radiation that all nuclear power stations emit. A recent German government study found large increases in leukaemia (220 percent) and embryonal cancer (160 percent) among children living near all German nuclear reactors. The study (called KiKK, the German acronym for Kinderkrebs in der Umgebung von KernKraftwerken) is supported by many other worldwide studies into child cancers near nuclear power plants. It is rather worrying that the German scientists cannot explain the results on the basis of the presently accepted model of radiation risk. How can one justify such a dilemma?
The Guardian's Environment Editor, John Vidal, reported that the children's cancer hospital in Minsk, Belarus and at the Vilne Hospital in the east of Ukraine, are both reporting highly unusual rates of cancers, mutations and blood diseases linked to the Chernobyl accident twenty-four years ago – although they were hundreds of miles from the stricken plant.
The KiKK Report is significant because it is a large and well-conducted survey; because it is scientifically rigorous; because its evidence is particularly strong and because the German Government, which commissioned it, has confirmed its findings. Last November our Department of Health requested the UK Government's Committee on the Medical Aspects of Radiation in the Environment (COMARE) to examine the German study and report back. The COMARE report will not be finished until after the Justification Consultation deadline of 22 February, yet the government refuses to extend the deadline. This is an unreasonable position for the British Government to take. It is vital to get to grips with the KiKK evidence to assess how great are the disadvantages of nuclear power. Once the 'Justification' decision has been taken it will be almost impossible to re-examine the major issues of policy.
Is it already a 'done deal'? No - not if we write and demand an independent inquiry, allowing the consultation to be open, transparent and democratic. Please comment to: Owen Jenkins, The Justification Assessment Centre, DECC, 3 Whitehall Place, London SW1A 2AW; Telephone: 0300 068 5869; e-mail: firstname.lastname@example.org - before 22 February!