Out of commission

Posted by John Sauven - 31 January 2008 at 10:43am - Comments

The cost of taking nuclear plants out of service is spiralling out of control. Is this just poor financial management, or does it have wider implications? Written by Greenpeace Executive Director John Sauven for comment is free.

This week, the National Audit Office released its damning assessment of the Nuclear Decommissioning Authority's (NDA) ability to estimate the true financial cost of decommissioning and cleaning up the UK's fleet of ailing reactors and contaminated facilities. As costs for decommissioning appear to spiral out of control - rising sharply from £56bn to £73bn over just a few years - the burden on the taxpayer grows ever more. And it doesn't end there. The NDA has also been made responsible for disposing of the UK's stockpile of legacy wastes which is estimated at an additional £10-20bn. The industry argues these increased costs have arisen in the face of "significant challenges", but the echoes from this announcement are all too familiar from a sector that has been plagued with industrial and financial incompetence.

Although NDA has only a short history, it has not been a happy one. Three weeks after it was created in April 2005, the spent fuel reprocessing plant at Thorp (at Sellafield) was shut down following the discovery of a leak of dissolved spent fuel. It had been leaking for nine months. Despite recent false promises of a restart, rather embarrassingly it still remains shut, with technical problems being cited. And it doesn't end there. In addition, unexpected problems with waste have been found, mainly at Sellafield, which has meant diverting more money away from other decommissioning and clean-up operations (for example, cracks at the UK's Magnox reactors). It's a mess and it could cost us billions.

But is this just a case of poor financial management and short-sightedness, or does this have wider implications for the industry?

It's a vital question because the same nuclear industry people and bureaucrats who totally underestimated the clean up costs for current nuclear plants are in charge of consultation on how much the next lot of reactors - and their wastes - might cost to deal with. In fact, the NDA is the lead agency in this! They will also have a central role in estimating the costs - over the next 150 years - of how much it might cost to dispose of new build wastes. The NDA's recent and woefully inadequate cost estimates for nuclear waste management won't provide any comfort to the taxpayer or provide any confidence in their waste management strategy. And remember - the same legislation that established the NDA also contains clauses which allow the government to direct the authority to take over managing and financing new build wastes.

So much for there being no possibility of future subsidies for new reactors.

The NAO's examination of the NDA should be a valuable lesson learnt and should serve as a warning to us all - that the government's irrational, ill-conceived and bloody-minded policy of supporting new nuclear reactors has been pushed forward while a solution to the radioactive waste issue still doesn't exist. Meanwhile the NDA is handing out millions of pounds of taxpayers' money to private companies because of badly designed contracts, and the cost of decommissioning nuclear facilities is rising. We've spent tens of billions on this already, and we're set to spend billions more dealing with the existing problem - to build a new generation of new reactors is pure folly.

I have a significant issue with Greenpeace's position on nuclear power. To begin with, almost all of the criticism is leveled at the current reactor costs and their costly reprocessing. Our current reactors (Magnox and AGR) were designed 40 years ago, and technology has moved on. CANDU, ABWR or AP600/1000 reactors are cheap and easy to build, for example, and require no research.

In terms of the Greenpeace alternative of renewables and efficiency, I accept that they have a role to play. However baseline load currently has to come from nuclear or fossils. Pumped Storage cannot smooth out fluctuations for more than 8-12 hours, and can only smooth out 10% fluctuations in generation. Hence relying on wind for baseline load is a really bad idea. There's also the minor issue that the National Grid would have to be massively redeveloped to cope with the fact that wind is good either offshore or in a few specific places, and current power stations are not there. Nuclear can at least be used as drop in replacements for current fossil stations.

Then there's the issue of nuclear waste. The claims as to quantity are grossly misleading, as low-level waste is no more radioactive than the same item in the environment. Less than a ton of the problematic high level waste is produced per year by even a large plant. Even so, current developments, such as the MSR will produce reactors whose high level waste is less radioactive than natural ores after 300 years.

On the emissions front, several studies show nuclear being comparable to wind and lower than hydroelectric per kWh. The Storm and Smith report, and its derivatives, are flawed as they fail to consider breeder cycles, which don't require ANY enrichment (again such as the MSR), and assume that power will still be dirty. If nuclear is used to run the mining and ancillary activities, then nuclear becomes very clean.

In essence, I fail to see why Greenpeace is so dogmatically anti-nuclear. If it is to protect renewables, then that is understandable, but then why criticize nuclear as a replacement of coal? If anyone could enlighten me, then I would be most appreciative.

Jonathan, thanks for that comment, it's nice to engage with someone who's studied the issue. In terms of costs, the new generation of reactors are supposed to be much more cost efficient than Magnox, and twice as efficient as Sizewell B, our most modern reactor. However, that still leaves them at half the efficiency of wind, according to government figures (see this comment for full details).

Greenpeace are not campaigning for 100% wind (although 100% renewables is entirely possible) but for a mix of technologies in a decentralised network. That would include as much renewable energy as possible, and also lots of CHP, ideally from biomass, but even gas is relatively clean in this context, as the efficiency can be so high – a 2006 German study claimed that gas CHP can be lower carbon than nuclear, whilst also being cheaper, faster to install and a lot safer.

Regarding waste, the industry claims our existing waste will cost 73 billion pounds to deal with, so even if we assume that a safe long term solution can be found (and it hasn't been found yet) it remains very much an issue. Nuclear is a relatively low carbon technology, but for details of why it won't help combat climate change, please have a look here.

graham, gpuk

Gas and biomass are not “relatively clean” compared to nuclear. The European Commission’s Externe study produced an objective comparison of the external cost of each method of electricity generation. This assesses the damage to health and the environment caused by each energy source and converts it into a monetary cost. The result is that gas and biomass-fired electricity in the UK is at least four times as damaging as nuclear electricity. (Apart from the CO2, they release SO2, NOx and particulates which cause thousands of premature deaths in the UK per year.)

Table on p13:
http://www.externe.info/externpr.pdf

Even if we generously allow the figure to be cut by two-thirds for the extra efficiency of gas/biomass CHP it is still worse than nuclear. (And, incidentally it is feasible to do cleaner CHP with nuclear power, as happens at Beznau in Switzerland.)

Natural gas, which is the major source of fuel for Greenpeace’s CHP solutions, is particularly unsuitable if it is transported over long distances. The gas itself is more than twenty times as potent a GHG as CO2. If 2% of it leaks (which is quite possible over the infrastructure from Russia to the UK) then using gas is as bad as burning coal.

Denmark uses coal-fired CHP along with wind power almost exclusively. Even so their CO2 emissions per capita are higher than the UK.

Sweden in contrast gets virtually all of its electricity from hydro and nuclear (50% of each) and their emissions are 40% lower than the UK per capita despite using 60% more energy per head.

I object to Greenpeace’s tacit endorsement of burning fossil fuel simply to avoid a U-turn on nuclear power. There is no valid environmental case for avoiding nuclear power. The only mature source of electricity that is cleaner is wind power, and we cannot get all our power from wind.

I've answered this here, posting again in full:

Hi ColinG

Sorry for the length of this but I'm trying to respond to all your comments across the site in one go, as they all repeat the same myths.

I’ll answer your points on air pollution below but first off, I have to point out that you haven’t provided a credible alternative to our energy solution.

We’ve clearly explained how renewables + efficiency + CHP can lead us to a low emissions energy system, using CHP as a transition to 100 per cent renewables, providing heat and electricity for the whole of the UK. Initially CHP would be partly fossil fuelled and it would then go on to use zero carbon fuels like biogas. Over time more, renewable heat like solar and geothermal can also be introduced into the district heating networks – as they have done in the 100% renewable district in the city of Malmö, Sweden.

As I’ve said before, a replacement programme of ten nuclear reactors in the UK that the government's endorsed will only meet about 3.6% of our total energy needs - because they won’t provide heat. Around half our energy need is for heat (mainly gas based), while the next biggest demand is for transport (mainly oil based). Electricity generation is the smallest portion, and any new nuclear would be a small portion of that, making its role in tackling climate change / ensuring energy security almost irrelevant.

That's why the nuclear plan causes much more air pollution overall, for the total system; it can't possibly displace the majority of fossil fuel use, and leaves us running on the same kind of wasteful and polluting coal plants we have today. (Don't forget, the same ministers and companies that want to build new nuclear plants are also proposing the horde of new dirty coal plants across Britain – the most polluting power plants of all.)

According to our report, a UK energy scenario with high levels of decentralised energy using CHP and big renewables leads to less fuel burn over all than the government and industry plan of a centralized scenario with ambitious nuclear build. Less fuel use means less overall air pollution.

Your answer to that is that you want nuclear combined heat and power. No one in the nuclear industry or government is proposing that anyway – they wouldn’t dare propose to put them near to densely populated areas. But even if they did, you still haven’t explained how you’ll get rid of fossil fuels.

Are you suggesting we’ll be able to displace all our fossil fuelled power plants and all our individual boilers with nuclear CHP? Do you have an estimate for how many nuclear plants you’d need to do that? (In China, with the most ambitious nuclear programme in the world, they will still only generate a couple of percent of their electricity from nuclear when and if they built all 30-40 reactors that have been mooted there. Most of the rest of their electricity will still be coming from coal.)

How can the UK possibly get enough nuclear power to displace all our fossil fuel needs? Specifically, how are you going to find the enormous funds required to build small nuclear power stations near every town and city (the smaller ones you suggest, which won’t benefit from the economies of scale)? Where will you find the sites fit to host N nuclear plants? How will you persuade local residents across the UK to accept nuclear power and/or nuclear waste sites in the outskirts of their towns and cities? If you don’t want the nuclear plants to be close to urban centres, how will you fund the phenomenal costs of piping heat from, say, Sizewell to London? How will you find the nuclear engineers to build all the plants (there’s already a huge skills shortage)?

How will you persuade the government that the building of your nuclear plants won’t run massively over time and over budget like every other nuclear construction project (the average nuclear power station is finished four years late and 300 per cent over budget)? How will you transport all the radioactive wastes between the sites without putting the public at an unacceptable risk? How will you protect every plant and transport route from contamination / accident / terrorist attack? How do you propose to make nuclear power a globally applicable solution (at the moment, some countries, like Iran, are being told they aren’t allowed to have it)? For nuclear power to realistically meet our future global electricity demands, 2000 - 2500 reactors will need to be constructed between now and 2075 - an impossible task. How will you guarantee the weapons grade plutonium doesn’t get into the wrong hands? How do you plan to get rid of the significant fossil fuel use in the nuclear lifecycle (mining, transport, energy use around facilities, waste storage)?

And, if you agree that nuclear CHP will never fill the gap alone and you want renewables in the mix, how do you envisage stopping nuclear from undermining renewables as global experience and technical grid limitations both show it does (nuclear and renewables may both be able to run on the grid as long as both are making relatively small overall contributions, but both can't expand beyond a certain point without there being operational conflicts)? The nuclear industry itself says there is a conflict between nuclear and renewables and has lobbied to get the European renewable energy target weakened. Vincent De Rivaz, the CEO of EDF Energy stated at the Adam Smith Institute in March that if the UK actually started to make significant progress in meeting its Renewables Obligations, the economic viability of the new generation of nuclear power plants would be undermined and nuclear would be marginalised.

The case for decentralised energy based on renewables, CHP and efficiency has already been made and proven – in countless reports and in other countries. Why would you want to use an outdated technology that is more expensive and more dangerous?

I’m guessing you’re going to say because of particulates/air pollution (and you are right that air pollution is a big concern and a killer, especially in places like China). But, for all the reasons above, nuclear allows continued and even increased air pollution because of its undermining effect on energy efficiency measures – the nuclear option is more likely to lead to more air pollution than a system of decentralised energy based on gas / biomass / biogas CHP. And going nuclear can’t lead us to a 100% renewables scenario. Decentralised energy can. All the new nuclear in China is barely going to touch the air pollution problems there.

On your comments about CHP and particulates, larger CHP falls under IPPC requirements, and these control emissions to air. (And, as from the start of this year, some large CHP plants are covered by Large Combustion Plant Directive (LCPD), specifically targetting NOx SOx and particulates.)

Before a CHP plant can be built, modified or continue to be operated, emissions to air are mapped, taking into account all existing sources of emission (not just those of the new/existing plant – let’s not forget that cars and lorries are a major source of air pollution too) to ensure local air quality standards are met. If the model shows that the emissions "on the ground" get near to breaching the local air quality standards then the plant will not be built or, if it exists, allowed to continue to operate unless its output is restricted/other measures put in place.

Then there’s the fact that a decent sized gas-fired CHP plant will displace many hundreds or thousands of individual gas-fired boilers. Therefore, it can actually improve local air quality, because:

- a large heat plant will be sized more closely to actual heat loads than individual boilers, which are typically oversized to meet peak demand load. (A district heat plant overcomes this problem by having in-line boilers that are switched on or off progressively as demand for heat fluctuates throughout the day or the year.)

- a large CHP plant will burn gas more efficiently than the combination of all those numerous small boilers and the power plants providing the equivalent heat and electricity.

- it’s cost effective and quick to add emissions cleaning equipment to large plant, or to switch it to cleaner fuels as they become available, but not with many small ones like boilers.

- the maintenance of large plants will be more effectively managed than individual boilers, impacting on the efficiency and cleanness of gas burn.

I hope that answers all of your points. And sorry for the delay. As you can imagine, we don’t have the resources to post dozens of comments on the same point – unlike some well funded industries… ;-)

Cheers,

Bex
gpuk

Your argument against nuclear seems to boil down to the concern that it might be selected as a cheaper alternative than renewables for abating carbon. What is wrong with this if it makes CO2 targets more achievable?

Note, the Germans, who in your view have a good approach to adopting renewables while phasing out nuclear power, are
lobbying to have their CO2 emission quota increased to compensate for their loss of nuclear
?

The reason is because it is not possible for renewables to take up the slack at the same time as replacing fossil fuel.

Regarding your attempt to dodge the issue of air pollution: as I said elsewhere, the fact that CHP emissions may be within legal limits means nothing. It certainly does not mean they are harmless.

The draft report from COMEAP (Committee on the Medial Effects of Air Pollution) has revised their opinion on the mortality risk from PM2.5 particulates upwards. These are now considered to have a mortality risk of 6% for every 10 micrograms per cubic metre.

The European target limit for PM2.5 particulates is 20 micrograms per cubic metre, and they expect most cities to have problems meeting this by 2015.

Just to spell this out, even if air pollution is cut to the target limit it will still pose a 12% mortality risk.

This could mean the premature death of 1 person in 8 in some UK cities.

So it is utterly unbelievable that you would wish to increase urban air pollution by moving biomass fired CHP into towns. The way to avert this horrendous death toll is to stop using fossil fuel and biomass for electricity generation. Stop using diesel and bio-diesel in cars. Instead move to electric vehicles, and generate more electricity using truly clean renewables like wind and hydro; and also to deploy more nuclear power.

I have a significant issue with Greenpeace's position on nuclear power. To begin with, almost all of the criticism is leveled at the current reactor costs and their costly reprocessing. Our current reactors (Magnox and AGR) were designed 40 years ago, and technology has moved on. CANDU, ABWR or AP600/1000 reactors are cheap and easy to build, for example, and require no research. In terms of the Greenpeace alternative of renewables and efficiency, I accept that they have a role to play. However baseline load currently has to come from nuclear or fossils. Pumped Storage cannot smooth out fluctuations for more than 8-12 hours, and can only smooth out 10% fluctuations in generation. Hence relying on wind for baseline load is a really bad idea. There's also the minor issue that the National Grid would have to be massively redeveloped to cope with the fact that wind is good either offshore or in a few specific places, and current power stations are not there. Nuclear can at least be used as drop in replacements for current fossil stations. Then there's the issue of nuclear waste. The claims as to quantity are grossly misleading, as low-level waste is no more radioactive than the same item in the environment. Less than a ton of the problematic high level waste is produced per year by even a large plant. Even so, current developments, such as the MSR will produce reactors whose high level waste is less radioactive than natural ores after 300 years. On the emissions front, several studies show nuclear being comparable to wind and lower than hydroelectric per kWh. The Storm and Smith report, and its derivatives, are flawed as they fail to consider breeder cycles, which don't require ANY enrichment (again such as the MSR), and assume that power will still be dirty. If nuclear is used to run the mining and ancillary activities, then nuclear becomes very clean. In essence, I fail to see why Greenpeace is so dogmatically anti-nuclear. If it is to protect renewables, then that is understandable, but then why criticize nuclear as a replacement of coal? If anyone could enlighten me, then I would be most appreciative.

Jonathan, thanks for that comment, it's nice to engage with someone who's studied the issue. In terms of costs, the new generation of reactors are supposed to be much more cost efficient than Magnox, and twice as efficient as Sizewell B, our most modern reactor. However, that still leaves them at half the efficiency of wind, according to government figures (see this comment for full details). Greenpeace are not campaigning for 100% wind (although 100% renewables is entirely possible) but for a mix of technologies in a decentralised network. That would include as much renewable energy as possible, and also lots of CHP, ideally from biomass, but even gas is relatively clean in this context, as the efficiency can be so high – a 2006 German study claimed that gas CHP can be lower carbon than nuclear, whilst also being cheaper, faster to install and a lot safer. Regarding waste, the industry claims our existing waste will cost 73 billion pounds to deal with, so even if we assume that a safe long term solution can be found (and it hasn't been found yet) it remains very much an issue. Nuclear is a relatively low carbon technology, but for details of why it won't help combat climate change, please have a look here. graham, gpuk

Gas and biomass are not “relatively clean” compared to nuclear. The European Commission’s Externe study produced an objective comparison of the external cost of each method of electricity generation. This assesses the damage to health and the environment caused by each energy source and converts it into a monetary cost. The result is that gas and biomass-fired electricity in the UK is at least four times as damaging as nuclear electricity. (Apart from the CO2, they release SO2, NOx and particulates which cause thousands of premature deaths in the UK per year.) Table on p13: http://www.externe.info/externpr.pdf Even if we generously allow the figure to be cut by two-thirds for the extra efficiency of gas/biomass CHP it is still worse than nuclear. (And, incidentally it is feasible to do cleaner CHP with nuclear power, as happens at Beznau in Switzerland.) Natural gas, which is the major source of fuel for Greenpeace’s CHP solutions, is particularly unsuitable if it is transported over long distances. The gas itself is more than twenty times as potent a GHG as CO2. If 2% of it leaks (which is quite possible over the infrastructure from Russia to the UK) then using gas is as bad as burning coal. Denmark uses coal-fired CHP along with wind power almost exclusively. Even so their CO2 emissions per capita are higher than the UK. Sweden in contrast gets virtually all of its electricity from hydro and nuclear (50% of each) and their emissions are 40% lower than the UK per capita despite using 60% more energy per head. I object to Greenpeace’s tacit endorsement of burning fossil fuel simply to avoid a U-turn on nuclear power. There is no valid environmental case for avoiding nuclear power. The only mature source of electricity that is cleaner is wind power, and we cannot get all our power from wind.

I've answered this here, posting again in full: Hi ColinG Sorry for the length of this but I'm trying to respond to all your comments across the site in one go, as they all repeat the same myths. I’ll answer your points on air pollution below but first off, I have to point out that you haven’t provided a credible alternative to our energy solution. We’ve clearly explained how renewables + efficiency + CHP can lead us to a low emissions energy system, using CHP as a transition to 100 per cent renewables, providing heat and electricity for the whole of the UK. Initially CHP would be partly fossil fuelled and it would then go on to use zero carbon fuels like biogas. Over time more, renewable heat like solar and geothermal can also be introduced into the district heating networks – as they have done in the 100% renewable district in the city of Malmö, Sweden. As I’ve said before, a replacement programme of ten nuclear reactors in the UK that the government's endorsed will only meet about 3.6% of our total energy needs - because they won’t provide heat. Around half our energy need is for heat (mainly gas based), while the next biggest demand is for transport (mainly oil based). Electricity generation is the smallest portion, and any new nuclear would be a small portion of that, making its role in tackling climate change / ensuring energy security almost irrelevant. That's why the nuclear plan causes much more air pollution overall, for the total system; it can't possibly displace the majority of fossil fuel use, and leaves us running on the same kind of wasteful and polluting coal plants we have today. (Don't forget, the same ministers and companies that want to build new nuclear plants are also proposing the horde of new dirty coal plants across Britain – the most polluting power plants of all.) According to our report, a UK energy scenario with high levels of decentralised energy using CHP and big renewables leads to less fuel burn over all than the government and industry plan of a centralized scenario with ambitious nuclear build. Less fuel use means less overall air pollution. Your answer to that is that you want nuclear combined heat and power. No one in the nuclear industry or government is proposing that anyway – they wouldn’t dare propose to put them near to densely populated areas. But even if they did, you still haven’t explained how you’ll get rid of fossil fuels. Are you suggesting we’ll be able to displace all our fossil fuelled power plants and all our individual boilers with nuclear CHP? Do you have an estimate for how many nuclear plants you’d need to do that? (In China, with the most ambitious nuclear programme in the world, they will still only generate a couple of percent of their electricity from nuclear when and if they built all 30-40 reactors that have been mooted there. Most of the rest of their electricity will still be coming from coal.) How can the UK possibly get enough nuclear power to displace all our fossil fuel needs? Specifically, how are you going to find the enormous funds required to build small nuclear power stations near every town and city (the smaller ones you suggest, which won’t benefit from the economies of scale)? Where will you find the sites fit to host N nuclear plants? How will you persuade local residents across the UK to accept nuclear power and/or nuclear waste sites in the outskirts of their towns and cities? If you don’t want the nuclear plants to be close to urban centres, how will you fund the phenomenal costs of piping heat from, say, Sizewell to London? How will you find the nuclear engineers to build all the plants (there’s already a huge skills shortage)? How will you persuade the government that the building of your nuclear plants won’t run massively over time and over budget like every other nuclear construction project (the average nuclear power station is finished four years late and 300 per cent over budget)? How will you transport all the radioactive wastes between the sites without putting the public at an unacceptable risk? How will you protect every plant and transport route from contamination / accident / terrorist attack? How do you propose to make nuclear power a globally applicable solution (at the moment, some countries, like Iran, are being told they aren’t allowed to have it)? For nuclear power to realistically meet our future global electricity demands, 2000 - 2500 reactors will need to be constructed between now and 2075 - an impossible task. How will you guarantee the weapons grade plutonium doesn’t get into the wrong hands? How do you plan to get rid of the significant fossil fuel use in the nuclear lifecycle (mining, transport, energy use around facilities, waste storage)? And, if you agree that nuclear CHP will never fill the gap alone and you want renewables in the mix, how do you envisage stopping nuclear from undermining renewables as global experience and technical grid limitations both show it does (nuclear and renewables may both be able to run on the grid as long as both are making relatively small overall contributions, but both can't expand beyond a certain point without there being operational conflicts)? The nuclear industry itself says there is a conflict between nuclear and renewables and has lobbied to get the European renewable energy target weakened. Vincent De Rivaz, the CEO of EDF Energy stated at the Adam Smith Institute in March that if the UK actually started to make significant progress in meeting its Renewables Obligations, the economic viability of the new generation of nuclear power plants would be undermined and nuclear would be marginalised. The case for decentralised energy based on renewables, CHP and efficiency has already been made and proven – in countless reports and in other countries. Why would you want to use an outdated technology that is more expensive and more dangerous? I’m guessing you’re going to say because of particulates/air pollution (and you are right that air pollution is a big concern and a killer, especially in places like China). But, for all the reasons above, nuclear allows continued and even increased air pollution because of its undermining effect on energy efficiency measures – the nuclear option is more likely to lead to more air pollution than a system of decentralised energy based on gas / biomass / biogas CHP. And going nuclear can’t lead us to a 100% renewables scenario. Decentralised energy can. All the new nuclear in China is barely going to touch the air pollution problems there. On your comments about CHP and particulates, larger CHP falls under IPPC requirements, and these control emissions to air. (And, as from the start of this year, some large CHP plants are covered by Large Combustion Plant Directive (LCPD), specifically targetting NOx SOx and particulates.) Before a CHP plant can be built, modified or continue to be operated, emissions to air are mapped, taking into account all existing sources of emission (not just those of the new/existing plant – let’s not forget that cars and lorries are a major source of air pollution too) to ensure local air quality standards are met. If the model shows that the emissions "on the ground" get near to breaching the local air quality standards then the plant will not be built or, if it exists, allowed to continue to operate unless its output is restricted/other measures put in place. Then there’s the fact that a decent sized gas-fired CHP plant will displace many hundreds or thousands of individual gas-fired boilers. Therefore, it can actually improve local air quality, because: - a large heat plant will be sized more closely to actual heat loads than individual boilers, which are typically oversized to meet peak demand load. (A district heat plant overcomes this problem by having in-line boilers that are switched on or off progressively as demand for heat fluctuates throughout the day or the year.) - a large CHP plant will burn gas more efficiently than the combination of all those numerous small boilers and the power plants providing the equivalent heat and electricity. - it’s cost effective and quick to add emissions cleaning equipment to large plant, or to switch it to cleaner fuels as they become available, but not with many small ones like boilers. - the maintenance of large plants will be more effectively managed than individual boilers, impacting on the efficiency and cleanness of gas burn. I hope that answers all of your points. And sorry for the delay. As you can imagine, we don’t have the resources to post dozens of comments on the same point – unlike some well funded industries… ;-) Cheers, Bex gpuk

Your argument against nuclear seems to boil down to the concern that it might be selected as a cheaper alternative than renewables for abating carbon. What is wrong with this if it makes CO2 targets more achievable? Note, the Germans, who in your view have a good approach to adopting renewables while phasing out nuclear power, are lobbying to have their CO2 emission quota increased to compensate for their loss of nuclear? The reason is because it is not possible for renewables to take up the slack at the same time as replacing fossil fuel. Regarding your attempt to dodge the issue of air pollution: as I said elsewhere, the fact that CHP emissions may be within legal limits means nothing. It certainly does not mean they are harmless. The draft report from COMEAP (Committee on the Medial Effects of Air Pollution) has revised their opinion on the mortality risk from PM2.5 particulates upwards. These are now considered to have a mortality risk of 6% for every 10 micrograms per cubic metre. The European target limit for PM2.5 particulates is 20 micrograms per cubic metre, and they expect most cities to have problems meeting this by 2015. Just to spell this out, even if air pollution is cut to the target limit it will still pose a 12% mortality risk. This could mean the premature death of 1 person in 8 in some UK cities. So it is utterly unbelievable that you would wish to increase urban air pollution by moving biomass fired CHP into towns. The way to avert this horrendous death toll is to stop using fossil fuel and biomass for electricity generation. Stop using diesel and bio-diesel in cars. Instead move to electric vehicles, and generate more electricity using truly clean renewables like wind and hydro; and also to deploy more nuclear power.

Follow Greenpeace UK