Combined Environmental Non Government Organisations submission to the Australian Senate recommends keeping the existing and prudent federal nuclear prohibitions.

FROM:
Friends of the Earth Australia
Australian Conservation Foundation
Greenpeace Australia Pacific
The Wilderness Society
Conservation Council of WA
Conservation SA
Nature Conservation Council (NSW)
Environment Victoria
Queensland Conservation Council
Environment Centre NT
Environs Kimberley
Submission to the Senate Environment and Communications Legislation Committee
Inquiry into the Environment and Other Legislation Amendment (Removing Nuclear Energy Prohibitions) Bill 2022 Submission 14 January 2023.
EXECUTIVE SUMMARY
Our groups maintain that federal and state legal prohibitions against the construction of nuclear power reactors have served Australia well. We strongly support the retention of these prudent, long-standing protections.
Proponents of the Environment and Other Legislation Amendment (Removing Nuclear Energy Prohibitions) Bill 2022 (The Bill) are seeking to remove these prohibitions, claiming this is needed to address climate change. However nuclear power is – at best ‒ a distraction to effective climate action.
It is important to note that promoters of nuclear power in Australia are not suggesting we build the nuclear technology that currently exists in the commercial world. The reactors that exist today are increasingly seen as a high cost and high-risk way to make electricity. They are also directly linked to high-level radioactive waste and nuclear security, weapons and terrorism concerns.
Nuclear promoters are staking their hopes – and Australia’s energy future – on technology which is uncertain and unproven. At the time of the 2021 Glasgow COP26, the UN Secretary General’s Special Advisor on Climate Change Selwin Hart stated that nations seeking to base their climate response on technologies that have not yet been developed are “reckless and irresponsible.”1
The good news about the renewed nuclear discussion is that it highlights that business as usual with fossil fuels is not an option. The bad news is the very real risk of delay, distraction and a failure to advance a just energy transition.
In response to the 2019 federal inquiry by the Standing Committee on Environment and Energy into the pre-requisites for nuclear power, over 60 Australian organisations representing millions of Australians, and including trade unions,
Indigenous, environment, health, faith and peace groups, signed a joint statement opposing nuclear power:
“Our nation faces urgent energy challenges. Against a backdrop of increasing climate impacts and scientific evidence the need for a clean and renewable energy transition is clear and irrefutable. All levels of government need to actively facilitate and manage Australia’s accelerated transition from reliance on fossil fuels to low carbon electricity generation.
The transition to clean, safe, renewable energy should also re-power the national economy. The development and commercialisation of manufacturing, infrastructure and new energy thinking is already generating employment and opportunity. This should be grown to provide skilled and sustainable jobs and economic activity, particularly in regional Australia.
There should be no debate about the need for this energy transition, or that it is already occurring. However, choices and decisions are needed to make sure that the transition best meets the interests of workers, affected communities and the broader Australian society.
Against this context the federal government has initiated an Inquiry into whether domestic nuclear power has a role in this necessary energy transition. Our organisations, representing a diverse cross section of the Australian community, strongly maintain that nuclear power has no role to play in Australia’s energy future.
Nuclear power is a dangerous distraction from real movement on the pressing energy decisions and climate actions we need. We maintain this for a range of factors, including:
Waste: Nuclear reactors produce long-lived radioactive wastes that pose a direct human and environmental threat for many thousands of years and impose a profound inter-generational burden. Radioactive waste management is costly, complex, contested and unresolved, globally and in the current Australian context. Nuclear power cannot be considered a clean source of energy given its intractable legacy of nuclear waste.
Water: Nuclear power is a thirsty industry that consumes large volumes of water, from uranium mining and processing through to reactor cooling. Australia is a dry nation where water is an important resource and supply is often uncertain.
Time: Nuclear power is a slow response to a pressing problem. Nuclear reactors are slow to build and license. Globally, reactors routinely take ten years or more to construct and time over-runs are common. Construction and commercialisation of nuclear reactors in Australia would be further delayed by the lack of nuclear engineers, a specialised workforce, and a licensing, regulatory and insurance framework.
Cost: Nuclear power is highly capital intensive and a very expensive way to produce electricity. The 2016 South Australian Nuclear Fuel Cycle Royal Commission concluded nuclear power was not economically viable. The controversial Hinkley reactors being constructed in the UK will cost more than $35 billion and lock in high cost power for consumers for decades. Cost estimates of other reactors under construction in Europe and the US range from $17 billion upwards and all are many billions of dollars over-budget and many years behind schedule. Renewable energy is simply the cheapest form of new generation electricity as the CSIRO and the Australian Energy Market Operator concluded in their December 2018 report.
Security: Nuclear power plants have been described as pre-deployed terrorist targets and pose a major security threat. This in turn would likely see an increase in policing and security operations and costs and a commensurate impact on civil liberties and public access to information. Other nations in our region may view Australian nuclear aspirations with suspicion and concern given that many aspects of the technology and knowledge base are the same as those required for nuclear weapons. On many levels nuclear is a power source that undermines confidence.
Safety: All human made systems fail. When nuclear power fails it does so on a massive scale. The human, environmental and economic costs of nuclear accidents like Chernobyl and Fukushima have been massive and continue. Decommissioning and cleaning up old reactors and nuclear sites, even in the absence of any accidents, is technically challenging and very costly. Unlawful and unpopular: Nuclear power and nuclear reactors are prohibited under existing federal, state and territory laws. The nuclear sector is highly contested and does not enjoy broad political, stakeholder or community support. A 2015 IPSOS poll found that support among Australians for solar power (78‒87%) and wind power (72%) is far higher than support for coal (23%) and nuclear (26%).
Disproportionate impacts: The nuclear industry has a history of adverse impacts on Aboriginal communities, lands and waters. This began in the 1950s with British atomic testing and continues today with uranium mining and proposed nuclear waste dumps. These problems would be magnified if Australia ever advanced domestic nuclear power.
Better alternatives: If Australia’s energy future was solely a choice between coal and nuclear then a nuclear debate would be needed. But it is not. Our nation has extensive renewable energy options and resources and Australians have shown clear support for increased use of renewable and genuinely clean energy sources.
The path ahead: Australia can do better than fuel higher carbon emissions and unnecessary radioactive risk. We need to embrace the fastest growing global energy sector and become a driver of clean energy thinking and technology and a world leader in renewable energy technology.
We can grow the jobs of the future here today. This will provide a just transition for energy sector workers, their families and communities and the certainty to ensure vibrant regional economies and secure sustainable and skilled jobs into the future.
Renewable energy is affordable, low risk, clean and popular. Nuclear is simply not. Our shared energy future is renewable, not radioactive.”
There is now a consensus or near-consensus that, in the words of Dr. Ziggy Switkowski at the 2019 federal nuclear inquiry, “the window is now closed for gigawatt-scale nuclear” in Australia. Dr. Switkowski further noted that “nuclear power has got more expensive, rather than less expensive”, that there is “no coherent business case to finance an Australian nuclear industry”, and that no-one knows how a network of small modular reactors (SMRs) might work in Australia because no such network exists “anywhere in the world at the moment”.
The 2019 federal nuclear inquiry2 included Coalition MPs who were, in principle, enthusiastic about nuclear power. However, the Committee’s report argued that the government should retain legal bans prohibiting the development of conventional, large nuclear power reactors (“Generation I, Generation II and Generation III”).3 Committee chair Ted O’Brien said, “Australia should say a definite ‘no’ to old nuclear technologies.”4
The Committee’s report called for a partial repeal of legal bans to permit the development of “new and emerging nuclear technologies” including SMRs, a call that was ruled out by the Morrison government.5 The current Labor federal government and the Australian Greens (among others) support the legal prohibitions.
The Labor dissenting report to the 2019 federal nuclear inquiry argued for retaining the prohibition:
“There is no basis for lifting the legislative prohibition on nuclear energy (Recommendation 3). There is no need for additional work or specific investigations into the science or economics of nuclear energy (Recommendation 2) as Australia already has significant expertise and engagement in this space through the Australian Nuclear Science and Technology Organisation (ANSTO), the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA), the Australian Energy Market Operator (AEMO), the Commonwealth Scientific and Industrial Research Organisation (CSIRO), and through our nuclear-related international treaty-based collaborations. Devoting resources to a nuclear wish-fulfilment exercise, including what sounds like a nuclear propaganda exercise (e.g., ‘manage a community engagement program that would educate and inform Australians’) would be a costly and wasteful distraction.”
We wholeheartedly agree.
A January 2019 statement issued by the Climate Council, comprising Australia’s leading climate scientists and other policy experts6 argued that nuclear power reactors “are not appropriate for Australia and probably never will be” and further stated:
“Nuclear power stations are highly controversial, can’t be built under existing law in any Australian state or territory, are a more expensive source of power than renewable energy, and present significant challenges in terms of the storage and transport of nuclear waste, and use of water”
The pressing climate and energy crisis would be exacerbated by opening the door to nuclear power which would complicate and delay the much-needed transition away from fossil fuels. The opportunity cost of investing time and money in Gen IV nuclear power concepts and SMRs would be high and would distract from far more effective climate responses, especially as novel nuclear technology is unproven, not commercially available, and retains many of the same problems and risks as conventional, large-scale nuclear power.
SMRs do not have any meaningful existence. Some small reactors exist but currently there is no such SMR mass manufacturing capacity, and no company, consortium, utility or national government is seriously considering betting billions building an SMR mass manufacturing capacity. The only two operating SMRs ‒ one each in Russia and China ‒ could only loosely be described as SMRs (lacking serial factory construction of reactor components or ‘modules’). Both were long delayed and subject to large cost increases.
Instead, we should embrace a diverse suite of renewable energy options. Australia is well placed to be a global leader in this sector and to grow and enjoy the clear environmental, energy security and economic benefits.
Further, we maintain that the prohibitions on nuclear power should be retained because:
- Nuclear power could not possibly pass any reasonable economic test. It could not be introduced or maintained without huge taxpayer subsidies and would undoubtedly result in higher electricity prices.
- There is no clear social license to introduce nuclear power to Australia. Opinion polls indicate that Australians are strongly opposed to a nuclear power reactor being built in their local vicinity (10‒28% support, 55‒73% opposition); and opinion polls find that support for renewable energy sources far exceeds support for nuclear power (for example a 2015 IPSOS poll found 72‒87% support for solar and wind power but just 26% support for nuclear power).
- The pursuit of a nuclear power industry would almost certainly worsen patterns of disempowerment and dispossession that Australia’s First Nations communities have and continue to experience from uranium, nuclear and radioactive waste projects.
- The issue of the long-term management of low, intermediate and high-level nuclear waste resulting from a nuclear power should preclude further consideration nuclear power as an energy option. This unresolved inter-generational waste issue highlights that nuclear is not a ‘clean’ energy source.
- The introduction of nuclear power would delay and undermine the development of effective and cost-effective energy and climate policies based on renewable energy sources and energy efficiency.
- Introducing nuclear power to Australia would necessitate 10 years for planning and approvals, 10 years for construction, and an estimated 6.5 years7 to repay the energy and carbon debts from construction. Thus, nuclear power could only begin to contribute to reducing greenhouse emissions around 2050 even in the unlikely event that legal prohibitions were repealed in the near future. If we assume 10 years for the repeal of current legal prohibitions, nuclear power could only begin to contribute to reducing greenhouse emissions around 2060.
- Nuclear reactors are increasingly vulnerable to climatic changes and extreme weather conditions.
- Significant security and safety considerations, including the potential for infrastructure weaponisation and the vulnerability of civilian nuclear reactors in conflict zones as highlighted in the Ukraine war.
It is important to note that the impact of the nuclear industry on First Nations communities in Australia and globally has been disproportionate and discriminatory. In Australia this can be seen in many cases, including long standing concerns and tensions over radioactive waste management.
Decades-long efforts to establish a repository and store for Australia’s low and intermediate-level radioactive wastes continue to flounder. The federal Labor government has inherited and is currently progressing the previous government’s plans for a national nuclear waste facility near Kimba in regional South Australia. This is despite the opposition of many local farmers and the unanimous opposition of the Barngarla Traditional Owners. A legal challenge initiated by Barngarla Traditional Owners is currently underway and contest around the waste plan is growing.
Our groups believe there is a pressing need for the federal government to pause the current National Radioactive Waste Management Facility process pending the findings of a dedicated inquiry that explores all available options for the management of Australia’s existing holdings of radioactive waste.
The policy calcification and community division around the management of our existing national radioactive waste inventory should sound a cautionary note over any moves to take Australia further down a nuclear path.
Indeed, former Resources Minister Matt Canavan stated in June 2019 that “if we can’t find a permanent home for low-level radioactive waste associated with nuclear medicines, we’ve got a pretty big challenge dealing with the high-level waste that would be produced by any energy facilities”.
Fortunately, we are not faced with the limited energy options of coal, gas or nuclear.
A growing number of expert studies have mapped out viable, affordable scenarios for 100% renewable electricity generation in Australia8, while numerous studies demonstrate the significant and widening cost advantage enjoyed by renewables compared to nuclear power. Moreover, CSIRO/AEMO research shows that even when transmission and storage costs are factored in, renewables are still far cheaper than nuclear power.
Australia cannot afford to lose more time on energy ‘culture-wars’ or on the false promise of unproven and non-commercial technology.
The former Chair of the US Nuclear Regulatory Commission, Professor Allison Macfarlane, provided a further reality check in 2021 stating, “when it comes to averting the imminent effects of climate change, even the cutting edge of nuclear technology will prove to be too little, too late.”9
Wishful thinking is no substitute for real world evidence and action, or for effective climate action.
Renewable energy exists in the real world and this is the crucial decade when real climate action is urgently needed to make the required transition to a low carbon future.
It is our considered view that the pursuit of nuclear power would delay and undermine efforts to reduce Australia’s greenhouse emissions and address the challenges and opportunities of climate change.
Our shared energy future is renewable, not radioactive.
Recommendation:
Our groups call on the Committee to support effective climate action by recommending against the proposed Bill and reaffirming support for the existing and prudent federal nuclear prohibitions.
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