The Independent Peaceful Australian Network (IPAN) rejects proposed changes to laws prohibiting nuclear power.
Recommendation 1
Reject the proposed amendments to bills
The Senate Standing Committees on Environment and Communications maintain the status quo in relation to
the Australian Radiation Protection and Nuclear Safety Act 1998 and the Environment Protection and
Biodiversity Conservation Act 1999.
Recommendation 2
Threat priorities
The Australian Government should prioritise as a matter of urgency:
(a) The two existential threats of climate change and nuclear war, and we support joining the Treaty on
the Prohibition of Nuclear Weapons. Prioritising climate change would necessitate a re-orientation of
the role of the Australian Defence Force (ADF).
Recommendation 3
Nuclear energy
The Australian Government should legislate the use of warships or submarines that only use a non-nuclear
energy source.
Submission No.17. The Independent Peaceful Australian Network (IPAN) Public Submission to the Inquiry into Environment andOther Legislation Amendment (Removing Nuclear Energy Prohibitions) Bill 2022
About IPAN
IPAN is a national umbrella organisation of community, peace, faith and environmental groups and trade
unions around Australia with an interest in peace and security. IPAN aims to build public dialogue and pressure
for change to a truly independent foreign policy for Australia – one in which our government plays a positive
role in solving international conflicts peacefully.
The announcement of the Inquiry into Environment and Other Legislation Amendment (Removing Nuclear
Energy Prohibitions) Bill 2022 comes at a very critical time for our country.
IPAN feels very strongly about providing a contribution to this inquiry and seeks to make comments on the
proposal to both amend the Australian Radiation Protection and Nuclear Safety Act 1998 to remove the
prohibition on the construction or operation of certain nuclear installations; and to amend the Environment
Protection and Biodiversity Conservation Act 1999 to remove the prohibition on the Minister for Environment
and Water declaring, approving or considering actions relating to the construction or operation of certain
nuclear installations. These Acts currently expressly prohibit the approval, licensing, construction, or operation
of a nuclear fuel fabrication plant; a nuclear power plant; an enrichment plant; or a reprocessing facility.
Australia currently faces rapidly changing strategic circumstances, global instability and planetary threats to
human security. This set of interlinking challenges, among others, requires an urgent and holistic response
from the Australian government.
Recognising the circumstances outlined above, in 2020 IPAN initiated its own national public inquiry to ‘Explore
the Case for an Independent and Peaceful Australia’ (the People’s Inquiry) so as to determine a path that would
lead Australia towards a genuinely independent, peaceful and secure defence and foreign policy.
IPAN led ‘People’s Inquiry: Exploring the Case for an Independent and Peaceful Australia’
The People’s Inquiry comprehensively questioned the foundations and assumptions underpinning the
cornerstone of Australia’s security – the Australia-US Alliance – across several impact areas: military and
defence, foreign policy, First Nations peoples, politics, society, workers, economy, and the environment.
The People’s Inquiry received 283 submissions from individuals and organisations across the country. An
interim report was released in October 2021 and the full report was released on 22 November 2022.
IPAN’s submission to this current inquiry draws, in part, on the findings and recommendations of the People’s
Inquiry, specifically those related to the area of impact on First Nation’s people, military and defence, foreign
policy and the environment. In particular, some submissions focused directly on issues surrounding nuclear
energy including concerns around storage of nuclear waste and consultation around land use (IPAN 2022a.
pp.21,23).
For a full copy of the Inquiry Report go to https://independentpeacefulaustralia.com.au/
Introduction
IPAN’S interest in matters related to nuclear energy, nuclear installations and nuclear weapons
IPAN has had a longstanding concern about nuclear issues, as a network of organisations and individuals
motivated by the desire to see peaceful resolutions to international conflicts and greatly concerned that our
world never sees a nuclear bomb dropped again – in particular such as the two bombs dropped on Hiroshima
and Nagasaki in 1945, leading to the immediate and subsequent deaths of over two hundred thousand people.
To this end, IPAN (and many member organisations and individual members) has been a very strong supporter
of the international Campaign to Abolish Nuclear Weapons (ICAN) regarding the adoption of a UN treaty to
prohibit nuclear weapons – i.e. the Treaty on the Prohibition of Nuclear Weapons (TPNW).
IPAN has been heartened by the positive steps that have been taken by the new Federal government, in
attending the first Meeting of States Parties to the TPNW in Vienna in June and ending Australia’s opposition tothe treaty by abstaining on a resolution at the UN First Committee after the previous government’s practice of voting ‘No’
Proposed Amendments to Federal Legislation
IPAN is concerned about the proposals in the bill to amend the Australian Radiation Protection and Nuclear
Safety Act 1998 to remove the prohibition on the construction or operation of certain nuclear installations;
and in the Environment Protection and Biodiversity Conservation Act 1999 to remove the prohibition on the
Minister for Environment and Water declaring, approving or considering actions relating to the construction or
operation of certain nuclear installations.
IPAN’ broad concerns with the use of nuclear power
First and foremost, IPAN believes that radiation is dangerous to people and the environment and that it is
critical to reduce human exposure to it. In addition, IPAN believes that the adoption of nuclear power in
Australia would increase electricity costs, slow the transition to a low-carbon economy and introduce the
potential for catastrophic accidents.
IPAN is also concerned about the water resources required for the production of nuclear energy, with huge
volumes required for the production of nuclear energy. We are also concerned about the contentious issue of
where to store nuclear waste, given the associated long-term risks of storage.
This submission therefore makes a number of key points in relation to the proposed amendments to the two
acts – which if adopted would remove the blanket prohibition on the construction or operation of certain
nuclear facilities. IPAN believes that the current blanket prohibition acts as a very important safeguard against
the risks and dangers associated with the nuclear industry – and that to remove this blanket prohibition would
be to the detriment of the Australian community, the environment and the Australian ecosystem.
Factors for the Senate Standing Committees on Environment and Communications to consider in its
decision regarding the proposed amendments
1 The dangers of radiation and risks of human exposure …………………………………………………….
2. Lack of compliance in the uranium mining industry.…………………………………………………….
3 The links between nuclear technology and military nuclear technology’
IPAN is in particular concerned with the links between civil nuclear technology and military nuclear technology.
The ACF have highlighted that uranium is a “dual use fuel and nuclear is a dual use technology – it can power a reactor or a weapon” and they have described how the current conflict in Ukraine has seen “the weaponization of nuclear facilities and the threat of an uncontrolled radiation release”, even if the Russian army does not use its nuclear weapons (ACF 2022a, p.1 cited in IPAN, 2022, p. 71).
The development of nuclear energy could be seen as a slippery slope to the eventual development of nuclearpowered weapons and even nuclear weapons themselves. It is important to recognise that nuclear power
programs have provided cover for numerous weapons programs over many years. An expansion of nuclear
power would simply worsen the situation……………………
Nuclear reactors are pre-deployed military or terrorist targets. The current situation in Ukraine illustrates the
risks:…………………………..
The current ban on nuclear energy in Australia provides a very important safeguard to avoid any chance of the
eventual development of nuclear-powered weapons and even nuclear weapons themselves. We must continue
this ban…………………………………………………………
4 The Costs of Nuclear Power
As pointed out in the second reading speech (by Senator Matt Canavan) of the ‘Environment and Other
Legislation Amendment (Removing Nuclear Energy Prohibitions) Bill 2022 Wednesday, 28 September 2022, the building of a nuclear plant requires high capital costs and long construction times. While the Senator also
argues that nuclear plants have relatively low operating costs – other factors must be considered, such as the
cost of rehabilitation of mines and the cost of storage of nuclear waste, as well as the many risks involved………………………………………………
5. The Costs of nuclear energy vs renewable energy sources
IPAN believes that it is important to address a number of the claims made by Senator Canavan in the Second
reading Speech (Australian Parliament 2022), for example where he asserted that “The relative costs of nuclear
compare well to renewable energy. Between 1965 and 2018 the world spent $2 trillion on nuclear compared to $2.3 trillion for solar and wind, yet nuclear today produces around double the electricity than that of solar and
wind.” He also added that costs may reduce soon.
As figures from Lazard Asset Investment (2021) in their annual Levelized Cost of Energy, Levelized Cost of
Storage, and Levelized Cost of Hydrogen Report showed, the cost of nuclear energy is far greater than that of
renewables, as per the following table. [ on original]
The costs of renewable technologies continue to decline globally, albeit at a slowing pace, reflecting reductions
in capital costs, increased competition as the sector continues to mature and continued improvements in scale
and technology. “Since 2010, the cost of energy has dropped by 82% for photovoltaic solar, by 47% for
concentrated solar energy (CSP), by 39% for onshore wind and by 29% for wind offshore.”
Unlike the costs of wind and solar, the cost of nuclear power has actually risen over time, since 2008, the
“projected cost of new nuclear power has risen by fourfold…and it is still rising”.
These figures are backed up by recent research from CSIRO and the national energy market operator (the
Australia Energy Market Operator (AEMO), with the 2022 CSIRO-AEMO GenCost report also showing that
nuclear power is simply not competitive with renewables, with 2030 cost estimates for Australia as follows
- A$136-326/MWh for Nuclear (small modular):
- A$61-82/MWh for 90 percent wind and solar PV with integration costs (transmission, storage and
synchronous condensers) necessary to allow these variable renewables to provide 90 percent of electricity in
the National Electricity Market. (CSIOR/AEMO, 2022).
IPAN believes that there is simply no economic case for nuclear power in Australia.
Senator Canavan also referred to the trials of Small Modular Reactors that are happening in a range of
countries currently and that “if they become a commercial prospect, their modular nature may deliver
substantial cost savings through mass production”.
The ACF/ICAN have made the very clear point that SMRs however are unproven and do not actually make
electricity in the real world, and further to this, the US Academy of Science in 2018 stated that “several
hundred billion dollars of direct and indirect subsidies would be needed to support their development and
deployment over the next several decades” (cited in ACF/ICAN 2022)……………………………………………………
6 Environmental Impacts
Urgent and Effective Action required.
The chaotic climate events that have punished Australia in recent years demand urgent and effective action.That urgency disqualifies the most expensive and slowest response (as outlined immediately above). In thisway, expense is not simply a consideration for investors. In addition, the imperative to better manage climate change is a strong argument against nuclear power
Storage of Nuclear Waste
IPAN is concerned that despite years of debate and attempted negotiations around the storage of nuclear
waste, it is now 2023 and there is still no agreement on a proven solution to manage or isolate and dispose of
high-level radioactive waste that has been produced in power reactors. Currently there is not one single
operating deep underground repository for high-level nuclear waste across the world……………………………
………………………………………
Another very significant factor is the extreme reluctance on the part of communities earmarked as a site or
potential site for nuclear waste. There are clear issues of racism in the choice of nuclear waste dump sites.
A pertinent point is made by Native American activist, Winona LaDuke,
The greatest minds in the nuclear establishment have been searching for an answer to the radioactive
waste problem for fifty years, and they’ve finally got one: haul it down a dirt road and dump it on an
Indian reservation.
Three years of electricity in a reactor leaves a legacy of 100,000 years of waste – a massive inter-generational
burden, which represents a “Poor risk to return ratio” and damage to the environment for hundreds of
thousands of years……………………………………………….
Water resources required
There are also significant issues around the water resources required for the production of nuclear energy, with
a huge volume of precious and at times scarce water resources required on an ongoing basis for the production
of nuclear energy. As an example from Australia, the Mulga Rock uranium project (200 kms east of Kalgoorlie – near the Queen Victoria nature reserve in the Great Victoria Desert), one of four proposed uranium
mines given approval by WA’s former Liberal-National government Environmental approvals, would see the
“extraction of 15 million litres of water per day, would create 32 million tonnes of tailings, threatens vulnerable species including the Sandhill Dunnart” (ACF/ICAN 2022)…………………………………………………….
Australia’s current independent stance in banning nuclear energy
AS rightly pointed out, by Senator Canavan in the Second Reading Speech, Australia is “the only developed
country, only G20 country in the world that actually bans nuclear energy (which has been in effect since the 10
December 1999 decision of Federal Parliament Australia is also one of only three countries within the 20
richest nations in the world to not have nuclear energy………………….. this must be a cause of celebration, not derision. IPAN feels that it is disingenuous of Senator Canavan to refer to Australia’s “status as a nuclear outcast”. While Senator Canavan highlights the fact
that “Australia has the largest reserves of uranium in the world” – this is not a reason to develop nuclear
energy, for all of the reasons that IPAN is highlighting in this submission.
Decisions about investing in nuclear energy
IPAN has concerns about Senator Canavan’s assertion that “The potential for high costs is not a reason to ban
anyone building a power station” and that “Decisions about the relative profitability of different investments
should be left to the businesses making those decisions”. This is not how public policy works. There are a rangeof processes and provisions that must be worked through with any public policy decision, with environmental impact assessments being one such example. Decisions such as these cannot happen in a void or be left purelyto the market (usually subsidised, in the case of nuclear power).
It also seems rather bewildering that the Senator also makes the seemingly very obvious comment that
“Our environmental laws should focus on protecting Australia’s natural environment.”. The proposal to amend
the two Acts in question represents precisely the kind of scenario where environmental laws should come in to
play – to assess any negative impacts on the natural environment that would result from future use of nuclearenergy.
Previous Inquiries regarding nuclear energy in Australia
A number of recent and very recent inquiries are very relevant to the issues being examined in this current
inquiry. It is fair to say each of the three inquiries listed did not come out favourably for the nuclear industry.
- 2019: Inquiry into the prerequisites for nuclear energy in Australia https://www.aph.gov.au/nuclearpower
- 2016: SA Nuclear Fuel Cycle RC http://nuclearrc.sa.gov.au/
- 2006: Uranium Mining Processing and Nuclear Energy Review (UMPNER)
https://catalogue.nla.gov.au/Record/3960972
The 2006 UMPNER was particularly comprehensive and very well resourced and contained a relatively high
proportion of people who were pro-nuclear – yet it concluded with a resounding, reluctant ‘no’.
10 Impact on First Nations peoples
First Nations’ peoples and their lands are especially impacted by the nuclear industry, both historically (sincethe UK nuclear bomb tests of the 1950s in outback South Australia) and presently.
11 Human rights issues
……………………………… There are clearly human rights implications whenever there is a proposal for the introduction or use of a substance or material that has the potential for catastrophic accidents and where there are inherent risks and challenges, such as those associated with the use of nuclear energy and high-level nuclear waste management. The exclusion of First Nations Peoples from their traditional lands used as the waste repository site represents a major denial of the human rights of those First Nations People.
12 Why Australia should sign and ratify the Treaty on the Prohibition of Nuclear Weapons (TPNW)…………………………………………………………………………………..
Recommendations
IPAN submits the following recommendations to the Senate Standing Committees on Environment and Environment and Communications:
Recommendation 1
Reject the proposed amendments to bills
The Senate Standing Committees on Environment and Communications maintain the status quo in relation to
the Australian Radiation Protection and Nuclear Safety Act 1998 and the Environment Protection and
Biodiversity Conservation Act 1999.
Recommendation 2
Threat priorities
The Australian Government should prioritise as a matter of urgency:
(a) The two existential threats of climate change and nuclear war, and we support joining the Treaty on
the Prohibition of Nuclear Weapons. Prioritising climate change would necessitate a re-orientation of
the role of the Australian Defence Force (ADF).
Recommendation 3
Nuclear energy
The Australian Government should legislate the use of warships or submarines that only use a non-nuclear
energy source.
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