National and International Organisations Join the Stand Against Seismic Blasting of Irish Sea for a Deep Hot Nuclear Dump.
Petition to the Marine Management Organisation can be signed here: https://www.change.org/p/save-the-whale-and-the-snail-stop-nuclear-waste-services-blasting-the-irish-sea
The following letter was sent to the Marine Management Organisation on World Ocean Day (June 8th).
FAO Mr Tom McCormack, Chief Executive, The Marine Management Organisation,
Objection to Seismic Blasting in the Irish Sea to test the geology for a deep geological nuclear facility for heat generating nuclear wastes.
(MMO EXEMPTION reference number EXE/2022/00048)
On this World Ocean Day (8 June), we, the undersigned representing national and international organisations with a concern for our marine environment, are writing to you to protest the outrageous proposal by Radioactive Waste Management Ltd (RWM), now Nuclear Waste Services (NWS), to conduct seismic testing that shall certainly be harmful, and may well prove deadly, to aquatic life in the Irish Sea, at sites off-shore of the West Cumbrian coast to determine the geology of the seabed in preparation to deposit toxic radioactive waste in a repository beneath the sea.
A Marine Licensing Exemption was submitted to the Marine Management Organisation (MMO) on 1 March 2022 citing ‘scientific research’ in the North West marine area.
This was submitted by RWM, now NWS. RWM/NWS have commissioned Shearwater GeoSciences who most commonly conduct similar work for the petroleum and gas industries to carry out this survey work in July – August 2022. We are convinced that RWM / NWS has improperly claimed an exemption from the requirement to secure a Marine Licence on the spurious grounds of ‘scientific research’, and that the Marine Management Organisation (MMO) should oblige the organisation to properly apply for a Marine Licence, which will be subject to a period of public consultation prior to a considered determination by the MMO based on the responses received whether to grant a licence.
By claiming an ‘exemption’, NWS is seeking to excuse itself not only from the possibility of public objections, but also from properly consulting with the many marine welfare and environmental charities on the British mainland, on the island of Ireland and on the Isle of Man with a legitimate and scientific concern for the movement, health and well-being of whales and dolphins, and with the government agencies charged with oversight of maritime matters, such as Nature Scotland, Natural Resources Wales, the Department of Agriculture, Environment and Rural Affairs in Northern Ireland, the Department of the Environment, Climate and Communications in the Republic, and the Department of Environment, Food and Agriculture in the Isle of Man.
Furthermore, it is our belief that the activity being carried out by Shearwater GeoServices specifically requires the granting of a Marine Licence in any case as it is not exempted. Finally, we contest that a European Protected Species Licence should not be granted to RWM / NWS because of the deleterious impact of the proposed testing on our precious marine life, especially as this is being carried out in the protected waters of the Irish Sea.
We should like to outline our views on each of these matters in turn:
The Exemption:
It is claimed that testing is being carried out by RWM/NWS for ‘scientific research’, but the reality is that testing will be carried out in readiness for a large-scale engineering project that is a huge commercial undertaking. For testing will determine the suitability of the geology beneath the Irish Sea to receive millions of tons of toxic radioactive waste that will be deposited in a so-called Geological Disposal Facility running out from a location on land through to a point up to 22km from the coast line.
RWM/NWS as a division of its parent, the Nuclear Decommissioning Authority (NDA), is charged by the British Government to find a location for and dig, engineer, fill and seal this nuclear waste dump, and it will receive billions of pounds from the UK taxpayer to do so – recent estimates published by the NDA suggested the final cost (at current prices) will amount to between £20 – 53 Billion. It is therefore our contention that this activity therefore constitutes a commercial venture rather than an investigation of pure ‘scientific research’ , on a par with similar activities carried out by the petroleum and gas industries in connection with fossil fuel extraction and as a commercial venture should be subject to the granting of a Marine License Furthermore within the category of ‘exemption’ on the grounds of ‘Scientific Research’, there are three sub-categories but two can be ruled out (3.2 Tracers and reagents and 3.3 Samples for testing and analysis) leaving only one that might be relevant (3.1 Scientific instruments).
Except that nothing is being deposited; instead Shearwater GeoServices intend to discharge compressed air to create a shock wave similar to the effect of a huge air rifle being discharged without a pellet loaded. In fact, Shearwater actually call their wave generator an air gun. The level of noise created by each airgun blast is up to 259 decibels – strong enough to kill a human. They are roughly 100,000 times more intense than a jet engine.These blasts occur every 10 seconds, 24 hours a day, 7 days a week, for four weeks. The noise travels incredibly well through water and can be heard by marine creatures up to 4,000km away. We would contend that the repeated and sustained use of an air gun which is capable of causing such damage to aquatic life, from the smallest plankton to the largest whales, is akin to the use of explosive underwater, which can also – if ill managed – cause harm to such life.
Under the sub-section in the licensing section marked deposits there is reference to the ‘Deposit or use of explosives’ and this details the requirement for a marine licence when it is intended to deposit or useany explosive substance or article, by any means, within English waters or Northern Ireland offshore waters, either in the sea or under the sea bed. Although Shearwater are not depositing anything, they are using something and we would contend that using a compressed air driven ‘article’ to create an energy wave is similar to the impact of the blast effect of an explosive underwater, ergo it should be subject to licensing. European Protected Species: Natural England anticipates testing would have behavioural impacts upon European Protected Species (EPS).
Marine welfare charities we have consulted have referenced specifically the likely impact on Risso’s dolphins and basking sharks as species with legal protections (both well known to frequent the waters around the Isle of Man) and the vulnerability of species of baleen whales, such as minke whale (as they are most sensitive to the lower frequency sounds that seismic testing produces).
Our concerns though also embrace the possible impact on harbour porpoises, common dolphin, bottlenose dolphin and sea turtles. The EPS Licence application should be submitted to the MMO as the competent authority responsible for wildlife licensing of activity in English water.
The impact of seismic testing is widespread and aquatic life in the whole of the Marine Conservation Zone and protected areas in the Irish Sea and beyond would be impacted and could be harmed. We are gravely concerned that we have seen no evidence that Shearwater or RWM/NWS have commissioned the services of a competent Marine Mammal Observer as per the guidance. However, even with a competent Marine Mammal Observer, it is clear that the deleterious impact on marine mammals would occur beyond sight lines. Furthermore, the activity for which testing is preparatory will have an adverse impact on the marine environment for millennia. Radioactive waste dumped in a facility beneath the ocean will at some point in future centuries (or sooner) inevitably leak – it is quite inconceivable that a manmade storage environment however well engineered will prevent this inevitability over the course of centuries.
Much of this waste will be highly radioactive and heat generating. The Irish Sea has already over the post-war decades suffered greatly from radioactive contamination being accidentally or wilfully discharged into it from the nuclear power plants and research facilities situated around the Sellafield area. Contamination levels, both offshore and on West Cumbria’s beaches and in her inlets, are significantly higher than the average. With this existing ‘radioactive burden’ the discharge of nuclear waste from an offshore repository could never be meaningfully monitored for leakage. In our view, there is therefore no justification for issuing a European Protected Species licence to Nuclear Waste Services for seismic blasting. Finally, we wish to address any false impression gained by MMO that RWM/NWS has conducted ‘extensive community engagement’ over seismic testing before RWM/NWS registered an Exemption. This is not the case.
The Mid-Copeland Community Partnership, which consists of Councillors and officials from Radioactive Waste Management (now Nuclear Waste Services), plays its business ‘very close to its chest’, and has no residents as members. In fact, the first the public knew about this plan for seismic blasting was on the 20th April via a blog on the Mid-Copeland Community Partnership website. This carried the news that Shearwater GeoServices have been engaged to carry out the blasting between July and August.
No public consultation has taken place specifically in relation to the conducting of seismic testing in the Irish Sea.
In Conclusion:
•There are no grounds for exemption as testing is being pursued for a commercial venture rather than for pure ‘scientific research’.
•Furthermore, the use of an underwater air gun is akin to the use of underwater explosive in that the sound / energy wave created will have similar effects to an explosive blast, and so should require a Marine Licence.
•The testing will cause unjustifiable damage to European Protected Species.
•There is no evidence that the applicant has a competent Marine Mammal Observer in place.
•That there has been no ‘extensive community engagement’ around seismic testing and no community consent obtained.
We therefore respectfully ask the MMO to:
•Require RWM/NWS to apply for a proper Marine Licence.
•Commit to carrying out a proper public consultation and to fully consider the resulting submissions prior to any final determination being made on whether to grant a Marine Licence.
•Refuse the granting of a European Protected Species at this time until the conclusion of this procedure when it should therefore be subject to a further review. Thank you for considering our submission.
We look forward to receiving your response which we would ask you to communicate by email to Marianne Birkby at Wastwater@protonmail.com
Yours sincerely, Marianne Birkby, Co-ordinator, Lakes Against Nuclear Dump, a Radiation Free Lakeland campaign
Councillor David Blackburn, Chair, UK/Ireland Nuclear Free Local Authorities
Philip Gilligan, Co-ordinator, Cumbria and North Lancashire CND
Martyn Lowe, Co-ordinator, Close Capenhurst
Patrick Lyne, Chartered Marine Scientist and Officer, Irish Whale and Dolphin Group
Jonathon Porritt, environmental campaigner and author
Ian Ralls, Co-ordinator of Friends of the Earth Nuclear Network
Irene Sanderson, North Cumbria CND
Ken Smith, Chairman, Guardians of the East Coast
Justin Byrne, Chair, An Claiomh Glas
Phil Kearney, Chair, An Taisce - the National Trust for Ireland
Helen Disley, Joint Co-ordinator, Greenpeace Preston
NOTES:
EXEMPTION - EXE_2022_00048-Copeland - Notification of Geophysical Survey Appendices A to F-3.pdf
GDF - Notification of Marine geophysical survey - February 2022 - Nuclear Waste Services https://drive.google.com/file/d/1IPElJQ6mCWKy0YjygYfBpLdihQrSE27c/view?usp=sharing
Marine Management - Nuclear Waste Services 'Exemption Journey" https://drive.google.com/file/d/1JeYOwj-fIim3U6T0lIo1emc-oS73DZWg/view?usp=sharing
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