Subject: Public Comment on Redesigning the Uranium Resource Pathway from Dave Sweeney, Australian Conservation Foundation
15 February 2019
ACF and wider civil society groups in Australia do not share or support the underlying rationale of this initiative and do not accept that uranium/nuclear power has a key or growing role in contributing to sustainable development or the attainment of the 2030 Agenda. This fundamental assumption is actively contested as we maintain that it is renewable energy that provides the safer. cleaner, more cost effective and deployable energy pathway.
Worldwide, a record amount of new renewable power capacity has been installed every year over the past decade. Renewables accounted for 26.5 per cent of global electricity generation in 2017 compared to nuclear’ s 10.3 per cent.
In January, Australia's Climate Council ‒ comprising our leading climate scientists and other policy experts ‒ issued a policy statement concluding that nuclear power plants "are not appropriate for Australia – and probably never will be. 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 Climate Council said.
ACF challenges the growth assumptions for the nuclear sector that underpin this initiative, including the possible future role of SMR (Small Modular Reactor) technology. Only a few SMRs have been built and the scale means they will likely be even more uneconomic than large, conventional reactors. William Von Hoene, senior vice-president at US energy giant Exelon, said last year SMRs were "prohibitively expensive ... in part because of the size and in part because of the security that's associated with any nuclear plant".
ACF’s view on the constraints facing the nuclear power sector and why it is unlikely to play a significant role in addressing the challenges posed by the real and pressing need to embrace a low carbon energy future are well reflected in WISE/NIRS Nuclear Monitor, 25 June 2016, 'Nuclear power: No solution to climate change', https://wiseinternational.org/sites/default/files/NM806-climate-nuclear.pdf
ACF is disappointed that the discussion around SLO (Social Licence to Operate) fails to explicitly acknowledge and address the disproportionate impact the uranium and nuclear sector has on the lands and lives of Indigenous peoples – and the role they have and do play in challenging this sector globally. This omission is glaring and profoundly undermines the credibility of any process that seeks to promote sustainability. ACF is a proud member of the Australian Nuclear Free Alliance – ANFA is a network of industry affected Aboriginal people and civil society supporters: https://www.anfa.org.au/
Systemic Aboriginal disadvantage has not been addressed by mining operations and most mining agreements have failed to deliver lasting benefits to Indigenous communities. Indigenous peoples ability to exercise full, free, prior and informed consent and effective input into the activities of mining operations on their traditional lands is compromised by severe capacity and procedural constraints. The legal and approvals framework governing the uranium sector should be changed to address this power imbalance.
ACF also notes the absence of a detailed assessment of the nuclear proliferation/safeguards issue and is further disappointed that much of the framing around SLO concerns (e.g./ 5.1.1) is expressed in terms of ‘anxiety’. This is reductionist and patronising. Critics of the nuclear and uranium sectors are not fear-filled or anxious, rather they are cognisant of the very significant gap between the sector’s promises and its performance. The failure of the Uranium 4.0 approach to genuinely engage with the concerns articulated by critics of the nuclear sector is not consistent with the initiatives stated purpose.
ACF welcomes the acknowledgement (3.12.2) that past industry rehabilitation and closure practises are ‘no longer acceptable’. As is the case in other nations, there is a history of sub-standard mine rehabilitation in the Australian uranium sector and an urgent need to address the long-term impacts of the Australian uranium sector in a way that does not allow cost shifting from mining companies to the public purse. This is a particular focus of attention now in relation to the current rehabilitation and closure activities at the heavily impacted Rio Tinto/ Energy Resources of Australia Ranger mine site in the Kakadu World Heritage region in the Northern Territory.
In conclusion, the global uranium sector will be viewed and judged by its operational reality, not its framework rhetoric. The uranium sector remains controversial and contested. It is characterised by underperformance and non-compliance and is in urgent need of regulatory reform. Unresolved concerns over site specific contamination, tailings management, radioactive waste and links with nuclear proliferation mean that the global uranium sector continues to fail any measured sustainability assessment.
15 February 2019
ACF and wider civil society groups in Australia do not share or support the underlying rationale of this initiative and do not accept that uranium/nuclear power has a key or growing role in contributing to sustainable development or the attainment of the 2030 Agenda. This fundamental assumption is actively contested as we maintain that it is renewable energy that provides the safer. cleaner, more cost effective and deployable energy pathway.
Worldwide, a record amount of new renewable power capacity has been installed every year over the past decade. Renewables accounted for 26.5 per cent of global electricity generation in 2017 compared to nuclear’ s 10.3 per cent.
In January, Australia's Climate Council ‒ comprising our leading climate scientists and other policy experts ‒ issued a policy statement concluding that nuclear power plants "are not appropriate for Australia – and probably never will be. 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 Climate Council said.
ACF challenges the growth assumptions for the nuclear sector that underpin this initiative, including the possible future role of SMR (Small Modular Reactor) technology. Only a few SMRs have been built and the scale means they will likely be even more uneconomic than large, conventional reactors. William Von Hoene, senior vice-president at US energy giant Exelon, said last year SMRs were "prohibitively expensive ... in part because of the size and in part because of the security that's associated with any nuclear plant".
ACF’s view on the constraints facing the nuclear power sector and why it is unlikely to play a significant role in addressing the challenges posed by the real and pressing need to embrace a low carbon energy future are well reflected in WISE/NIRS Nuclear Monitor, 25 June 2016, 'Nuclear power: No solution to climate change', https://wiseinternational.org/sites/default/files/NM806-climate-nuclear.pdf
ACF is disappointed that the discussion around SLO (Social Licence to Operate) fails to explicitly acknowledge and address the disproportionate impact the uranium and nuclear sector has on the lands and lives of Indigenous peoples – and the role they have and do play in challenging this sector globally. This omission is glaring and profoundly undermines the credibility of any process that seeks to promote sustainability. ACF is a proud member of the Australian Nuclear Free Alliance – ANFA is a network of industry affected Aboriginal people and civil society supporters: https://www.anfa.org.au/
Systemic Aboriginal disadvantage has not been addressed by mining operations and most mining agreements have failed to deliver lasting benefits to Indigenous communities. Indigenous peoples ability to exercise full, free, prior and informed consent and effective input into the activities of mining operations on their traditional lands is compromised by severe capacity and procedural constraints. The legal and approvals framework governing the uranium sector should be changed to address this power imbalance.
ACF also notes the absence of a detailed assessment of the nuclear proliferation/safeguards issue and is further disappointed that much of the framing around SLO concerns (e.g./ 5.1.1) is expressed in terms of ‘anxiety’. This is reductionist and patronising. Critics of the nuclear and uranium sectors are not fear-filled or anxious, rather they are cognisant of the very significant gap between the sector’s promises and its performance. The failure of the Uranium 4.0 approach to genuinely engage with the concerns articulated by critics of the nuclear sector is not consistent with the initiatives stated purpose.
ACF welcomes the acknowledgement (3.12.2) that past industry rehabilitation and closure practises are ‘no longer acceptable’. As is the case in other nations, there is a history of sub-standard mine rehabilitation in the Australian uranium sector and an urgent need to address the long-term impacts of the Australian uranium sector in a way that does not allow cost shifting from mining companies to the public purse. This is a particular focus of attention now in relation to the current rehabilitation and closure activities at the heavily impacted Rio Tinto/ Energy Resources of Australia Ranger mine site in the Kakadu World Heritage region in the Northern Territory.
In conclusion, the global uranium sector will be viewed and judged by its operational reality, not its framework rhetoric. The uranium sector remains controversial and contested. It is characterised by underperformance and non-compliance and is in urgent need of regulatory reform. Unresolved concerns over site specific contamination, tailings management, radioactive waste and links with nuclear proliferation mean that the global uranium sector continues to fail any measured sustainability assessment.