UK Government Consultation On The Future OF Nuclear Power
The Scottish Government Response
The Scottish Government's position on nuclear power
The Scottish Government is committed to achieving a secure, affordable, low carbon energy future - with a vibrant and growing energy sector that makes a significant contribution to Scotland's prosperity.
Scotland has a wealth of clean renewable power opportunities - as well as significant opportunities for deployment of clean fossil-fuel technologies and carbon storage. Seizing these opportunities will meet our future energy demands, help tackle climate change, and ensure Scotland's energy security. We do not believe there is an energy gap which only nuclear power can fill. We have made clear our opposition to new nuclear power stations in Scotland.
The UK Government states that it has formed an initial view that new nuclear power stations are needed to ensure the security of energy supplies, and to tackle climate change.
The Scottish Government is clear that the challenges of climate change and energy security are real and urgent - and that is why, as a part of our climate change response, we are committed to introducing a Scottish Climate Change Bill and proposing an ambitious target to reduce carbon emissions by 80% by 2050. However, we believe the issues of climate change can be addressed, and security of energy supplies ensured, without the development of new nuclear power stations. It is our responsibility to future generations to ensure that we tackle climate change now, and that we do this in a way that adds to future prosperity and quality of life - without imposing an increasing burden of toxic radioactive waste on future generations.
Our concern is that the UK Government has set out on a route to developing new nuclear power stations without adequately considering the alternatives, or indeed allowing the public to consider the alternatives as a part of this consultation. The reality is that the diversion of £ billions into nuclear power station development could have a significant adverse impact on research and development of long term clean energy alternatives to nuclear power. Unlike nuclear power, these clean energy alternatives are sustainable, and through export of energy and the related technologies could add hugely to Scotland's prosperity.
We are convinced that Scotland has the resources, skills, and leadership to pursue a clean, low carbon approach to energy policy that uses a combination of energy efficiency, renewables, microgeneration, combined heat and power, and carbon capture and storage. Renewables and clean fossil fuel technologies have massive potential in Scotland. Such an approach will not require a new generation of nuclear power stations in Scotland. Studies show there is more than enough renewable resource in the UK to provide a diverse, low carbon electricity supply. It is possible to meet our energy needs in a low carbon constrained economy without nuclear power.  The risks and uncertainties associated with nuclear power - whether in terms of waste disposal and decommissioning, security and health concerns, or cost and efficiency - remain too great when set against the low levels of Carbon Dioxide ( CO 2) reduction that would be provided by a new generation of nuclear power stations.
We hope that in considering this response, the UK Government will accept the weight of evidence against the need for new nuclear power stations in Scotland, and indeed across the UK, and that it will abandon its preliminary view to allow such a programme of development.
Scotland neither wants, nor needs, new nuclear power stations, and the Scottish Government owes it to the people of Scotland, and the health and prosperity of future generations, to oppose such a plan. We believe that our position has the clear support of the majority of members in the Scottish Parliament.
Security of Energy Supplies
Over 80%  of the energy consumed in developed countries currently comes from fossil fuels - oil, gas, and coal - and global demand for those fossil fuels continues to grow significantly. As oil and gas production from the North Sea is likely to decline to some degree over the next 30 years or so both the UK and Scotland could become increasingly reliant on imports of energy.
The UK Government's approach to meeting this challenge is to diversify the sources of those imports, and to build new nuclear power stations that would rely on imported uranium.
The Scottish Government's approach is to avoid reliance on imported fossil fuels by developing our indigenous energy resources - both renewable energy resources, as well as clean use of fossil fuels.
Scotland is estimated to have 60 GW of renewable energy resources - 10 times Scottish peak demand and the equivalent of three-quarters of the UK's installed electricity generating capacity. Scotland already generates 18% of its electricity from a mixture of renewable energy resources - largely hydroelectric and onshore wind. Currently there are applications to build a further 5 GW of renewable generation in Scotland.
The Scottish Government believes that investing in new, developing technologies, such as renewable generation, clean fossil-fuel and carbon capture technologies is a far more robust means of achieving energy security. Such an approach would generate many new jobs in technological research and development, cementing Scotland's position as a world leader in energy innovation, whilst at the same time ensuring a viable future for Scotland's fossil-fuel industries. Studies demonstrate that diverse and secure electricity supplies are entirely achievable without resort to nuclear power. 
Furthermore, Scotland produces far more electricity than it consumes. Around 20% of the electricity generated in Scotland is exported to the rest of the UK. This is roughly equivalent to the annual output of one of Scotland's two existing nuclear power stations. Therefore, when Hunterston B nuclear power station was closed for repairs for over 6 months in the last year it should come as no surprise that there was no interruption to Scotland's electricity supplies.
A new generation of nuclear power plants in the UK would be reliant on imported uranium. World reserves of uranium are finite - and as countries such as China build more nuclear power stations, global demand for uranium is growing. Studies estimate that world supplies of uranium may last another 80 years. There is a long lead time for developing new uranium resources, and supplies could become far more reliant on countries like Kazakhstan and Russia, rather than long-standing suppliers such as Australia and Canada . This should raise concerns about the potential long-term vulnerability of uranium supplies to political instability.
In addition growing demand for uranium can be expected to increase uranium prices. Prices for uranium are currently around $90 per pound having reached $150 per pound earlier this year. This compares to $20 per pound in 2000. Future significant price rises, or disruptions to uranium supplies, could affect the commercial viability of nuclear power operators - and therefore jeopardise the future operation of nuclear power stations.
We conclude therefore that nuclear power is not necessary to deliver secure energy supplies in Scotland, and furthermore that it cannot be automatically assumed that nuclear power will be any more secure than other forms of imported energy.
Climate change and carbon emissions
The Scottish Government agrees with the UK Government's view that "climate change represents a significant risk to global ecosystems, the world economy, and human populations," and is committed to ensuring that Scotland plays its part in responding to the challenge.
That is why the Scottish Government has announced its intention to consult on proposals to set a mandatory, long-term target to achieve an 80% reduction in Scottish emissions by 2050, in a Scottish Climate Change Bill. This challenging target will exceed the UK Government commitment and demonstrates the Scottish Government's determination to address climate change. Over a third (37%) of Scotland's emissions are associated with the energy supply sector  and tackling emissions from energy generation and use will clearly need to be an area for action if the Government is to meet its ambitious emissions reduction target.
The Scottish Government's approach to reducing carbon emissions from energy supply is broad - embracing renewable energy; carbon capture and storage; energy efficiency and microgeneration. The UK Government's approach is to largely dismiss these alternatives and focus on reducing carbon emissions through nuclear power.
In calculating the carbon emissions from nuclear power the Scottish Government believes that the full life cycle, including the mining, processing, transportation, and decommissioning of nuclear power generation must be taken fully into account. In particular, the Scottish Government is concerned that the CO 2 emissions associated with the decommissioning of nuclear power plants, and future waste management are not adequately taken into account in the UK Government's consultation paper.
The Sustainable Development Commission's  report shows that whilst nuclear power currently displaces around 9% of total UK carbon dioxide emissions, its future potential is only to make a 4% cut in UK emissions if existing capacity is replaced, or an 8% cut if nuclear capacity is doubled. It is our view that such small potential cuts do not justify the huge investment that new nuclear power would require across its life cycle, when compared to other sources.
The Scottish Government believes that renewable energy generation - such as wind, hydroelectric, wave and tidal power, bioenergy - produces less carbon than nuclear power. Scotland has vast potential to harness these clean, largely free sources of energy. The Scottish Government has set a commitment to achieve 40% of its electricity from these sources by 2020, and is well on the way to achieving this. Indeed, we have already met our target to achieve 18% of electricity generation from renewable energy sources. The Scottish Government believes that further carbon savings could be achieved through clean fossil-fuel and carbon sequestration technologies and we believe that the UK should support and invest in the development of these technologies.
Energy efficiency and microgeneration also have key roles to play. Improving energy efficiency is widely recognised as the easiest and most cost-effective means of reducing carbon emissions. Research carried out by Government-funded organisations such as the Energy Saving Trust and the Carbon Trust has shown that all sectors can reduce their energy consumption by between 10 and 20% by taking simple no- and low-cost measures, such as switching off appliances when not required, implementing insulation measures etc. Capital investment on energy efficiency can yield even greater returns, often a 30-40% saving, by replacing old and carbon-intensive equipment.
In Scotland, we recently set up an expert panel to make recommendations on improving the energy efficiency of our buildings to benchmark against Scandinavia and we have also commissioned further research into the integration of low and zero carbon technologies, including microgeneration, to consider further improvements to our building standards.
Microgeneration can provide a sustainable source of low carbon energy and help to reduce carbon dioxide emissions from homes and other buildings such as leisure centres and schools.
The legacy of infrastructure and known geology from oil and gas production places Scotland in a strong position to exploit opportunities to reduce sequester carbon - through capturing carbon dioxide and storing it in depleted oil and gas fields and deep saline aquifers. Studies estimate that geological structures beneath the North Sea could store somewhere between 60 and several hundred years of carbon emissions from the UK. Carbon sequestration in depleted oil and gas fields can also enhance oil and gas production, thus contributing to UK energy security. The technology could offer the opportunity for a new industry in the North Sea - prolonging the life of the existing infrastructure and utilising the world class skills base in the offshore industry.
Carbon capture and storage has the potential to reduce net atmospheric carbon dioxide emmissions from power stations by up to 90% . Given that three of Scotland's priciple power stations (Longannet, Cockenzie and Peterhead) burn fossil fuels and contribute up to 30% of Scotland's carbon dioxide emissions, this would represent a significant reduction.
It is these technologies, and innovative projects such as the Peterhead DF1 project, (which the UK Government has so far failed to support), that could make a major contribution to meeting our climate change objectives.
Nuclear power and safety
The Scottish public are clearly concerned about the safety of nuclear power stations. Nuclear incidents - such as Three Mile Island, Chernobyl, and Windscale - whilst rare, have acted to increase public concerns over the safety of nuclear power, and these concerns cannot simply be dismissed.
There is a well established regulatory structure in the UK to ensure that civil nuclear power stations operate in a safe and secure environment. However, without nuclear power, we would remove the need for the transportation, disposal, and storage of radioactive materials associated with nuclear power generation - and the potential terrorist threats associated with these activities. It is the responsibility of any Government to ensure the public safety and health of its citizens, and whilst research indicates that the health impacts of well-managed nuclear power facilities are normally small , the Scottish Government remains of the view that no new nuclear power is the safest option for the people of Scotland.
The Scottish Government recognises the existing concerns of the public on the transportation and security of nuclear installations and the materials used in the facilities, and we will continue to work with the various Government departments and organisations to further harmonise their roles and procedure until nuclear power is removed from Scotland permanently.
Nuclear waste, decommissioning, and fuel reprocessing
There continues to be public concern over the handling of radioactive material from nuclear power stations. As the report from the UK Government's nuclear power consultation seminar, "Talking Energy: the future of nuclear energy" on 8 September 2007, showed, over 50% of those who took part across the UK were either "dissatisfied or very dissatisfied with the [UK] Government's proposal to manage new nuclear waste in the same way as current waste (geological storage) ".
On 25 June 2007 the Scottish Government announced that it did not endorse the Managing Radioactive Waste Safely ( MRWS) consultation published by the UK Government and the devolved administrations of Wales and Northern Ireland on geological disposal. The Scottish Government did not accept that it was right to seek to bury nuclear waste, which will remain radioactive for thousands of years, in underground sites. The Scottish Government affirmed its support for all other current policy initiatives for the management of radioactive waste and the decommissioning of nuclear sites in Scotland. We do not want to increase radioactive waste in Scotland by building new nuclear power stations. The Scottish Government disagrees with the UK Government's assumption that deep storage would enable the safe development of new nuclear power in the future.
Economics of Nuclear Power
It would seem that the UK Government believes that nuclear power stations would yield economic benefits to the UK in terms of reduced carbon emissions and security of supply benefits. The Scottish Government, and other studies, believes that the costs of a new nuclear programme are likely to significantly higher than estimated. 
The historic experience of nuclear power in the UK has been characterised by optimistic estimates of construction costs, poor management, hidden subsidies, and uncertainties over decommissioning, and an expectation on the part of the industry that Government will always rescue the industry should it fail - as recent experience with British Energy has shown.
The Scottish Government also remains deeply concerned about the potential costs associated with future decommissioning of new nuclear power stations. The cost of decommissioning the Nuclear Decommissioning Authority's nuclear facilities has been estimated at £62.7 billion (undiscounted) , with estimated costs of between £220m and £440m per GW of potential future capacity, even before waste disposal costs have been factored. These costs will inevitably be passed on to consumers and taxpayers. We do not believe that such a price is worth paying. Such vast sums of money could be spent far more effectively on the research, development and commissioning of new renewable and clean carbon technologies.
This evidence leads the Scottish Government to conclude that there is no guarantee that new nuclear power stations would be an economic proposition in comparison to other cleaner forms of energy.
Applications to build new nuclear power stations
Under devolved powers, any application to build a new nuclear power station in Scotland would require consent from Scottish Ministers under Section 36 of the Electricity Act 1989.
Any proposal from the industry to build a new power station would need to be considered on its individual merits. However, Scottish Ministers have made it clear that given the Scottish energy policy position and the Scottish Government's desire to explore alternative strategies, combined with Scotland's current generating capacity and abundant energy sources, it is unlikely that proposals from the industry for new nuclear generation, would find favour with the Scottish Government.
In practice, should the UK Government proceed with a programme of new nuclear build, a range of commercial and infrastructural factors make it appear that applications to build new nuclear power stations would be more likely to occur in the Southern half of England.
In England the UK Government plans to take action to speed up and reduce uncertainty in the planning and consent process for new nuclear power stations. Where these are devolved matters (such as planning, consents, and environmental regulation) the Scottish Government will not take any similar action that would facilitate the building of new nuclear power stations.
Alternatives to nuclear power
One of the major failings of the UK Government's consultation is that it does not provide the necessary information, and does not allow the public to consider and give a view on the alternatives to nuclear power on a like for like basis.
The Scottish Government does not believe that Scotland needs to rely on nuclear power for low carbon energy. The capacity of installed renewable energy generation in Scotland already exceeds that of nuclear power and current trends suggest that renewables electricity generation itself will exceed that of nuclear by 2011. The Scottish Government is doing everything within its devolved powers to promote a diverse renewables supply. This includes providing short-term capital grant aid which, in the case of biomass, will result in up to 80 new projects this year, spread across Scotland, and bringing wider economic and social benefits particularly in rural communities. Longer term revenue support is also being provided in the Marine Supply Obligation which could be worth up to £700M to the marine generation sector over the next 20 years. There is also an enormous opportunity to develop the deep water offshore wind sector, and the Scottish Government is directly supporting the world's deepest water demonstrator in the North Sea.
Indeed, the potential to harness offshore renewables may also lead to enhanced security of supply as international grid connections are developed. The Scottish Government aims to kick-start this process with studies on grid connectivity between Scotland and Ireland, and Scotland and the North Sea regions.
We also believe that there is a risk that investment in a new nuclear programme would reinforce the UK's reliance on a centralised grid system and could therefore decrease the investment available for the network reinforcement needed to cope with much higher levels of decentralised generation (microgeneration) and large-scale renewables . The Scottish Government's commitment to supporting renewables (and microgeneration) is clear, and such an outcome could seriously prejudice the necessary changes to the transmission network.
Investment in renewables, energy efficiency and carbon storage and capture technologies - at the levels that would be required to deliver a new UK nuclear power programme - could give the UK and Scotland a world lead in these technologies. The Stern Report concluded that "Globally, support for energy R&D should at least double, and support for the deployment of new low-carbon technologies should increase up to five-fold."  This represents a major opportunity for the UK and Scottish economies - disregarding it has serious risks for our future prosperity.
The UK Government needs to give the public a fuller picture of the alternatives to nuclear power. We acknowledge that all such approaches have potential environmental and financial implications - but the UK Government needs to make a full evaluation of the alternatives, and allow the public a realistic choice between a range of feasible methods of delivering a secure, affordable, low carbon energy future.
Our obligation to future generations
Finally, in making a decision on new nuclear power stations the UK Government is taking a decision that not just we in the current generation will have to live with. It is a decision that many future generations will have to live with and pay for. It is therefore not a decision that should be forced through quickly. For all the reasons above, the Scottish Government believes that a UK policy in favour of nuclear power is disastrously short-sighted - it ignores our many other opportunities and will leave a legacy of toxic, radioactive waste that will last far beyond the lives of our great grandchildren. We have feasible, reliable alternatives to nuclear power; it is time that UK Government took them seriously.
 SOURCE: Sustainable Development Commission (2006) SDC Position Paper: The Role of Nuclear Power in a Low Carbon Economy, SDC, London, p.2.
 SOURCE: BP Statistical Review http://www.bp.com/productlanding.do?categoryId=6848&contentId=7033471
 SOURCE: Sustainable Development Commission (2006) SDC Position Paper: The Role of Nuclear Power in a Low Carbon Economy, SDC, London, p.11.
 SOURCE: Sustainable Development Commission (2006) SDC Position Paper: The Role of Nuclear Power in a Low Carbon Economy, SDC, London, p.10.
 SOURCE: Greenhouse Gas Inventories for England , Scotland , Wales and Northern Ireland; AEA Energy & Environment
 SOURCE: Sustainable Development Commission (2006) SDC Position Paper: The Role of Nuclear Power in a Low Carbon Economy, SDC, London, p.7.
 SOURCE: International Panel on Climate Change (2005) Carbon Dioxide Capture and Storage - Summary for Policymakers, p.3.
 SOURCE: Sustainable Development Commission (2006) SDC Position Paper: The Role of Nuclear Power in a Low Carbon Economy, SDC, London, p.16.
 SOURCE: http://nuclearpower2007.direct.gov.uk/docs/Events_070908_TalkingEnergyFinalEndOfDayReport.pdf
 SOURCE: Sustainable Development Commission (2006) SDC Position Paper: The Role of Nuclear Power in a Low Carbon Economy, SDC, London, p.9.
 SOURCE: Nuclear Decommissioning Agency Strategy 2006.
 SOURCE: Sustainable Development Commission (2006) SDC Position Paper: The Role of Nuclear Power in a Low Carbon Economy, SDC, London, p.12.
 SOURCE: http://www.hm-treasury.gov.uk/media/3/2/Summary_of_Conclusions.pdf