Environmental and social issues of site choice for nuclear power plants

Environmental and social issues of site choice for nuclear power plants

Miller B. Spangler

USA legislation now requires appli- cants for construction permits or operating licences to provide information about environmental impacts their activities might have. In this article the author suggests that individual cost-benefit analyses, while an improvement on traditional method- ology, could be more economic by establishing general rules through standardisation of plant design.

Dr Spangler is Chief, Cost-Benefit Analysis Branch, Directorate of Licensing, USAEC, Washington DC, USA

This article is based on a paper presented at the First International Congress on Technology Assessment, The Hague, The Netherlands, May 1973

! Environmental Ouafity, the 3rd Annual Report o f the Council on Environmental Quality (Washington, OC, US Government Printing Office, August 1972), page 354

The US National Environmental Policy Act (NEPA) of 1969 (Public Law 91-190) requires statements to be prepared for major Federal actions having a significant impact on the environment. The utility companies applying for a construction permit or operating licence are required to provide essential information to the US Atomic Energy Commission (AEC) as an aid to the preparation of the environmental impact statements (EIS). These statements include consequences of the licensing decision on the human as well as the natural environment. Important considerations are stated in Section 102(c) o f the NEPA Act: ~

Include in every recommendation or report on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment, a detailed statement by the responsible official on -

(i) The environmental impact of the proposed action, (ii) Any adverse environmental effects which cannot be avoided should

the proposal be implemented, (iii) Alternatives to the proposed action, (iv) The relationship between local short-term uses of man's environment

and the maintenance and enhancement of long-term productivity, and

(v) Any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented.

It is clear that 'man's environment ' includes both natural and man-made features, the latter involving the proposed nuclear facility as well as other man-made facilities or proper ty whose values may be positively or negatively affected by the nuclear plant during its construction or operation. Moreover, the impact of the proposed nuclear development on the natural environment will also affect to some degree social values including recreational, aesthetic, cultural, historical as well as economic and communi ty values. Indeed, an important criterion for deciding how much emphasis should be placed in the EIS on analysing impacts on the natural environment is the degree of significance of such impacts to societal values. Since the human values affected by a nuclear plant may be in conflict with each other or have different levels of significance to different individuals, groups or organisations, a key role (though not the only role) o f government in preparing

18 ENERGY POLICY March 1974


environmental impact statements and recommended actions is that of a referee of different kinds of public interests.

The AEC has issued a Regulatory Guide to aid the utility in its preparation of the environmental report (ER) which must accompany its application for a construction permit or operating licence. 2 In terms of the effects on the human environment (ie, societal or public interests), the Regulatory Guide includes descriptions of desired information of the following kinds:

• need for power and consequences of delay, • relation of the proposed site to regional demography, land and

water use as well as to historic, scenic, cultural and natural landmarks,

• external appearance of the nuclear plant and aesthetics of transmission facilities,

• radiological impact on man and other forms of life, • other environmental disturbances (eg, chemical or thermal

discharges, land disturbances, etc) that affect life-forms of interest to man,

• the irreversible and irretrievable commitment of natural resources and

• other economic and social effects of plant construction and operation including alternative energy sources, sites, and plant designs.

The data thus supplied by the applicant plus that assembled by the AEC staff from published sources and field trips to the proposed nuclear site form the basis for an independent evaluation of the positive and negative impacts on public interests of the recommended action and its alternatives.

In the following sections of this paper a number of methodological problems and issues are discussed in preparing cost-benefit analyses for licensing nuclear power plants.

Inadequacies of traditional cost-benefit analysis The traditional approach to cost-benefit analysis used since the 1930s for decision making regarding public investments in multi-purpose dams and port and harbour developments had the following characteristics:

1. costs and benefits were projected in dollars for the assumed economic life of the proposed development,

2. all dollar estimates were discounted to present worth at a discount rate that usually included a substantial element of subsidy, and

3. the ratio of benefits to costs was computed from the results of steps 1 and 2.

2 Preparation o f Environmental Reports for Nuclear Power Plants, Regulatory Guide 4.2 (Washington, OC 20545, US Atomic Energy Commission, Directorate of Regulatory Standards, March 1973)

When this ratio was greater than unity, the proposed development was regarded as desirable in the public interest, ignoring the inherent subsidy as a hidden cost element. Moreover, options of siting and project scale and design were compared on the basis of such benefit-cost ratios and the option which had the highest ratio was generally regarded most favourably.

The requirements of cost-benefit analysis of nuclear power

ENERGY POLICY March 1974 19


development alternatives departs from this traditional approach in the following important respects:

1. All important elements of public subsidy must be accounted for by using realistic discount factors.

2. Social as well as economic or dollar costs must be included. 3. Computing benefit-cost ratios is no longer a feasible approach

since not all social and economic impacts relating to different kinds of public interests can be quantified - or at least not in commensurable (dollar) units.

4. Uncertain or probabilistic consequences having potentially important social and economic impacts are not to be neglected s in contrast to the traditional approach which only included costs and benefits that were deemed certain of realisation.

5. The new approach deals with who bears the costs and who reaps the benefits, reflecting a concern for social justice in attempting to achieve a more equitable distribution of costs and benefits in public decision making (a glaring omission of the traditional approach).

6. The new approach is vastly more complex involving a multidisciplinary analysis of technological, social, economic, cultural, legal, political and environmental factors.

The new approach to cost-benefit analysis in preparing environmental impact statements involves a number of problems and issues: (a) measuring of social and economic values not determined in the market place; (b) deciding which parties or interest groups are sufficiently affected to merit analysis of their interest and how to organise the analysis by political jurisdictions and other interest groups, (c) treating risk and uncertainty, and (d) deciding on scope and limitations of analytical effort.

3 This is especially true of assessing the l ikely impacts on human and animal life of radioactive emissions or numerous other probabil istic hazards to the natural or man-made environments resulting f rom the proposed development.

4 Preparation o f Environmental Reports for Nuclear Power Plants, op cit, page 33-66

The measurement of values In the AEC Regulatory Guide a number of requests are made of the applicant for information to assess social and economic impacts of the proposed nuclear facility or its alternatives which pose difficult problems of measurement or estimation. 4 Despite the hundreds of thousands of dollars often expended by the applicant in preparing his environmental report, there still remain numerous deficiencies of the sort of information required to achieve the objectives of the NEPA Act.

One such problem is estimating the value of electricity generated by a nuclear or other facility. It is of course impossible to trace the flow of electrons delivered over transmission and distribution lines connecting a newly installed plant with its consumers. Not only is this a problem because the proposed facility will become only one part of an interconnected power generating and distribution system operated by the utility, but also this system is interconnected in a power pool with neighbouring utilities or power distributors. An approximate solution to this difficulty is to assume that transmission and distribution losses of power generated by a new facility in delivering energy to consumers is proportionately the same as that experienced for the utility's system as a whole. If the quantity of


s Paul A. Samuelson, Economics: An In t roductory Analysis (New York, McGraw-Hill Book Company, Inc, 1961), page 446


electricity thus estimated to be delivered to consumers is multiplied by the respective prices paid by different classes of consumers, then a measure of the market value of electricity can be established.

However, the latter represents only a partial - and most likely, l e sse r - fraction of the total value of electricity to society. As noted by Adam Smith, the value of certain resources such as air and water is great in its importance to the general welfare but their value as determined in the market place may be relatively small or even negligible. The difference between total social utility and total market value is called consumer's surplus, s According to economic theory, market price equates supply with demand in such a way that it is the marginal consumer who is instrumental among consumers in determining the price of goods or services. At a price higher than equilibrium market price, the marginal consumer refuses to buy and it is this market resistance that keeps market prices from rising, given stability on the supply side. However, all consumers but the marginal ones receive a measure of surplus value which is the difference between the market price and the price the consumer would be willing to pay rather than to do without the commodity. This of course will vary with individuals in accordance with the level of their income and their preferences for different kinds of goods and services.

With regard to electricity, which is a highly divisible and generally highly valued commodity by practically all individuals, it is the marginal uses of the marginal consumer that are instrumental in determining market price. In other words, the marginal consumer receives surplus value for some uses of electricity but not for those uses (or portions thereof) whose purchase he would forego rather than pay a higher price for. The problem of estimating the total value of electricity as the sum of market value and consumer's surplus is somewhat complicated by the fact that market rates are established by public utility commissions on the basis of costs of the utility's total system and not those of the more recent additions to capacity which would enter more forcefully into pricing decisions under free market conditions. Since the various uses of electricity enter so importantly into the quality of living and are generally such a small fraction of the investment or consumer goods whose functioning they enable, it is safe to assume that the surplus value of electricity for society is at least several times greater than the market value of electricity.

The principal quality of electricity is its reliability and it is abundantly evident that the truest appreciation of the value of consumer's surplus would be registered whenever brownouts or blackouts might occur. It is not difficult to imagine that some very high prices for electricity might be elicited were it possible to bargain with consumers individually at a time of energy failure: factories, hospitals, passengers on trains and elevators, persons uncomfortable in homes or offices that are served by air conditioning in the summer or electric heating in winter, the housewife cooking a meal, the student cramming for an exam, or persons cringing with fear in darkened streets or homes; not to mention the loss of other conveniences and entertainments of



6 This argument is cast m somewhat emotional tones precisely becaus~ emotion is an element of personal~values of interest to social action.

appliances run by electricity. 6 Thus an important part of cost-benefit analysis in nuclear power plant licensing is the qualitative appraisal of consumer's surplus which in turn focuses attention on the impact of the proposed facility on the over-all reliability of the applicant's system were the plant built or not built, or delayed.

There are other social and economic benefits of proposed nuclear power facilities which pose problems of measurement or estimation. Included are:

1. Temporary and permanent new jobs created and the payroll for these.

2. Incremental increase in regional product (value-added concept).

3. Enhancement of recreational values through making available for public use any parks, artificially created cooling lakes, marinas, etc.

4. Enhancement of aesthetic values through any special design measures as applied to structures, artificial lakes or canals, parks, etc.

5. Environmental enhancement in support of the propagation or protection of wildlife and the improvement of wildlife habitats.

6. Creation and improvement of local roads, waterways, or other transportation facilities.

7. Increased knowledge of the environment as a consequence of ecological research and environmental monitoring activities associated with plant operation, and technological improve- ments from the applicant's research programme.

8. Creation of a source of heated discharge which may be used for beneficial purposes (eg, in aquaculture, in improving commercial and sport fishing, and other water sports).

9. Provision of public education facilities (eg, a visitors' centre). 10. Avoidance of harmful impacts on society of air pollution were

oil or coal-fired generating facilities to be built instead of nuclear.

11. Unfavourable impacts on the US balance of payments position and related national security interests through increased imports of crude oil or petroleum products were oil-fired units to be built rather than nuclear.*

It is noted that estimating such a value places a great deal of importance on the reliability of the average price estimate for the 30-year life of the plant which will hinge upon such factors as future discoveries of domestic or foreign oil, distances of shipment, growth rates in the world consumption of oil, technological change in reducing the cost of future oil supplies or reducing demand for oil, and political developments at home and abroad that regulate the oil industry including oil imports, taxes, exploration and production incentives, etc.

Moreover, there is considerable difficulty in estimating the impact of the increased value of oil imports on the US balance of payments position since some fraction of the dollar earnings of countries exporting oil to the USA will directly or indirectly result in increased purchases from that country. This would contribute

* It is estimated that fou, nuclear units totalling 4964 megawatts of net capacity recently proposed for construction on a single site by a uti l i ty company would save petroleum imports of roughly 1"6 thousand million barrels for a 30-year plant life required by oil-fired plants were these to be substituted for the nuclear units. I f one assumes that the cost of these imports would average $5-00 per barrel of low- sulphur residual oil, then the total value of these imports would be approximately $7"9 thousand million dollars.


Environmental and social issues o f site choice for nuclear power plants

to some increase in foreign exchange earnings by the USA of an amount which cannot be very accurately determined because of time lags and the triangular nature of world trade patterns. According to estimates of the Cabinet Task Force on Oil Import Control, one might infer that the net adverse impact on the US balance of payments would be roughly 50% of the projected gross increase in the value of oil imports. 7 However, a great deal depends on which countries supply the oil since countries have widely differing propensities for purchasing US goods with dollars earned and propensities for individual countries may decline were dollar earnings to reach high levels.

Among the different kinds of costs posing the most difficult problems of evaluation stemming from nuclear power plant construction and operation are:

• impairment of recreational values, • impairment of aesthetic values, • impairment of natural conservation values, • plant decommissioning costs, • spent fuel disposition costs, • losses of property values, • risks to public health and safety, • loss of certain kinds of regional income, and • a host of temporary stresses on community identity and

cohesion or the overloading of public services and social overhead facilities during the period of plant construction.

There is a growing body of literature on social indicators which, while not directly measuring the social values affected, provide some indication or scaling of the importance of social values. Some of these values are undergoing a state of flux which adds to the difficulty of their quantification. Generally, the amount of narrative required to analyse socio-economic values is inversely proportional to the susceptibility of the values to direct measurement.

It is suggested by Rescher that the 'whole structure of value rests ultimately on what is beneficial to man. '8 Some costs are a means of achieving benefits and still other costs represent the thwarting or constraint of certain beneficial values. The intangible nature of most human values is complicated by their interrelation- ship. Thus the problem is not one of merely assessing values in isolation of each other but in terms of their causal support or contradiction.

7 Cabinet Task Force on Oil Import Control, The Oil Impor t Question: A Report on the Relationship o f Oil Imports to the National Security, (Washington, E)C, US Government Printing Office, Feb- ruary 1970), page 43

8 Nicholas Rescher, Introduct ion to Value Theory, (Englewood Cliffs, N J, Prentice- Hall, Inc, 1969), page 133

9 Charles J. Hitch and Roland N. McKean, The Economics o f Defense in the Nuclear Age, (Cambridge, Harvard University Press, 1960), page 165

The organisation and significance of values In commenting on the types of consequences of an action (ie, positive gains or benefits and negative effects or costs), Hitch and McKean have observed:

Neither type by itself can serve as an adequate criterion: the maximising of gains without regard to cost or resource limitation is hardly a helpful test, and the minimising of cost regardless of other consequences of the alternative actions is nonsense?

While both benefits and costs must be accommodated in the over-all criteria, it is clear that in a major developmental action


Environmental and social issues o f site choice for nuclear power plants

(such as the construction and operation of a nuclear power plant) benefits and costs will fall on certain individuals or public interest groups quite differently. An important question becomes: who are the 'winners' and who are the 'losers' in a selection of alternatives for generating electricity: the choice of fuels, sites, plant designs. For example, the selection of the type of cooling system is particularly important for nuclear power plants, which although superior to fossil-fuelled plants regarding air pollution, generate about 40% more waste heat to the condenser water per kilowatt hour of electricity than fossil-fuelled plants and hence the choice of cooling systems for nuclear plants if of key importance.* Nor is it a realistic possibility to make choices of these kinds so that everyone is better off and no one is worse off. The best that can be done is to make trade-offs between costs and benefits so as to improve the equity of the decision without sacrificing unduly the interests of the majority of the affected parties.

A public hearing process follows the issue of a final environment statement prepared by the AEC in support of a licensing recommendat ion and permits various affected parties to state their views and raise questions about the objectivity and completeness of the environmental statement. The views of the majority of the persons affected beneficially by the proposed action are rarely represented very adequately, if at all, at these hearings. It is seldom easy to determine what the views of the majority might be with any degree of accuracy. According to Bowman and Bach:

The problem of ascertaining the ends, or goals, of social policy is a very complex one. How, in a democratic society, can the attitudes of the majority of people be discovered? It is not enough to take a poll of opinions. Many attitudes are only half-conscious, and most people are only partially articulate. And apparently subtle variations in attitudes are sometimes very significant in revealing underlying differences. Moreover, human beings are neither consistent nor fully informed. Each individual has ideas which are mutually incompatible. Conflicts will be even greater between different individuals? 0

10 Mary Jean Bowman and George Leland Bach, Economic Analysis and Public Policy (New York, Prentice-Hall, Inc, 1943), page 140

* This refers to the light water reactors which are the type at present most widely used; it is not true of all types of reactor.

One method of dealing with public values is to organise the analysis by interest groups in order to determine the gains and costs for each group. For example, it is advantageous to organise interest groups in accordance with the political jurisdictions principally affected by the proposed nuclear power facility. In this respect a balancing analysis of the costs and benefits affecting the citizenry as a whole is desirable for: (1) the county in which the plant is to be built, (2) adjacent urban areas, (3) the state in which the plant is to be built, and (4) the nation. If it can be demonstrated that, on balance, all such political judicatures affected by the proposed developmental action will receive benefits in excess of costs, a most useful perspective is established by which to gauge the conflicting interests of other identifiable groups.

Still another appropriate organisation of desirable and undesirable impacts of the alternatives being evaluated is from the standpoint of the affected social or economic activities:


11 Environmental Ouafity, op cit, page 353


• the consumers of electricity in the general service area of the utility or neighbouring areas for which significant exports of power are projected if the nuclear plant is built,

• the utility's stockholders, • fishermen and other recreationists, • commercial fishermen, • nature preservationists, • tourists and owners of related businesses, • residents or workers displaced by conversion of original land

uses of the site to the proposed use, • residents who live within the range of adverse noise, aesthetic,

and safety or health impacts of the proposed facility, • farmers adjacent to the site whose agricultural productivity is

affected, and • water resource users vulnerable to any adverse impacts on the

quality or available supply of ground or surface waters.

Parties of these kinds who share in common certain harmful impacts of ten have a tendency to unite in their opposition to the proposed development. To the extent that some of the above categories of interest groups would be principally located in the county in which the plant is to be built, the balancing analysis of costs and benefits tends to be less complex or difficult for other political jurisdictions.

A cost-benefit analysis must also take account of present and future generations of interest groups, as stated by Section 101 (a) of the NEPA Act: ~ 1

. . . it is the continuing policy of the Federal Government, in cooperation with State and local governments, and other concerned public and private organizations, to use all practicable means and measures, including financial and technical assistance, in a manner calculated to foster and promote the general welfare, to create and maintain conditions under which man and nature can exist in productive harmony, and fulfill the social, economic, and other requirements of present and future generations of Americans.

Moreover, the concern for achieving a more equitable distribution o f costs and benefits between present and future generations is implicit in Section 102(c) previously quoted that requires analysis of the relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term productivity as well as the evaluation of irreversible and irretrievable commitments of resources involved in the proposed action. There is a real danger in actions involving political processes that the interests of future generations may get unfairly compromised by the interests of present generations. It is seldom made sufficiently clear to the present generation of voters just how the interests of their progeny would be affected (ie, favourably or unfavourably) by the proposed nuclear development. The difficulties inherent in treating long-range uncertainties of this kind are discussed in the following section.

It would appear desirable to organise these three classes of interest groups in an impact evaluation matrix. The category headings of the trimatrix would be: (1) socio-economic functions (2) spatial organisation (political jurisdictions), and (3) temporal organisation. The latter might be conveniently divided into the



period of construction (usually 5 to 7 years), the period of operation (divided by decades up to the projected plant life of 30-40 years), and the post-operative period. Of concern to the post-operative period is the planned re-use of the land for a new plant or other social needs; disposal of spent fuel; and the irreversible loss of resources, especially non-renewable natural resources. Each cell of the matrix would be accorded an evaluation of costs and benefits. Since many of these consequences are not quantifiable in commensurable units, the matrix is not intended for use in mathematical or algorithmic manipulation of evalu- ations. Rather its purpose is to serve as a mapping device to ensure an exhaustive search for all cost-benefit impacts and their interrelationships that are significant to the public interest.

The criterion of significance to the public interest permits such a matrix to be used as a preliminary device for cost-benefit analysis. The scope of the analysis would include all cells of the matrix except those for which the consequences of the proposed action are deemed insignificant. For it seems clear that if the NEPA Act permits Federal agencies to omit a detailed statement on major Federal actions not significantly affecting the quality of the human environment (see Sec. 102(c) above), then by the same token it would appear reasonable to exclude from any detailed statements required under these terms those impacts deemed to be insignificant.

In practice, it is sometimes difficult to apply this significance test in preparing a cost-benefit analysis of a proposed action. How is one to conclude some impact is unimportant? By intuition of the analyst without benefit of preliminary analysis or fact finding? By the statements of others? Before concluding that some potential impact is unimportant, it is essential to ask: 'Important to whom?' If the potentially affected persons are small in number it may be tempting to dismiss these interests as relatively unimportant. Yet the displacement of 20 to 30 farm families from a site in a sparsely populated county can place a serious stress on a rural community. Can this be called an insignificant impact? On the other hand, the unavoidable displacement of three or four families using the most favourable plant design and site options might be deemed insignificant.

At wlaat point does one draw a line of demarcation in observing that an impact is relatively insignificant and can be neglected in further analysis and reporting? A basic consideration in this respect is that the trade-offs may be slightly higher costs for a large number of consumers of electricity were a different action taken to moderate intense impacts on a rather small number of residents, recreationists, workers, or businessmen. Moreover, there may be differences of opinion over the importance or insignificance of certain impacts such as safety and health for which little tangible evidence exists and whose risks cannot be quantified using standard procedures. A rule of thumb would seem to be that whenever the presumed insignificance of an impact of the proposed development is seriously challenged by potentially affected parties, then it would be desirable for the analyst to cite opposing views and to give the basis for believing the impacts to be negligible, if he does.


12 Natural Resources Defense Council v. Morton, 458 2d 837, 838 (CADC, 1972). This passage was cited in the Federa/ Register, Vol. 37, No. 248, Dec 23, 1972, page 28413


The treatment of uncertainty Another problem of assessing the consequences of technological applications is the tendency to dismiss those impacts which are uncertain or speculative in nature. Peculiarly, this tendency is not uniform for different kinds of impacts. For example, there is no inclination to dismiss public health and safety impacts because of their speculative nature. Likewise certain thermal plume and ecological predictions are of a highly uncertain nature, yet included in detailed environmental statements. On the other hand, there is a noticeable tendency to dismiss the probable outcome of R & D efforts that might have a favourable impact on the flow of costs and benefits of a proposed nuclear facility over its life. Examples might be:

• the development of desalination or other technologies that would utilise waste heat presently discharged to the environment, thus creating economic values while reducing adverse socio-economic effects of ecological impairments of thermal discharges,

• aquaculture research that would make beneficial use of thermal discharges of once-through cooling systems,

• the development of new technologies that could substantially reduce impingement or entrainment losses of once-through cooling systems,

• technological advances that would reduce radioactive emissions or the risk of emergency core cooling systems (ECCS) failure,

• new technologies of reprocessing nuclear fuels or disposing of spent fuels,

• technology advances to reduce plant decommissioning costs, • improved corrosion inhibitors or algicides that would reduce

operating costs or be less injurious to social uses of water- courses, and

• new technologies to increase the supply or reduce the cost of uranium fuel.

Indeed, there is a large number of potential advances in science and technology that are generally excluded from nuclear power plant cost-benefit analyses principally because of their speculative nature.

In addressing the responsibility of an agency for consideration of environmental effects of reasonable alternatives the Federal Power Commission has noted that in a recent Court decision 'crystal ball' inquiry is not required, citing the following passage of that decision:

NEPA was not meant to require detailed discussion of the environmental effects of 'alternatives' put forth in comments when these effects cannot be readily ascertained and the alternatives are deemed only remote and speculative possibilities.' 2

Yet, there is a serious question whether technological forecasting should be excluded from environmental impact statements of the socio-economic effects of nuclear power plant siting merely because of their speculative or uncertain nature. Rather, it seems highly probable that at least some significant fraction of the potential technological developments of the above kinds will be realised to affect in a favourable way the flow of costs and


Environmental and social issues of site

13 Envi ronmenta l Quality, op cit, page 242

choice for nuclear power plants

benefits from a proposed nuclear plant long before its expiry date (30-40 years). It is easy to overlook that the joint criteria cited above included remote as well as speculative possibilities. 'Remote' could be interpreted as either far o f f in realisation or of low probability. Since the NEPA Act requires analysis of the interests of future generations, it is clear that the life expectancy of the next single generation will lead the analyst to consider a period as long as 60 to 80 years. If generations is viewed in the plural sense as stated in the Act, then a forecasting horizon of 80 to 100 years into the future would appear sanctioned by the Act. Thus, the interpretation of 'remote' from the standpoint of the NEPA Act should be events of low probability rather than distant in time.

Clearly, technological advances that will reduce the consumption of non-renewable resources and environmental degradation ought to be a cornerstone of national policy in mitigating for future generations dire consequences of a continuing use of present technologies. And it would seem that technological forecasts which would serve such objectives ought not to be ruled out of environmental statements merely because of their speculative nature. On the other hand, their inclusion might appropriately be limited to those developments for which R & D funds have already been committed and accompanied by a brief discussion of the uncertainty of outlook for positive results of the R & D within the time frame of interest to the cost-benefit assessment. It would appear that such an approach would serve to meet the 'remoteness' criterion cited above in the Morton case since R & D projects with remote possibilities for successful results generally have difficulty being funded.

Indeed, the Third Annual Report o f the Council on Environ- mental Quality cites a court decision (Environmental Defense Fund versus Corps of Engineers) that an impact statement must discuss 'all known possible environmental consequences of proposed agency action. '~ a The Council's stressing of the word 'possible' can be interpreted to mean that certainty of impact is not required. Hence it would appear that in an impact statement it may be proper to consider a speculative evaluation of the probability of the consequence and its magnitude.

Aside from technological uncertainties there are those arising from the difficulties of reliably forecasting institutional decisions or changing social values that may have relevance to the magnitude of beneficial or harmful consequences of the proposed nuclear development. Especially troublesome in this respect are public attitudes toward aesthetic, recreational and health and safety values. These are likely to be sensitised during periods of public controversy and possibly exaggerated. With the passage of time certain psychic costs such as these may iron out. That is to say, parties who for personal safety reasons initially feared living near a nuclear plant may lose these fears after a number of years without a nuclear accident. The opposite might also happen should safety problems arise during the operation of a plant. Persons who initially objected to the aesthetic impact of tall cooling towers and their vaporous plumes may in due course find them less objectionable, while others not initially aware of the vaporous plumes or enormity of the towers may come to develop



more antagonistic feelings about them with the passage of time. Persons who feared a loss of property values because of proximity to a proposed nuclear plant may assuage their objections when it becomes clear such losses are not materialising.

In this respect, it can be expected that some intervenors objecting to a proposed facility for a single reason may nonetheless raise a host of other objections of known concern to diverse parties on this or similar actions as a matter of tactics, though they themselves may have no significant feelings on all of these subjects. The scaling of present values of these kinds or forecasting their change over the period of construction and plant operation is a baffling problem of social psychology. Accordingly, it is essential that the cost-benefit analyst take a cautious position against drawing any hard and fast conclusions concerning a specific case, drawing instead on generic experience with related historical cases of these or other kinds.

14 Environmental QuafiW, op cit, page 354

The problem of limiting effort A major problem of evaluating the desirable and undesirable consequences to the public interest of different alternatives in nuclear power plant siting and plant design, is the large number of elements to be assessed and the complexity of their interrelationships. These are so great that it is impracticable to have sufficient human and financial resources to perform all of the analyses that seem worthwhile. To deal with these complexities, Section 102(A) of the NEPA Act requires that all agencies of Federal Government 'shall utilize a systematic, interdisciplinary approach which will ensure the integrated use of the natural and social sciences and the environmental design arts in planning and in decision-making which may have an impact on man's environment. '~ 4

In implementing this interdisciplinary approach the applicant for a construction permit for a nuclear power plant may spend up to half a million dollars or more in gathering data for the environmental report which it submits to the AEC as part of its application. The AEC and its contractors may spend several hundred thousand dollars more in gathering additional information and preparing the analyses and recommendations con- tained in the environmental impact statement, not to mention follow-up effort in the public hearing process and its aftermath. To gather and analyse even more information would not only threaten the desirable objective of reducing this cost but might also lengthen the calendar time to render a licensing decision thus risking costs of delay in plant construction.

By considering too large a scope of analysis relative to the level of effort permitted in the budgetary allocation for AEC licensing staff, ,,there is an induced potential for some of the topics to receNe relatively shallow treatment. This kind of problem in preparing environmental statements is recognised by the Council on Environmental Quality and a limitation of scope is suggested to overcome this difficulty:

However, a program statement would not satisfy section 102(2)(C) if it were superficial or limited to generalities. The very rationale for a program statement requires that environmental considerations be analyzed fully. When



all significant issues cannot be treated adequately in connection with the program as a whole, statement of more limited scope will be necessary on some or all individual actions to complete the analysis. 1 s

l 5 /b id , page 234

16 /b id, page 242

17 /bid, page 244

18 /b id, page 244

19 Ib id

Even so, early Court decisions relating to Section 102(c) of the NEPA Act have ruled that this section of the Act together with Section 6 of the Council's guidelines are intended to bring 'full disclosure' of the environmental implications of an impending decision, stressing the need to fully inform the public, the President, and the Congress on the issues. 16 This includes the duty to discuss opposing views under NEPA.I 7 The dilemma of limiting the scope of analysis to preclude shallowness of treatment and the need to fully inform interested parties requires the agency preparing an environmental impact statement to exercise sound but difficult judgment.

In preparing its environmental impact statements on licensing actions for nuclear power plants, the AEC has given priority of effort to analysing the consequences for the public interest of the facility and site as proposed and has placed less emphasis on analysing the consequences of alternatives for which only sketchy information is available.

Likewise greater emphasis has been placed on analysing direct or primary impacts on society and much less on indirect or secondary impacts of the proposed facility or its alternatives. Secondary and higher order impacts generally are more speculative in nature and often are influenced by causal factors that may be far more important to the impact in question than the proposed plant construction and operation. An example of this is the stimulating impact of nuclear power generation on industrial development of the county in which the plant is proposed and the general service area of the utility. Since the cost of electricity represents only 1 or 2% of the factor costs of most manufacturing industries and the proposed electrical generating facility will only marginally affect these costs, other factors will tend to dominate the decision of existing firms to expand their production or new firms to establish manufacturing facilities in these areas.

The sizeable task of assembling data and preparing analyses of the legion of conceivable alternatives suggests that if a cost-benefit analysis were to be performed of the enhanced social value of substantially enlarging the scope of analysis it may reveal that the costs are too large to justify the increased effort. That is to say, cost-benefit analysis must also be cost-benefited.

The Courts, too, have recognised a rule of reasonableness in preparing environmental impact statements. In the case of Natural Resources Defense Council versus Morton, the court stressed that it was not asking the impossible in a discussion of alternatives but rather that a 'rule of reason is implicit in this aspect of the law, as it is in the requirement that the agency provide a statement concerning the opposing views that are responsible. '18 In further elaborating on the rule of reasonableness, the court went on to say that the agency will have taken the 'hard look' demanded by NEPA if it has discussed the reasonably foreseeable impacts with a thoroughness commensurate with their severity and the significance of the action.19



From this it seems clear that priority should principally be directed to limiting the scope of analysis to those consequences of the proposed action that have greatest impact on the public interest and particularly to those issues wherein opposing views are known to exist - in other words, criteria such as the importance and controversiality of the societal impacts of the proposed development.

It is inappropriate, of course, to consider too narrow a scope in preparing environmental statements. One such failing would be to stress adverse impacts on the natural environment giving insuffi- cient attention to impacts on other public interests. In this regard the Council on Environmental Quality points out that 'agencies have public values to consider other than just the environment. Balancing them against environmental values is inherent in the duty imposed by NEPA. '20

For example, in the case of Natural Resources Defense Council versus Morton, the court observed that 'the consideration of pertinent alternatives requires a weighing of numerous matters, such as economics, foreign relations, (and) national security. '21

Another problem of a too narrow interpretation of scope is the disinclination to deal with alternatives outside the authority of the agency. This matter was commented on by the court decision on the Morton case: 'Even if s o m e . . , alternatives are outside the authority of the agency preparing the statement, their discussion will inform the public on the issues and guide the future choices of the ultimate decision makers in the Federal Government - - the President and the Congress. '22

2O /b id 21 /bid, page 245 22 Ibid, page 244

23 /bid, page 354

The need for generic research It is obvious from the above discussion that methodological difficulties arise in assessing the societal impacts of nuclear power plant developments because of the need to deal with a complexity of alternatives and impacts whose uncertainty spans the 30-40 year life of the plant and even beyond for certain of the consequences. In this regard, advances in planning and forecasting methodologies could prove helpful in improving the quality and responsiveness of environmental impact statements to public interests. Matrix methods of organising the evaluation of public interests by political jurisdiction, functional type, and future periods of time need to be developed and made operational. Much more research needs to be performed on social indicators and the scaling of social values, particularly the factors that cause these to change over time including the role of information in influencing values or attitudes.

The NEPA Act in Section 102(B) requires all Federal agencies to identify and develop methods and procedures in consultation with the Council on Environmental Quality which will ensure that presently unquantified environmental amenities and values may be given appropriate consideration in decision making along with economic and technical considerations. 2a The use of the word 'amenities' suggests such attributes of the natural and man-made environment as aesthetic, recreational, cultural and historical. The wide differences in personal appreciation of these values makes



24 /bid, pages 229-230

2s Ibid, page 230

their evaluation especially difficult and research on how this might be effectively accomplished would be of considerable aid to the preparation of environmental impact statements on nuclear power plant licensing actions.

Economy of effort and improved quality of such environmental statements could be achieved through the performance of generic research studies. Some insight of the kind produced by these studies is developed through case-by-case analyses and the AEC is proceeding with topical research on generic issues both in-house and through contracted efforts. It seems evident that such research whether performed by a concerted study effort or through an accumulation of insights from case-by-case analyses can aid in expanding the scope of factors considered in the environmental analyses without a substantial increase in costs. It is noted by the Council on Environmental Quality that despite the stress in the Calvert Cliffs' decision on an individualised balancing analysis of nuclear power plant impacts, the opinion does not say that an agency cannot turn to its own general rules to guide all or part of individual decisions. 2 4 NEPA does not dictate that the balancing of all competing factors be done entirely anew in each decision, without the assistance of general rules and past experience. 2 s

The development of revised standard formats of information to be supplied by the applicant for a nuclear power plant licence plus a standard review plan for the use of this and other information in preparing environmental impact statements by the AEC will be valuable steps in achieving greater economy and quality of analyses. Standardisation of nuclear plant designs, such as the proposed concept of offshore barge-mounted nuclear plants will also be of considerable aid in expediting licensing applications while reducing costs and delays through bringing economies of scale to the preparation of environmental impact statements. The latter is possible because of the repetitive nature of trade-off analyses involving impacts of standardised design features in combination with site characteristics falling within a 'standard design envelope.' The criteria of these siting characteristics are still to be worked out and the concept merits extension of application to onshore facilities as well.


Documents

Environmental and social issues of site choice for nuclear power plants