To
The Secretary
Department of Atomic Energy, New Delhi

Dr. Jitendra Singh
MOS, PMO, New Delhi
Honorable Prime Minister
Govt. of India, New Delhi


Dear Sirs,

Greetings from Sagar, Western Ghats, Karnataka.

May I draw your kind attention to the latest French Auditor’s report, as in the news links below, and submit that the same deserves a lot more closer attention than our authorities have been giving to many such credible reports from around the world on the overall approach needed in the case of nuclear energy; particularly for India.  Among other things mentioned in this audit report few highlights of importance from India’s perspective are: 
“The construction of new EPRs in France cannot in any event be envisaged without clear prior answers on the methods of financing and the role of nuclear power production in the electricity mix of tomorrow.”    

The report says the 3.3 times increase in the construction cost, estimated by EDF at EUR12.4 billion (2015 value), and by at least 3.5 times the commissioning time for the Flamanville EPR compared to initial forecasts, “constitutes a considerable drift”.  It says this is the result of “unrealistic initial estimates, poor organisation of the project by EDF, a lack of vigilance on the part of the supervisory authorities and a lack of awareness of the loss of technical competence of industrialists in the sector”.   

The report says EDF is no longer in a position to finance the construction of new reactors on its own. The utility, it says, is studying means of financing that either makes the consumer – as in the case of the UK’s contract-for-difference for construction of Hinkley Point C – or the taxpayer bear the costs of construction.

“The financial challenges are major, with the cost of construction of three pairs of EPR2 reactors being estimated at EUR46 billion (2018 value),” the Cour des Comptes notes. “Taking into account their duration of construction, production and dismantling, the decision to build or not to build future EPRs will have consequences until the 22nd Century.”  
———————————————————————————French auditor calls for financing guarantee for future EPR projects
https://world-nuclear-news.org/Articles/French-auditor-calls-for-financing-guarantee-for-f

The EPR sector
https://www.ccomptes.fr/fr/publications/la-filiere-epr
—————————————————————————————————-
In view of such clear audit recommendations, will EPRs from France, as being proposed for Jaitapur, Maharastra can even deemed to be remotely acceptable to our country?

Whereas the unacceptable consequences to India of the uncertainties, enormous economic, social and health costs associated with EPRs have been made clear by this report, such consequences to India with even other types of nuclear reactor technologies, including the indigenous types such as PHWRs, cannot be any thing much less.  As detailed in an elaborate representation sent to the Honorable Prime Minister through an email on 12th Sept. 2019 in the context of societal concerns over the Environmental Clearance (EC) accorded for the expansion of Kaiga Nuclear Power Project, Karnataka, there are many unacceptable and non-essential risks, costs and uncertainties associated with even the indigenous nuclear power technology.  The PDF version of the above mentioned representation to PM is as enclosed for quick reference.

It should be a matter of great concern that none of the concerns raised in this representation have been addressed by any of the concerned authorities, which may clearly indicate that they have no satisfactory answer to these concerns. In a welfare oriented governance such a practice of burdening the society with such risky & costly technologies without due diligence and without taking the civil society into confidence is deeply reprehensible, and hence does not augur well for the country.

In view of such mounting evidences from around the world against the techno-economic feasibility of the nuclear power technology itself, as compared to many other benign and much attractive options to meet the growing demand for electricity in India, it will not be an exaggeration to state that the interest of our country will not be served in anyway by continuing to pour the meager resources available for the country into nuclear power generation schemes, at a time when very many other sectors of our economy such as poverty alleviation, health, education, basic infrastructure, environment etc. are suffering due to lack of financial support. 
 
It is very unfortunate that even India’s CAG does not seem to be interested in undertaking such diligent auditing of the nuclear power projects, which are of huge capital cost itself.

Instead of locking our communities into humongous costs and risks of nuclear power technology for next few generations, it is critical that we utilise such meager resources to make the distributed type of renewable energy resources widely popular, through which all the concerns associated with  nuclear power technology can be addressed.
In this context, once again I request that every one of the activities associated with the approved, ongoing and planned nuclear power projects in the country be paused, and thoroughly reviewed keeping in objective view the attractiveness of other power generation technologies available to India and the overall relevance of nuclear power for India not only at present but also in future.  Effective participation of the interested civil society groups/individuals in such an important policy matter will be critical for the long term welfare of the country.

Regards
Shankar Sharma
Power Policy Analyst
Anugraha, 5th Cross, 80 ft Road
Vijayanagar 1st stage, Sagara, Karnataka – 577 401
Phone: ++ 91 94482 72503
shankar.sharma2005@gmail.com
shankar.sharma2005@hotmail.com