December 15, 2010

Mr. Akihiro Ohata
Minister of Economy, Trade and Industry

Petition Concerning Feasibility Study for Construction of Nuclear Power Plant in Viet Nam
~Japanese Government Support for Exports of Nuclear Power Plants~

We are seriously concerned that the Japanese Government's use of public funds for the incautious promotion of exports of nuclear power plants will give rise to large nuclear proliferation and nuclear safety risks, that it could cause huge social and environmental impacts on local communities where nuclear power plants are constructed, and that Japan's taxes will be used for the profit of a limited number of companies. These concerns are the basis of this petition.

I. Background
At the moment the Japanese Government is providing official support in all sorts of ways, including top-level diplomacy, technical cooperation and feasibility studies, in order to achieve exports of nuclear power plants by Japanese companies to countries including the United States, Viet Nam, Thailand, Kazakhstan and Jordan.

For example, at the end of October this year, at a meeting between the Prime Ministers of Japan and Viet Nam, it was announced that the Vietnamese Government had decided to choose Japan as its cooperation partner for building two reactors.1 The agreement included conducting feasibility studies with Japanese funds and low-interest loans for the project.

Meanwhile, last year the Nuclear Energy Policy Planning Division in the Electricity and Gas Industry Department of the Ministry of Economy, Trade and Industry's Agency for Natural Resources and Energy called tenders for a "low carbon electricity generation industry international expansion study project". 2 It selected Japan Atomic Power Company from two bids received during the tender period. According to the Nuclear Energy Policy Planning Division, 1.999 billion yen was awarded for a feasibility study related to Viet Nam's nuclear power plant construction project. Due to delays in Viet Nam's selection of a partner, the study project was carried over to the 2010 fiscal year. However, it appears likely that tenders for the abovementioned "2009 fiscal year low carbon electricity generation industry international expansion study project" were called with the Viet Nam project in mind.

It is envisaged that public finance and insurance for nuclear exports will be provided by Japan Bank for International Cooperation (JBIC) and Nippon Export Investment and Insurance (NEXI). Both these organizations intend to produce guidelines related to review of support for nuclear exports. 3

II. Our perspective
We believe the current policy of promoting nuclear exports is the result of an underestimation of the financial risks, as well as the social and environmental risks associated with nuclear energy in relation to nuclear proliferation, accidents, radioactive waste, worker exposure to radiation and other issues. Furthermore, in view of the many problems experienced with nuclear power plants in Japan, we question the wisdom of using public funds to promote the export of nuclear power plants. Above all, proceeding with nuclear projects in developing countries, which face additional problems in relation to issues such as governance, technical capacity and democratic participatory processes, entails great risks for local communities. In addition, when considering the use of taxes as an "economic measure", we question spending taxpayers' money to promote nuclear exports from which only a very limited number of Japanese companies will profit.

For the above reasons, we believe the Japanese Government's policy of investing extravagant amounts of public money to promote nuclear exports is inappropriate.

Nevertheless, bearing in mind the current situation where nuclear exports are already being promoted, we believe that at the very least, when the Japanese Government provides support for studies related to nuclear exports, or when it provides public credit for nuclear exports it is necessary to ensure adequate transparency and to carefully examine the abovementioned nuclear risks.

III. Demands We demand the following in regard to feasibility studies carried out in relation to the construction of nuclear power plants overseas.

1. Since the Vietnamese feasibility study will be carried out with Japanese taxpayers' money, with the exception of details of bids, the study report should be published in its entirety. 4

2. The topics to be covered in the feasibility study should be decided taking into account the views of stakeholders, including NGOs.

3. The topics of the feasibility study should include consideration of whether or not information disclosure concerning the whole project and consultation with residents will be assured in the decision-making process for construction of the nuclear power plant.

4. The topics of the feasibility study should include consideration of whether or not information disclosure and consultation with residents concerning safety etc. will be assured in relation to operation of the nuclear power plant.

5. The feasibility study should also include an assessment of the risks posed by the project covering the radioactive waste management system, accident response, accident liability, protection of workers from exposure to radiation, safety assurance, as well as other social and environmental risks.

References
1. The October 31, 2010 Japan-Viet Nam Joint Statement contains the following: "The Vietnamese side affirmed that [it] had decided to choose Japan as the cooperation partner for building two reactors at the second nuclear power plant site in Ninh Thuan Province, Viet Nam."
https://www.mofa.go.jp/region/asia-paci/vietnam/joint1010.html

2. "Concerning the result of tenders for 2009 fiscal year low carbon electricity generation industry international expansion study project", Nuclear Energy Policy Planning Division, Electricity and Gas Industry Department, Agency for Natural Resources and Energy, Ministry of Economy, Trade and Industry, October 16, 2009
https://www.enecho.meti.go.jp/info/tender/tenddata/0910/091016c/091016c.htm

3. In regard to the production of nuclear guidelines by JBIC/NEXI, in July 2009 NGOs submitted demands including the following:
>Public Finance and Export Insurance for Nuclear-Related Exports NGOs Demand Rigorous Safety Assessment, Information Disclosure and Stakeholder Involvement

  • Public support should not be provided for nuclear-related projects in regions of tension and regions where terrorism is rife, or for projects in politically unstable countries.

  • Safety standards at least as high as those in Japan should be required.

  • The details and the efficacy of safety plans and management and disposal plans for radioactive waste, including spent nuclear fuel, should be confirmed.

  • Appropriate standards and monitoring systems in regard to worker radiation exposure should be in place.

  • Adequate access to information and stakeholder involvement and consent should be assured

  • Proposals should be reviewed by an independent review committee.

4. The results of feasibility studies funded the Ministry of Economy, Trade and Industry and carried out by the Japan External Trade Organization (JETRO) in support of Japanese companies are, in principle, made public, in accordance with JETRO's environmental and social guidelines. >https://www.jetro.go.jp/disclosure/environment/guideline-e.pdf