Hi. Surely there is some disparity in your analysis here? You simply imply that it is down to the threat of legal challenge that brings about the increased the NSIP documentation quantum between additional Hinckley and Sizewell reactors - but what about the sensitivities of their respective locations? One might be nearer to more sensitive, European protected sites, requiring HRA as well as EIA - you may wince that that is the point of your article, but environmental protection is also hugely important factor for PINS/SoS to consider before sanctioning new NSIP development, but especially nuclear.

Also, their newer reactors may well be being built next to "older reactors", so it's all OK, right? BUT presumably those older reactors could/probably were sanctioned and built BEFORE EIA was a thing in the UK - suggesting a more thorough analysis was needed to gauge the potential impacts of these newer reactors.

You have also negated to mention changes to the EIA regs, around 2016/17, which - then - as derived EU legislation meant more evidence was needed and from "competent experts", to address a wider remit of considerations to whether such development would have a significant effect. Again, from where you sit, you may tut and think - duh!, that's the point, too much red tape! - but from where we stand, these considerations are welcome and force the UK government to take climate and the environment more seriously.

Essentially there are other reasons for expanded paperwork in all this; especially for the types of NSIP you mention i.e. nuclear power stations! - the consequences of ill-judged or underestimated impacts potentially being disastrous for wildlife, nature and local communities...hence why sometimes it's good such decision making takes a while (e.g. Fukushima!).

I understand you want to get things moving, for those businesses where uncertainty and delay is deleterious for their models, BUT the fact remains that EIA/SEA/HRA are (were) key environmental protections to ensure nature, which is not assigned any capital value (when it should) isn't eroded further (NB your article even states the UK is the EU's most nature depleted country!).

Sure, we have the LURB and its new EOR paradigm to replace EIA and SEA, but does anyone REALLY know what it will actually encompass in terms of requirements for developers?; do it's instigators appreciate that specialists will STILL BE NEEEDED to implement/formulate and assess what will still be complicated documents or do they appreciate they will STILL have to account for inevitable project delay that will arise in the courts when/if the government rushes through such monumental system change to replace a tri-partite of well established environmental safeguards left in the UK.

It seems for NSIPS, the destination might be important than the journey, and we if it takes a little longer for good reason (ie environmental protection), then we shouldn't complain too much - especially as most protects are guaranteed (re government's 95% approval rate).

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Enjoyed the article! You might get something out of this post recently out in The TransAtlantic on the political geography of development/anti-development in the British Isles. It's a bit more general and sweeping than your analysis here, but the intention is to publish some empirical work on the basis of this positioning piece, so do consider subscribing for future posts.


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Hi Sam - I am working on this at DLUHC and am very keen to chat. Would you drop me a line at Jenny.preece@levellingup.gov.uk ? Thanks!

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The whole purpose of the DCO and PINS process was to avoid the interminable delays which you highlighted above with T5 for example. It appears that, like everything in Gov, everything tends towards the Blob. Hence Project Speed, the Acceleration Unit etc. which will work for a few years and then need replacing themselves.

Are there other countries who consistently do this better? I'm not sure that many OECD countries are legitimately faster on a consistent basis. It's just that we are more aware of our own country's process.

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An interesting article, but no credit given to the fact that the situation is complex regards development as Government wants growth at all costs and the climatic and ecological emergency are rolling forward. There is an obvious link with many major projects increasing carbon emissions, so the governments low carbon strategy is directly at odds with this opinion. The planning departments are therefore the last line which try to establish sustainable development. If they fail and we continue with our foot solidly on the Gas (and oil) pedal heading for the "wall of limits" we are going to see the crash live and in technicolour.

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The Tory Party, which you have supported for several years, has been in power for nearly 13 years. Why would people listen to you now given the failures of you and the party you've supported and continue to support?

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