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).
Why especially nuclear? Less than 3,000 people have died as a result of commercial nuclear, and this includes Chernobyl, which was primarily a nuclear weapons materials facility (most likely tritium), which the KGB were informed was extremely hazardous, yet chose to disregard the warning because of its vital role in Soviet nuclear arms manufacture (Reuters). At the same time, now that the Japanese have realised they massively overreacted with hysteria to the Fukushima incident, from which only one person ever died from radiation (which is also heavily disputed), they are back to building nuclear power plants. The last evacuated town was reopened in 2022.
At the same time, measured analysis has shown that solar doesn't fare well in terms of carbon, compared to other alternatives. Any rational examination of solar PV has to include the cost of recycling through smelting which carries both an economic and carbon cost. Without this process, solar PV ends up in landfill and this poses a genuine risk to human health given that solar PV utilises 300 times as much toxic material because of energy density issues.
My point would be this- the regulatory costs of nuclear are 13 times higher than other nations who have developed commercial nuclear have proven they need to be. Despite the hysteria, commercial nuclear has proven to be one of the safest technologies in history. I am not saying that lessons cannot be learned from Fukushima. One of the key observations is creating designs that are idiot-proof. Not only should the generator which powered the cooling system never have been built where it was, but when the alarm sounded local safety operators didn't raise the flood gates which would have protected the generator from flooding, because they were worried that it would cause a public panic. That being said, Fukushima was commissioned in 1971. It was an old plant. Many of the newer models built successfully in East Asia at low cost and in a timespan averaging six years, are far safer.
It's worth noting that SMR's will render much of this discussion moot. Although only 3 models have been built to date, there are around 80 companies investing serious amounts of capital to make them a reality. Sure, the first models which likely require a launch cost per energy unit around 20% higher than the UK is currently paying for new wind development, but if the cost reduction with time plays out anything like the profile for wind, then it's highly likely that SMR energy will ultimately cost less than half of what we are currently paying for wind.
It's worth noting that SMRs are fundamentally more safe than large-scale nuclear, and will not require anywhere near the levels of current safety regulations. It's also worth noting that both the UN and the EU have tacitly acknowledged the likelihood that wind and solar alone are incapable of delivering net zero- as well as reclassifying nuclear as a green technology, they also reclassified natural gas as green (as a transition technology)! Hydrogen storage is innately flawed- heat leakage from storing energy means only around 30% of energy generated is stored. Battery is better, especially for power management (few focus on the fact that the Big Battery in Australia delivered huge costs savings to customers, because it obviated the need for fossil fuel plants to remain idling)- but it can't be delivered at scale. Stored hydro is also a good technology, but given that intermittency is also a seasonal problem, we need to acknowledge that somewhere around 40% of energy will need to come from baseload energy sources like nuclear and hydro, and this is before one considers the significant additional burden which transport electrification will place upon countries, in terms of demand for additional energy.
The future of energy in the UK is wind and nuclear, backed up by hydro and stored hydro to handle intermittency.
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.
It is nice to know that those in the DLUHC are at least reading content like this. It gives me more hope for the future, albeit more hope from a low baseline.
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.
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.
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?
Who from a consulting firm wrote the policy paper, Getting Britain building again? I read he will write articles in LinkedIn but forgot his name.
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).
Why especially nuclear? Less than 3,000 people have died as a result of commercial nuclear, and this includes Chernobyl, which was primarily a nuclear weapons materials facility (most likely tritium), which the KGB were informed was extremely hazardous, yet chose to disregard the warning because of its vital role in Soviet nuclear arms manufacture (Reuters). At the same time, now that the Japanese have realised they massively overreacted with hysteria to the Fukushima incident, from which only one person ever died from radiation (which is also heavily disputed), they are back to building nuclear power plants. The last evacuated town was reopened in 2022.
At the same time, measured analysis has shown that solar doesn't fare well in terms of carbon, compared to other alternatives. Any rational examination of solar PV has to include the cost of recycling through smelting which carries both an economic and carbon cost. Without this process, solar PV ends up in landfill and this poses a genuine risk to human health given that solar PV utilises 300 times as much toxic material because of energy density issues.
My point would be this- the regulatory costs of nuclear are 13 times higher than other nations who have developed commercial nuclear have proven they need to be. Despite the hysteria, commercial nuclear has proven to be one of the safest technologies in history. I am not saying that lessons cannot be learned from Fukushima. One of the key observations is creating designs that are idiot-proof. Not only should the generator which powered the cooling system never have been built where it was, but when the alarm sounded local safety operators didn't raise the flood gates which would have protected the generator from flooding, because they were worried that it would cause a public panic. That being said, Fukushima was commissioned in 1971. It was an old plant. Many of the newer models built successfully in East Asia at low cost and in a timespan averaging six years, are far safer.
It's worth noting that SMR's will render much of this discussion moot. Although only 3 models have been built to date, there are around 80 companies investing serious amounts of capital to make them a reality. Sure, the first models which likely require a launch cost per energy unit around 20% higher than the UK is currently paying for new wind development, but if the cost reduction with time plays out anything like the profile for wind, then it's highly likely that SMR energy will ultimately cost less than half of what we are currently paying for wind.
It's worth noting that SMRs are fundamentally more safe than large-scale nuclear, and will not require anywhere near the levels of current safety regulations. It's also worth noting that both the UN and the EU have tacitly acknowledged the likelihood that wind and solar alone are incapable of delivering net zero- as well as reclassifying nuclear as a green technology, they also reclassified natural gas as green (as a transition technology)! Hydrogen storage is innately flawed- heat leakage from storing energy means only around 30% of energy generated is stored. Battery is better, especially for power management (few focus on the fact that the Big Battery in Australia delivered huge costs savings to customers, because it obviated the need for fossil fuel plants to remain idling)- but it can't be delivered at scale. Stored hydro is also a good technology, but given that intermittency is also a seasonal problem, we need to acknowledge that somewhere around 40% of energy will need to come from baseload energy sources like nuclear and hydro, and this is before one considers the significant additional burden which transport electrification will place upon countries, in terms of demand for additional energy.
The future of energy in the UK is wind and nuclear, backed up by hydro and stored hydro to handle intermittency.
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.
https://thetransatlantic.substack.com/p/high-finance-and-anti-development
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!
Who from a consulting firm wrote the policy paper, Getting Britain building again? I read he will write articles in LinkedIn but forgot his name.
It is nice to know that those in the DLUHC are at least reading content like this. It gives me more hope for the future, albeit more hope from a low baseline.
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.
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.
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?