Above: The Purple Heather on Dunwich Heath, around 3km north of the proposed Sizewell C site


A DECISION BY EDF ENERGY on 7 June to close and defuel its Dungeness B nuclear station — ahead of its recent schedule, but well beyond its initial life expectancy as the lead AGR – has thrown into sharp relief the UK’s nuclear new-build. The UK’s ambitious decarbonisation strategies in general assume that the contribution from nuclear will remain consistent, although it will represent a smaller proportion of electricity use as mobility and heating increases electricity demand.

The two unit EPR at Hinkley Point C is the first new-build plant since Sizewell B and it is under construction and under intense scrutiny — not least because it is the model for a second two-unit plant, Sizewell C, on the opposite (east) coast. The next step for Sizewell C is being granted development consent. Detailed plans for the power plant, the local effects of construction and managing the project’s environmental impact are now being examined by National Infrastructure Planning, which will report and to make a recommendation to the Secretary of State at the Department for Business, Energy and Industrial Strategy, the decision-maker on development consent.

The Sizewell C process will provide important experience for a third new station, planned for Bradwell in Essex. This will also be on the east coast, although further south, and is adjacent to the existing Bradwell A plant (which ceased operation in 2002 and has been in the care and maintenance phase since 2018).

The Bradwell project is in early discussions with National Infrastructure Planning but has not yet indicated when it will enter the formal process — the Chinese HPR1000 design to be employed only recently entered its licensing process at the Office for Nuclear Regulation. But scoping documents suggest that construction of the Proposed Development will take place over 9 to 12 years and will require facilities for around 4500 temporary staff. The document also notes that within 10km of the main development site there are 14 sites that are internationally and 11 that are nationally designated (generally for wildlife or landscape value), of which eight are within or very close to the main development site. A number of heritage assets are located within the main development site including three scheduled monuments.

These are not insuperable objections but they are significant, both nationally and in winning local support for a project, as a selection of comments from recent public hearings held as part of the Sizewell C examination, reveals. The four days of hearings — online instead of in person, due to Covid restrictions — was largely a forum allowing local people to raise concerns, so they naturally saw local issues raised, rather than fears over nuclear safety or waste, although several speakers did raise specifically nuclear concerns. Among those, witnesses thought the reactor design was too powerful and not proven in use, was slow to build and the site was vulnerable to sea level rise.

They also asked about whether the broader process was properly considered, and specifically whether EDF should have the funding model in place before seeking development consent. The funding model is currently under consideration by government and is expected to be on some form of regulated asset basis.

What are the objections to Sizewell C?

Some objections over the plant, which is a major development in an area that is largely rural with small towns, focused on the effect on the relatively sparse local infrastructure and the loss of access to natural amenities such as beaches. Although the effects on both were acknowledged to be in large part temporary, nevertheless the construction timescale of a decade or more was considered ‘long term’ for parents with concerns about children or retirees who had moved to the area for its rural nature.

An argument that the project would bring long term highly-skilled jobs to the region also with construction jobs — a key positive for supporters of the plant — were countered by fears over the region’s existing jobs. One witness said “the tourism industry was certainly on the last figures worth about 40,000 jobs, and was growing by 5% a year”. The permanent jobs offered by the new plant represent only “about one year’s growth in tourism,” they said.

One reason tourism has been growing in recent years is the large bird sanctuaries and other important local wildlife areas, and here the fears over local jobs coincided with concern over how the plant would affect those habitats. Equally there were fears over the loss of local amenities such as footpaths, local environmental degradation such as water pollution and full access.

“We’ve spoken to a lot of people in the village about recreational use of the Suffolk coast. And nobody wants to lose access to that,” said one speaker.

There was more general scepticism over the jobs ‘bonus’. One said, “Very few jobs will be truly local”, and “The development will simply overwhelm the local economy”.

As ever in the event of development applications there were fears about the effect on traffic, both due to the workers — one speaker said “EDF defines local as being within a 90 minute drive time”, which is very high for the region — and the transport of “huge volumes of material” to and from the site. The issue of materials was not helped by a recent ‘Change Request’ agreed by NIP (changes once the examination process has started are strictly limited) that has seen the amount of material required for the Sizewell C construction increased by 20% compared to the original application. But it also reveals the variety of views that have to be balanced in the consent process. Some speakers were keen to see as much freight as possible moved by train, while others objected that they would be affected by a large increase in rail freight, especially out of working hours. And while road movements were unwelcome, permanent improvements to local road (and potentially rail) routes were not.

Energy coast?

Sizewell C is a very large project of itself but it is just one of a series of energy projects that will affect the area. That has redoubled local concerns. One speaker said, “I don’t think anyone envisages the onslaught of energy projects that are now proposed,” and “Should Sizewell C be consented by the Secretary of State at the end of this examination, it will be the biggest of eight energy infrastructure projects in the heritage coast”.

Another said, “The cumulative effect of all the industry energy plants will swamp this area of outstanding natural beauty and undermine daily life and the key economic business of tourism, providing employment and enjoyment in the area. “

The other projects include landfall from offshore wind farms or electricity interconnectors, and potential hydrogen production plants. Proponents have seen this as a boost to the region bringing jobs and investment and branded it an “energy coast” but feelings are mixed over this. One speaker said the accumulation “has led to efforts to rebrand the southern coast the energy coast. This is not welcome.” Another said, “this is an heritage coast, it is not an energy coast”.

Next steps

The experience at potential new-build site, at Wylfa Newydd in Wales, has given opponents a boost, as development consent was not granted. One speaker explicitly asked the inspector to follow “the relevant and important precedent … Given the similarities between that scheme and Sizewell.”

National Infrastructure Planning has to complete its examination of Sizewell C by 14 October. It must prepare a report on the application to the relevant Secretary of State, including a recommendation, within three months of the close.

The Secretary of State then has three months to make the decision on whether to grant or refuse development consent, but there have been occasions when the decision has been delayed — several times, in the case of one offshore wind farm.

Once a decision has been issued by the Secretary of State, there is a six week period in which the decision may be challenged in the High Court.

There are clearly lessons from Sizewell C for the Bradwell team. They must not underestimate the importance of local issues and the cost of not building them in fully from the start.

An early Bradwell ‘scoping’ report from NIP reveals some areas where local campaigners might suggest a lack of local engagement, such as planning to exclude roads where pedestrians are not permitted from its early assessment. As at Sizewell the project is in a rural area where pedestrians or cyclists use roads without dedicated facilities. NIP said it would expect traffic planning to take account of this from the start.

Bradwell can also expect national concerns to be raised locally, as happened at the Sizewell hearings. Several speakers were worried about the role of China in the project. They mentioned that the UK recently banned the use of other Chinese equipment, from Huawei, in some parts of the UK telecoms network and that China General Nuclear (CGN), owned by the Chinese government, has been blacklisted by the US Department of Commerce. They also raised concerns over widely reported human rights abuses by the Chinese government in Xinjiang and noted that the UK government has itself recently brought in sanctions against officials in China over this issue.

Despite China’s important role the Sizewell C has been fairly successfully positioned as a ‘copy’ of Hinkley Point C. With China in the lead at Bradwell it is already clear that it cannot skimp on engagement nationally or locally if the project is to follow on.

Author: Janet Wood, Expert author on energy issues