All posts by Alison Downes

Reaction: Secretary of State publishes draft designation reasons for Sizewell C Co.

BEIS has today published draft reasons for designating NNB Generation Co (Sizewell C Co) as the first step towards the company being able to use a RAB funding model. All financial figures have been redacted. The BEIS press statement says “by publishing the draft reasons for designating Sizewell C under the RAB model, the government is going beyond the transparency requirements set out in legislation.”
Stop Sizewell C said: “It’s outrageous that ministers are hiding the cost to electricity bill payers and the public purse of Sizewell C, while claiming to be transparent. By redacting the finances, it is impossible to know if the Secretary of State’s judgement on Value for Money is sound. We fail to understand why the government would not impose conditions related to the EPR reactor technology, when it has such a catastrophic track record, and one of the only working examples has been offline for almost a year in China”
Additionally we note the following:
  • The Secretary of State is intending to designate a company which no one knows who the owners will be. EDF and the government – both apparently intending to be minority partners in Sizewell C with 20% stakes – are continuing to negotiate with each other behind closed doors. The government intends to take a special share in Sizewell C, as a means of “protecting national security interests”, yet there is no mention of removing China General Nuclear from the project.
  • The Value for Money assessment acknowledges that the (secret) figures provided by NNB require “uplift” (page 22 “Given that largescale infrastructure projects have a tendency to cost more and take longer to build than expected, the analysis has applied appropriate uplifts to these assumptions”), and conclude that “the estimated return on government investment is positive in the majority of scenarios modelled” (page 22). With no indication of the size of that majority, or the various cost burdens, it is therefore clear that the return was negative in at least some scenarios. The only cost for Sizewell C in the public domain is the original estimate of £20 billion, published over two years ago. Since then there have been major changes to the project and huge price hikes in construction materials.
  • Despite references to lessons learned at other EPR projects, there are no specific conditions linked to design adaptations that will be required for Hinkley Point C and Sizewell C’s reactors based on the experience of Taishan 1, where problems have led to the reactor being offline for almost a year. (EDF reports, p116 “In addition [to fuel failure], a phenomenon occurring between the assemblies and a component enclosing the core has been identified, which would be linked to hydraulic stresses”  and the French regulator, ASN, refers to (p14) “various anomalies observed on the cores of the EPR reactors of TaishanSuch adaptations could have a serious impact on both cost and timescales. A government condition was attached to an (unused) offer of loan guarantees for Hinkley Point C, that the Flamanville EPR should be operating by December 2020. It is not expected to be operating until mid 2023 at the earliest. Finland’s Olkiluoto EPR is still testing at reduced capacity.
  • The government’s Dynamic Dispatch Model (DDM) methodology is secretive. The modelling should be made public and subjected to proper scrutiny by informed people in order to build the private investor confidence the project requires. Neil Crumpton of PAWB says “The DDM model is too technically and economically simplistic and not sufficiently transparent for robust engineering decision making, due diligence or public scrutiny. Decisions on multi billion projects should not be based on anything like such basis”. 
  • The document contains a number of statements we consider to be prejudicial to the DCO (planning) process, despite the Secretary of State’s claims that another BEIS minister will make that decision, due by 8 July. eg para 134: “The construction of Sizewell C is also expected to have adverse effects on ecology, fisheries and marine water quality. However, some effects will be reduced dependent on successful establishment of replacement habitats. Suffolk County Council, SZC GenCo and East Suffolk Council have agreed a funding package for mitigation and compensation measures in a Deed of Obligation, which includes up to £100m for the environment.”
  • If the Secretary of State wanted more transparency, the legislation provides the option to consult “any other person” but he has rejected this opportunity, limiting the consultation very narrowly to a small group of statutory consultees. Not even the relevant Local Authorities are included. Local communities are dismissed on the grounds that they have been extensively consulted during the DCO process, yet BEIS is well aware of multiple complaints about the poor quality of EDF’s consultations. The government has however published a public consultation on the detail how of how nuclear projects would receive their funding under the RAB model.
  • A reference to Sizewell C contributing to the government’s target of 2 million “green” jobs pre-judges the outcome of a promised UK consultation on the taxonomy of nuclear energy.
  • The BEIS press statement reiterates a claim that a RAB model for Sizewell C would cost consumers on average a pound a month, a figure that has been challenged by Stop Sizewell C working with Professor Steve Thomas, see https://stopsizewellc.org/rab.
  • There are no references to or conditions attached to lessons learned from Ukraine where nuclear sites have been targeted during the conflict.

Hundreds join Sizewell C protest march as planning decision is delayed

15 May, Suffolk: Hundreds of people came together in east Suffolk today to join Stop Sizewell C and Together Against Sizewell C for a colourful, noisy march and rally against Sizewell C. Carrying banners saying “Chaos Coast, coming soon”, “Roadworks (for years) ahead” and “Enjoy Suffolk while you can”, protestors marched from Leiston to Sizewell beach where they were joined at a rally by Adrian Ramsay, Co Leader of the Green Party. 

The march took place just days after Ministers decided to delay the Sizewell C planning decision by over 6 weeks, from 25 May to 8 July, [1] which campaigners take as clear recognition of the project’s many difficult problems including water supply, transport, coastal erosion and biodiversity. [2]

Alison Downes of Stop Sizewell C said: “We have all come here today to show that a decision to go ahead with Sizewell C would be a wrong decision. EDF has clearly not taken this community with them, [3] and the government has totally betrayed the faith of local people in due process by repeated commitments to Sizewell C [4] when it doesn’t have planning consent, let alone a Final Investment Decision. Two wrongs don’t make a right, so where is the sense in copying Hinkley C, badly overrun and overspent [5] using a faulty reactor design that’s been offline in China for the last 10 months?” [6]

Pete Wilkinson, Chair of Together Against Sizewell C said “As we have shown comprehensively in evidence to the government and the planning authorities, the case against Sizewell C is overwhelming. If the Secretary of State dares to approve its construction in the face of that evidence and in the knowledge that nuclear is a declining industry, competes badly with renewables on all fronts [7] and will fail to provide the sort of response required by the existential emergency created by climate change, the government can add dereliction of duty to its charge sheet.”

Adrian Ramsay, co-leader of the Green Party, said: “We face an unprecedented rise in the cost of living. Building a nuclear power station with the kind of subsidy the Government is talking about will lock in raised electricity prices for years to come. Renewably generated electricity is now far, far cheaper and will deliver far more sustainable jobs for Suffolk people and its independent businesses than this expensive white elephant. As the Greens’ parliamentary candidate for villages near this site, I know first hand the strength of opposition locally. Construction will take a decade and generate thousands of tonnes of carbon emissions. The climate crisis needs tackling now, not in a dozen years’ time when Sizewell C may just start operating.”

Other speakers at the rally include district councillors Louise Gooch [Labour, Kirkley & Pakefield] and David Beavan [Liberal Democrat, Southwold, Reydon and Walberswick]. Invitations were extended to two Conservative councillors but they were unavailable.

Photos available here: https://www.smugmug.com/gallery/n-B9wfx9/  Credit Gregg Brown/Stop Sizewell C & TASC

Notes for Editors

  1. On 12 May Minister Paul Scully said “I have decided to set a new deadline of no later than 8 July 2022 for deciding this application. This is to ensure there is sufficient time to fully consider further information provided by the applicant and interested parties in response to the Secretary of State’s post-examination consultation.” 
  2. For a summary of outstanding issues, see www.stopsizewellc.org/predecision/There is as yet no long-term mains water supply for the plant, which needs an average of 2.2 million litres per day in the driest region of the UK. Potable water for the construction will have to be supplied by a damaging desalination plant. 
  3. In January 2021 Kwasi Kwarteng said “The way in which EDF engages with the local community, particularly in Sizewell C – if that’s the one that gets the green light – is really important because in all of these issues there are always two sides. The onus is on the company developing a project to bring as many people as possible with them”. Sizewell C is facing considerable local opposition and it is also opposed by the RSPB, whose internationally famous Minsmere reserve adjoins Sizewell C, and the Suffolk Wildlife Trust. Part of Sizewell Marshes Site of Scientific Interest would be lost forever. The cooling systems have the potential to trap and kill hundreds of millions of fish and other marine biota annually during each of its 60 years of operation.
  4. On 7 April Kwasi Kwarteng told the “Today” programme “we are committed to Sizewell C”. On 13 May he tweeted “agree Sizewell C” 
  5. EDF is shortly expected to publish details of the extent to which Hinkley Point C will overspend and overrun. This would be the 4th confirmed increase since construction began in 2016 (other increases announced in 2017, 2019 and 2020). Industry claims that making a copy of Hinkley C’s EPR reactors will reduce costs and construction risk are not credible. It is impossible to replicate the location ,and the pattern of delay and overspend has been repeated multiple times at Taishan, Olkiluoto (still not at full operating capacity) and Flamanville – the latter two over a decade late and multiple times overspent.
  6. Taishan I has been offline since July 2021 with fuel failure. Besides the loss of sealing on the fuel rods, EDF also reports (see page 116)In addition, a phenomenon occurring between the assemblies and a component enclosing the core has been identified, which would be linked to hydraulic stresses. Studies are underway on these phenomena and their potential impacts.”
  7. Sizewell C’s 3.2GW of power would cost at least £20bn (this figure is 2 years out of date) compared to an estimated £50bn for 30GW – nine times this capacity – in offshore wind. Investments in Sizewell C would suck vital resources from renewables, energy efficiency or technologies such as green hydrogen storage.