Campaigners from Suffolk are in Glasgow to highlight how Sizewell C is not the solution to our climate emergency. Stop Sizewell C, two Suffolk Coastal 2019 General Election candidates – Green East Suffolk Councillor Rachel Smith-Lyte and Liberal Democrat Julia Ewart – whose parties oppose Sizewell C, and local supporters unfurled a “Nuclear is Not Green” banner in the centre of Glasgow.

For immediate release, 26 October 2021.

Stop Sizewell C denounces the government’s announcement today of legislation for a new tax on consumer energy bills to help build nuclear power stations such as Sizewell C. The Regulated Asset Base (RAB) model would transfer substantial upfront costs, and considerable risk, onto consumers already struggling with rising energy bills and other tax increases. [1] Developer EDF Energy estimates Sizewell C – which does not have planning consent and may never get it – would cost at least £20 billion and has made no secret that the project could not proceed without a RAB. The announcement is clearly earmarked for large-scale nuclear projects, as Rolls Royce says it doesn’t anticipate using RAB for Small Modular Reactors. [2] The government is moving with extreme haste, with the second reading of the bill tomorrow.

“RAB is a desperate measure to attract investment for Sizewell C, a project so toxic that no one wants to pay for it,” said Alison Downes of Stop Sizewell C. “Compared to other energy solutions, Sizewell C is an expensive distraction – too damaging, too slow for our climate emergency and with serious question marks over its reactor technology. [3] Whichever way you look at it RAB spells TAX, with every single energy bill payer forced to contribute to the construction of Sizewell C whether they like it or not, adding to households’ rising costs, the risk of fuel poverty and putting us all on the hook for likely cost overruns and delays.” 

The political favour of allowing use of a RAB model for nuclear has fluctuated considerably: it was reported last year that the Treasury “was not enthused” [4] and this has changed only recently. The lack of appeal of investing in large-scale nuclear has prompted multiple infrastructure investors, including Legal & General, Prudential, Nest, Abrdn and Phoenix Group, owners of Standard Life and Sun Life, to state they have no plans to invest in Sizewell C. [5] This lack of support undermines EDF’s claim that Sizewell C should be majority UK-owned, and shows how RAB’s main purpose would be to incentivise billions of pounds of foreign funding by offering an immediate financial return at households’ expense.  

Nuclear energy is specifically excluded from the government’s ‘Green Gilts’ [6] implying a degree of recognition of market or consumer choice, however RAB would permit no consumer choice, the tax being applied to all energy bill payers in England and Wales, including those on renewable tariffs who have already rejected nuclear energy supplies. 

Almost 100,000 people have signed a SumOfUs online petition objecting to use of the RAB for nuclear projects. [7] Eoin Dubsky, campaigner at SumOfUs said “It is preposterous that consumers should be forced to pay for the construction of big nuclear power projects. Nuclear energy is a technology fraught with difficulties and there are better, cheaper and more sustainable options out there to help guarantee our energy security and get us to net zero more quickly. It’s time the government listened to what bill payers want.”

The most often-quoted example of using a RAB for infrastructure projects is the Thames Tideway “Super Sewer” Tunnel. The capital cost is only a quarter of Sizewell C, and the Financial Times recently revealed that the project developer wants to pass overspends onto consumers, raising the surcharge on bills from about £18 per year to £20-25. The project is two years behind schedule. A further key difference is that those paying are limited to Thames Waters’ customers. [8] While all energy infrastructure would no doubt welcome reduced financing costs, this offer is only being made to nuclear power.

There remain major concerns about Sizewell C’s location on a fragile eroding coastline, in an area with limited infrastructure and where no long term water supply has yet been identified. [9] The planning examination ended on 14 October. The Secretary of State would be expected to rule on planning consent by mid April 2022, with decisions on site licenses and permits likely to follow later in the year. EDF’s Simone Rossi has said he hoped a Final Investment Decision could be made by the end of 2022. [10] China General Nuclear’s removal from the project has not yet been achieved. The project remains subject to value for money assessments amid demands the industry make cost savings of 30%.

High resolution images of Stop Sizewell C protests are available (please credit Stop Sizewell C) of an Advan in Whitehall on 20 October, displaying “RAB spells TAX” outside HM Treasury, BEIS and in Whitehall https://drive.google.com/drive/folders/1h96CMl0v7DT1zxFmhlKRKh16JQTH7l7a 

Notes

1. It is widely accepted that a Regulated Asset Base financing model for Sizewell C would expose consumers to construction and cost overruns and add to rising energy bills 10-12 years before any energy was generated. A RAB-type model for a cancelled plant in the US (Summer in South Carolina) is costing ratepayers $2.3bn, and for another, Vogtle in Georgia, whose costs ballooned, the power company is being allowed to pass a further $2.1 billion in overspend on to consumers. There is little evidence that nuclear electricity can compete cost-wise with renewables. Analysis by Professor Steve Thomas of Greenwich University concluded that it would be decades before EDF’s claim that power from Sizewell C would reduce to £60/MWh was realised. 
2. See Alan Woods, speaking at the UK Sustainable Infrastructure Policy & Investment Online Virtual Summit on 14 September 2021 https://www.youtube.com/watch?v=SmUbk2XPjUI at 7.18:45.
3. EDF claims the EPR reactors at Taishan in China – the only two completed EPRs anywhere in the world – prove the technology works, yet Taishan I has fuel failure after only 3 years of commercial operation. A Freedom of Information request reveals that The Office of Nuclear Regulation has access to very little information about the cause or implications for Hinkley C.
4. Sir John Armitt, Chair of the National Infrastructure Commission in Utility Week, August 2020 https://utilityweek.co.uk/treasury-still-unconvinced-rab-model-nuclear/
5. Legal and General told pension holders it did not plan to invest in Sizewell C and confirmed this at the 2021 AGM. We have secured similar statements from Prudential, Nest pensions, Abrdn and Phoenix Group, owners of Standard Life and Sun Life (correspondence available on request). 
6. The Green Financing Framework published in June 2021 said “Recognising that many sustainable investors have exclusionary criteria in place around nuclear energy, the UK government will not finance any nuclear energy-related expenditures under the Framework.”  However the Green Finance Paper, published 18 October 2021 states “The government has asked the EWG to prioritise considering nuclear power’s role in the UK Taxonomy”
7. Sum of Us petition
8. https://www.ft.com/content/f25e29f9-03b4-43a2-9da5-779bcdc3f883
9. The Sizewell site is considered the most environmentally sensitive in the National Policy Statement EN-6, being wholly within the Suffolk Coast & Heaths AONB. Sizewell C would permanently take around 10 football pitches of rare SSSI habitat at Sizewell Marshes and the RSPB says it could be “catastrophic for wildlife” at Minsmere. Both the RSPB and Suffolk Wildlife Trust oppose Sizewell C. At a meeting with the Environment Agency on 28 September 2021, coastal defences were named as an outstanding issue of concern. EDF has been forced to propose a water desalination plant for the period of constructing Sizewell C, and does not yet have an identified long-term water supply.
10. Financial Times

For immediate release, 19 October 2021.

Government Net Zero strategy lacks specific commitment to Sizewell C

[EAST SUFFOLK] Stop Sizewell C notes that despite speculation there is no specific financial support committed for large scale nuclear in today’s Net Zero Strategy, [1]  let alone Sizewell C, beyond a restated intention to take a Final Investment Decision on one large scale nuclear project by the end of this Parliament “subject to value for money and relevant approvals.” The strategy does say the government plans to establish a Regulated Asset Base (RAB) model, but there is no more information on funding, perhaps until the Spending Review. 

Alison Downes of Stop Sizewell C said “Our message to government ministers today remains ‘don’t buy Sizewell C’. It’s too damaging, slow and risky and expensive; it may not even work [2] and it’s certainly not green, so don’t waste either your energy and our money on something that would be obsolete before it was completed. [3] Additionally, however you look at it, RAB spells TAX, adding to already stretched energy bills and putting the British public on the hook for cost overruns and delays. [4] 85,000 people have already said they oppose RAB, and we predict that opposition is going to grow.” [5]

Paul Collins of Stop Sizewell C said: “Sizewell C still doesn’t have planning consent, and may never get it. The negative impacts of the Sizewell project, which far outweigh those at Wylfa in Anglesey where the Planning Inspectorate recommended refusal, should lead to the same result here. [6] It is vitally important that the government takes an objective view of the impacts of Sizewell C, or the faith of local communities in due process – already stretched to breaking point – will be destroyed. Britain should build back faster and greener by focusing on renewables, energy storage, clean heat and energy efficiency.”

Media reports yesterday cited government insiders as saying that Sizewell C was front-runner to win funding support [7] and today’s reported breakfast meeting between Business Secretary Kwasi Kwarteng and EDF’s Jean Bernard Levy seemed designed to confirm this assumption. [8] 

Sizewell C is expected to cost at least £20 billion, [9] and significant concerns remain about its location on a fragile eroding coastline, in an area with limited infrastructure and where no long term water supply has yet been identified. [10] The planning examination ended on 14 October. The Secretary of State would be expected to rule on planning consent by mid April 2022, with decisions on site licenses and permits likely to follow later in the year. EDF’s Simone Rossi has said he hoped a Final Investment Decision could be made by the end of 2022. [11]

High resolution images of Stop Sizewell C protests are available (please credit Stop Sizewell C)

1. Projected messages to the Conservative Party Conference https://drive.google.com/drive/folders/15xoh09StJW3YVcHCtD1xknxsRn_dHahB
2. Mass protest on Sizewell beach, September 2021. https://drive.google.com/drive/folders/1mEdfobUmRU1hp6qDG-I1DMn8p-XBNtKC 

Notes

1.https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1026655/net-zero-strategy.pdf 

2. 2. EDF claims the EPR reactors at Taishan in China – the only two completed EPRs anywhere in the world – prove the technology works, yet Taishan I has fuel failure after only 3 years of commercial operation. A Freedom of Information request reveals that The Office of Nuclear Regulation has access to very little information about the cause or implications for Hinkley C. 

3. During the 12 years Sizewell C would take to construct, renewables would be built more quickly and cheaply and storage options developed. There are increasing numbers of credible, affordable energy models that exclude Sizewell C eg Energy Systems Catapult found that further nuclear power would disrupt and diminish the overall economic value of a more flexible electricity system championed by the National Infrastructure Commission; Imperial College’s analysis met system security standards without Sizewell C and noted that new nuclear at plausible prices led to increased consumer bills. The most ambitious decarbonisation scenarios of both National Grid ESO and the Climate Change Committee do not include Sizewell C; indeed National Grid’s “Leading the Way” scenario is net negative for CO2 emissions by 2032, at least two years before Sizewell C would be on line. If, despite the above, the government is determined to build new nuclear capacity, it should look at other options, such as Small Modular Reactors which could be delivered with less significant construction impacts, and more suitable sites such as Wylfa, which would make a greater contribution to levelling up the UK. 

4. The Regulated Asset Base model would expose consumers to construction and cost overruns and add to rising energy bills 10-12 years before any power. A RAB-type model for a cancelled plant in the US (Summer in South Carolina) is costing ratepayers $2.3bn, and for another, Vogtle in Georgia, whose costs ballooned, the power company is being allowed to pass a further $2.1 billion in overspend on to consumers. Major UK infrastructure investors Legal and General have said “no” to Sizewell C and we have secured similar statements from Prudential, Nest pensions and Phoenix Group, owners of Standard Life and Sun Life (correspondence available on request). China General Nuclear’s removal from the project has not yet been achieved. The project remains subject to value for money assessments amid demands the industry make cost savings of 30%. There is little evidence that nuclear electricity can compete cost-wise with renewables. Analysis by Professor Steve Thomas of Greenwich University concluded that it would be decades before EDF’s claim that power from Sizewell C would reduce to £60/kwh was realised. 

5. Sum of Us petition

6. The Planning Inspectorate recommended Wylfa be refused because of environmental impacts. 

7. Daily Telegraph

8. 8. BBC

9. 9. EDF’s estimated cost is £20bn but is “illustrative and non-binding”. EDF is reassessing the cost but a revised cost assessment will not be available until after the planning examination.

10. The Sizewell site is considered the most environmentally sensitive in the National Policy Statement EN-6, being wholly within the Suffolk Coast & Heaths AONB. Sizewell C would permanently take around 10 football pitches of rare SSSI habitat at Sizewell Marshes and the RSPB says it could be “catastrophic for wildlife” at Minsmere. Both the RSPB and Suffolk Wildlife Trust oppose Sizewell C. At a meeting with the Environment Agency on 28 September 2021, coastal defences were named as an outstanding issue of concern. EDF has been forced to propose a water desalination plant for the period of constructing Sizewell C, and does not yet have an identified long-term water supply.

11. Financial Times

6 October 2021.

For high resolution images see: https://drive.google.com/drive/folders/15xoh09StJW3YVcHCtD1xknxsRn_dHahB (credit Stop Sizewell C)

[MANCHESTER] Stop Sizewell C last night projected a series of messages close to the Conservative Party Conference [1] to Boris Johnson ahead of today’s conference speech, urging him not to announce significant financial support for Sizewell C. It has been widely reported that the government is considering taking a direct stake in Sizewell C, as well as introducing legislation that would add a nuclear ‘tax’ onto already-stretched consumer bills. through a regulated asset base (RAB) financing model during construction, as an incentive to draw in new investors. [2]

Alison Downes of Stop Sizewell C said: “Committing financial support for a project as slow, risky and expensive as Sizewell C, especially since the EPR reactor may not even work [3] is – to borrow expressions from the Chancellor – economically irresponsible, even immoral, given that taxpayers and consumers would be forced to pay for it. We say to the Prime Minister, Don’t buy Sizewell C. We can’t afford it, or afford to wait for it, so don’t waste our money on something that would be obsolete before it was completed. He should have the guts to build back faster and greener by supporting renewables, energy storage, clean heat and energy efficiency.” [4] 

Large-scale nuclear plants are considered by many experts to be too inflexible to be a good fit with renewable energy generation. According to Lord Deben, Chair of the Climate Change Committee “Nuclear isn’t the best way of getting that base energy because you can’t turn it on and off: you have to use it all the time”. A Good Energy report by Energy Systems Catapult published in June 2021 found that “beyond the existing Hinkley Point C plant, new nuclear is both unnecessary to reach net zero and would be difficult to manage alongside such a large fleet of renewables.” [5]

Sizewell C is expected to cost at least £20 billion, [6] and significant concerns remain about its location on a fragile eroding coastline, in an area with limited infrastructure and where no long term water supply has yet been identified. [7] The planning examination concludes on 14 October. The Secretary of State would be expected to rule on planning consent by mid April 2022, with decisions on site licenses and permits likely to follow later in the year. EDF’s Simone Rossi said he hoped a Final Investment Decision could be made by the end of 2022. [8]

Notes

1. The messages projected on Manchester One read “Don’t Buy Sizewell C – Too damaging, too costly, too risky”, “Build Back Greener, Faster – we can’t afford to wait for Sizewell C” and “Sizewell C is a taxing issue – we’ll all pay the £20 billion construction cost”. Designer Antony Easton, projection POW.
2. The Regulated Asset Base model would expose consumers to construction and cost overruns and add to rising energy bills 10-12 years before any power. Over 85,000 people have signed a petition opposing use of the RAB for new nuclear projects. Major UK infrastructure investors Legal and General have said “no” to Sizewell C. Stop Sizewell C has also secured similar statements from Prudential, Nest pensions and Phoenix Group, owners of Standard Life and Sun Life (correspondence available on request). China General Nuclear’s removal from the project has not yet been achieved. The project remains subject to value for money assessments amid demands the industry make cost savings of 30%. There is little evidence that nuclear electricity can compete cost-wise with renewables. Analysis by Professor Steve Thomas of Greenwich University concluded that it would be decades before EDF’s claim that power from Sizewell C would reduce to £60/kwh was realised.
3. EDF claims the EPR reactors at Taishan in China – the only two completed anywhere in the world – prove the technology works, yet Taishan I has fuel failure after only 3 years of commercial operation. A Freedom of Information request reveals that The Office of Nuclear Regulation has access to very little information about the cause. The ONR needs to urgently establish if there is any link between this incident and the EPR design or use of high burn-up fuel, and assess the implications for Hinkley C. 
4. During the 12 years it would take to construct, renewables would be built more quickly and cheaply and storage options developed. Here are increasing numbers of credible, affordable energy models that exclude Sizewell C eg Energy Systems Catapult found that further nuclear power would disrupt and diminish the overall economic value of a more flexible electricity system championed by the National Infrastructure Commission; Imperial College’s analysis met system security standards without Sizewell C and noted that new nuclear at plausible prices led to increased consumer bills. The most ambitious decarbonisation scenarios of both National Grid ESO and the Climate Change Committee do not include Sizewell C; indeed National Grid’s “Leading the Way” scenario is net negative for CO2 emissions by 2032, at least two years before Sizewell C would be on line. If, despite the above, the government is determined to build new nuclear capacity, it should look at other options, such as Small Modular Reactors which could be delivered with less significant construction impacts, and more suitable sites such as Wylfa, which would make a greater contribution to levelling up the UK. It’s hard to imagine that money could be found to support all of these.
5. See www.utilityweek.co.uk/lord-deben-politicians-finally-grasped-reality-climate-change and www.thetimes.co.uk/article/big-is-not-so-beautiful-in-grid-talks-to-power-down-8w0qxbtgg and Good Energy (referenced above) http://www.goodenergy.co.uk/business/exclusive/renewable-nation
6. EDF’s estimated cost is £20bn but is “illustrative and non-binding”. EDF is reassessing the cost but a revised cost assessment will not be available until after the planning examination.
7. The Sizewell site is considered the most environmentally sensitive in the National Policy Statement EN-6, being wholly within the Suffolk Coast & Heaths AONB. Sizewell C would permanently take around 10 football pitches of rare SSSI habitat at Sizewell Marshes and the RSPB says it could be “catastrophic for wildlife” at Minsmere. At a meeting with the Environment Agency on 28 September 2021, coastal defences were named as an outstanding issue of concern. EDF has been forced to propose a water desalination plant for the period of constructing Sizewell C, and does not yet have an identified long-term water supply.
8. Financial Times https://www.ft.com/content/7c3a4e77-9889-43b4-a7fa-1bbb5b6bd985