At TopNux 2006 (see page 6), Wicks robustly challenged the nuclear industry to demonstrate how our specific proposals for planning and licensing regulation changes would work in practice. The consultation provides the opportunity to comment on these aspects, as well as clarifying our position on economics and waste management. Perhaps most interestingly, the consultation asks precisely what we are asking Government to do to make these changes work. The Government has produced a consultation that has been hailed by leaders of the power industry such as Paul Golby, Chief Executive of Eon, as “the most important work to shape the power and gas industry for the next 50 years”. So are we properly grabbing the opportunity to make our case crystal clear?

Hinkley B, an Advanced Gas Cooled Reactor, celebrates its 30th anniverary this year.

The industry’s coordinated response to ‘Our Energy Challenge’, delivered through the NIA, attempts to answer the minister’s challenge. Our key recommendation is that the UK’s current nuclear contribution needs to be maintained if we are to have the balanced energy mix we need in the future. This would mean replacing our current plant with new ones. First of all, however Government needs to make it clear that it sees nuclear as part of the generation mix in the UK’s long term energy policy, and is prepared to take the necessary steps to facilitate investment in new build. It could do this by introducing a market framework designed to deliver the White Paper’s security and environmental objectives. This would include developing measures that would recognise the benefits of low carbon generating plant and encourage investors to engage in a replacement nuclear programme. Ultimately, there should be clear, long-term signals that recognise the benefits of low carbon technologies. We offered the idea that the timeline for the EU Emissions Trading Scheme could be extended to provide assurance to investors that carbon trading and a value for carbon will be available over the lifetime of the project.

We attempt to address the Minister’s queries on planning and licensing by requesting predictability in the overall process. No investment in nuclear will be forthcoming while there is uncertainty about the length and scope of the planning and approvals procedures. The planning process for Sizewell B took six years and examined policy and need, safety, economics as well as local environmental issues. We recommend that clear statements of Government policy should be in place before major projects are considered in the planning system. Principles of policy and need would therefore be publicly debated and agreed ahead of a more detailed local inquiry. This approach would reconcile the democratic right to participate with a need to expediate major infrastructure projects. The generic issues of policy and need, reactor design and safety and environmental impact should be considered at the beginning and only once, leaving the public inquiry to deal with local environmental and siting issues.

With respect to licensing, an early review of potential internationally accepted reactor designs by regulators is essential to meet the programme and to preserve essential skills in the regulators, as well as encourage the necessary investment and recruitment of skills within the supply chain. Regulatory bodies should take account of overseas design approval and licensing of nuclear systems. This does not mean accepting them without question, but questioning only those aspects where the UK has specific and significantly different requirements. We suggest that a ‘licenseability review’ of the designs by the regulators should take place in advance of a specific licence application, and therefore be generic in nature such that the equivalent of design certification is obtained in the UK. Subsequent detailed design reviews would therefore not be required as part of the notional series of replacement reactors. Finally, we suggest that once a site licence is issued there should be no significant revisiting of design issues. A clear programme of construction and commissioning approvals should be agreed to help ensure low residual regulatory risk to programme and capital costs at the time of plant order, when the major funding commitment is made.

On the issue of waste management, which the consultation specifically requests comments on, we ask for a clear policy framework and strategic approach for long term radioactive waste management. After CoRWM’s recommendations to Ministers in July, the Government needs to respond to the findings and establish a clear policy agenda for waste, including transparent procedures for site identification and selection. We suggest that in order to provide predictability on sharing risks and rewards with investors, the Government could adopt financial models that have been successfully implemented in other countries, such as Sweden, Finland and the US. Under such arrangement the Government could set a waste disposal ‘levy’ or fee on the basis of nuclear power generation, and charge for this at the time of generation.

Can we build it? Yes we can!

To complement the submission to the Government’s Energy Review NIA’s New Build Working Group has produced a report studying ‘The UK capability to deliver a new nuclear build programme’. The key finding of the study is that the UK nuclear industry has the capability to provide over 80% of the scope of new nuclear power station projects if the Government’s review concludes that new nuclear build should be part of the UK’s future energy mix. Another vital message to the Government is that an assumed reactor programme of 10GW located at 5 sites constructed over a period of 15-20 years should generate 64,000 man-years of work, with a further 22,000 man-years of work generated in the community through indirect jobs in the support sector. Good news for the Government and good news for the country as a whole.

New build report - further copies are available from NIA