Hinkley Point C and Fish Protection: What the Evidence Actually Shows

The Nuclear Industry Association (NIA) is today showing how The Wildlife Trusts have misrepresented the scale and effectiveness of fish protection measures at Hinkley Point C. There is not a choice to be made between nature protection and development – both are achievable but a disproportionate approach delivers small benefits to nature at a large cost to the country.

Nuclear power is the best we have for nature. Across its full lifecycle, nuclear has the lowest carbon emissions, lowest land use, and lowest overall impact on ecosystems of any electricity, according to the UN. Climate change is the single greatest driver of biodiversity loss and habitat destruction. Delaying clean power only accelerates that damage.

The claims were made in a letter sent by the Wildlife Trusts to the Energy Secretary and in a recent statement claiming EDF is making ‘distorted claims about Hinkley Point C’s fish deterrent.’

You can also read a blog post by Tom Greatrex, the Chief Executive of the NIA.

CLAIM 1

“Environmental groups have highlighted that these recommendations were primarily made based on just one nuclear case study in the review, that of the Hinkley C nuclear project.”

— The Wildlife Trusts

FACT

Pages 66-70 of the Nuclear Regulatory Taskforce review discuss several examples from non-nuclear infrastructure projects, the example of fish deterrence at Hinkley Point C, and a number of examples from Sizewell C, including how Sizewell C made dose calculations for freshwater insect larvae.

CLAIM 2

“This case study included incorrect statistics which understated the environmental impact of the project and overstated the cost of environmental mitigation measures.”

— The Wildlife Trusts

THE FACTS

This is not true. The review itemised the cost of three separate fish deterrent systems at Hinkley Point C, as given on page 68 of the taskforce report: “There will be three systems in place: Low Velocity Side Entry water intake heads (£500M), a Fish Recovery and Return System (FRR) (£150m), and an Acoustic Fish Deterrent (AFD) (£50M).”

Certain fish species are protected under the Habitats Regulation, and others are not. The Wildlife Trusts have sought to conflate protected and non-protected fish species to try to come up with a more impressive number. However, the amount of fish killed at Hinkley Point C, even without the acoustic fish deterrent, has been agreed with regulators to be 44 tonnes per year – the same as one small fishing vessel. With the AFD now shown to be highly effective that number will be even smaller.

CLAIM 3

“These [sic] result of these inaccuracies, and the extrapolation of the one flawed case study to wider development, has been the erroneous portrayal of nature protection as a significant blocker to nuclear energy requiring a sledgehammer solution in the form of recommendations 11, 12 and 19.”

— The Wildlife Trusts

THE FACTS

Again, it is not one example and there is no extrapolation. The Review does not say that environmental protection is the only cause of nuclear cost overruns, far from it. The Review identifies a number of factors across government, industry and regulator responsibility and proposes solutions across all of these.

CLAIM 4

“Nature in England is in decline, and the Office for Environmental Protection has this month warned that the Government ‘remains largely off track to meet its environmental targets and obligations, including legally binding biodiversity targets set under the Environment Act’.”

— The Wildlife Trusts

THE FACTS

No one disputes this, but delaying the deployment of nuclear, which has the lowest lifecycle carbon, lowest lifecycle land use, and lowest lifecycle impact on ecosystems puts back the fight on climate change and further damages nature.

CLAIM 5

“Such a blow to nature protection, net zero and clean energy delivery is not yet Government policy. It can still be avoided, if you decide not to progress the three flawed recommendations in the Nuclear Regulatory Review. We urge you to follow the evidence, reject the three recommendations and prevent unnecessary and hugely damaging environmental regression.”

— The Wildlife Trusts

THE FACTS

This statement assumes that the UK’s system of nature protection is working, which we do not believe is true. The current system delays the deployment of clean power to fight climate change, which is the leading cause of biodiversity loss and habitat destruction.

CLAIM 6

“EDF has published a press release which misrepresents the cost of its acoustic fish deterrent and the impact that the Hinkley Point C nuclear plant will have on wildlife.”

— The Wildlife Trusts

THE FACTS

The EDF press release is explicit on the fish deterrent that “It is one of three separate fish protection systems at the power station, which is the first in the area to have any fish protection measures at all. The three systems will cost more than £700 million and give Hinkley Point C more fish protection than any other power station in the world.

CLAIM 7

“Today’s press release claims that a number of plant safety measures are fish protection measures. This is highly misleading and allows EDF to pretend that £700 million is being spent to protect nature, when the real figure is closer to £50m.”

— The Wildlife Trusts

THE FACTS

As EDF and the Nuclear Regulatory Taskforce have said: “There will be three systems in place: Low Velocity Side Entry water intake heads (£500M), a Fish Recovery and Return System (FRR) (£150m), and an Acoustic Fish Deterrent (AFD) (£50M).” The low velocity intake heads and the recovery and return system are unique to Hinkley Point C and were specifically designed to mitigate impacts on fish populations. These features were not used on the previous nuclear power stations at Hinkley Point, and were not used on the other EPRs in France and Finland.

CLAIM 8

“…they spotlight the suggestion that just two salmon will be killed per year when Environment Agency experts warn that 4.6 million fish will die every year.”

— The Wildlife Trusts

THE FACTS

Some fish species are protected under the Habitats Regulations, and some are not protected species. EDF’s analysis deliberately focuses on protected species. Species that are not protected under the Habitats Regulation were outside the scope of the Nuclear Regulatory Taskforce review.

The amount of fish killed at Hinkley Point C, even without the acoustic fish deterrent, has been agreed with regulators to be 44 tonnes per year – the same as one small fishing vessel. With the AFD now shown to be highly effective, that number will be even smaller.

EDF is also very clear on the context of the specific issues of salmon, which are a protected species in the Severn: “Swansea University research has also provided a much better understanding of the movements and location of fish populations in the Severn Estuary. It shows that salmon, migrating to the Atlantic, generally use the main channel - well away from Hinkley Point C’s water intakes. In two years, only 2 tagged salmon were detected within 1km of the intakes.”

A further example around tagged shad is given in the EDF press release, but that has been ignored.

CLAIM 9

“It’s shocking that these claims were accepted without interrogation by the Nuclear Regulatory Review. On the basis of these false claims, the Government is now considering progressing recommendations which will lead to nature protections being severely compromised.”

— The Wildlife Trusts

THE FACTS

The taskforce took months to review documents and speak to stakeholders, including the EA, Natural England, the Marine Management Organisation, EDF, the RSPB, and the Wildlife Trusts themselves.

Again, there is no evidence given for how nature protections will be affected. The UK’s current system does not protect nature because it delays the deployment of clean power to fight climate change, and climate change is the leading cause of biodiversity loss and habitat destruction.

CLAIM 10

“The estuary also plays a crucial role in the lifecycle of a range of endangered migratory fish species including Atlantic Salmon. It is for these reasons that the estuary and some of its species are protected by law.”

— The Wildlife Trusts

THE FACTS

No one has disputed this. The question is about the proportionality of fish protection measures versus all the issues that affect environmental and human welfare. There is not a choice to be made between nature protection and development – both are achievable but a disproportionate approach delivers small benefits to nature at a large cost to the country.