NIA Response to EA Consultation on Hinkley Point C: water discharge activity permit variation

The NIA is the trade association and representative body for the civil nuclear industry in the UK. We represent around 270 companies operating across all aspects of the nuclear fuel cycle.

Our Response

The Environment Agency is entirely correct to grant the proposed variation in particular to remove any references to an Acoustic Fish Deterrent (AFD) because an AFD would add cost to a project essential to our national drive for net zero and energy security and add risk to maintenance workers for a very marginal potential difference to local fish populations.

The Acoustic Fish Deterrent

We note that Hinkley Point C is making unprecedented efforts to protect local fish populations: the AFD was not the only proposed protection. The project will make use of Low Velocity Side Entry intake heads for cooling water, which will cut the overall risk of fish entrainment. It will also have a Fish Recovery and Return system to offer further protection for local species. These measures have been taken despite the fact that for decades, many power stations have taken cooling water from the Bristol Chanel with no detrimental effect on fish. This empirical evidence of the effect of thermal power generation supports and validates the Environment Agency’s proposed course of action.

In this context, requiring an Acoustic Fish Deterrent would be highly disproportionate and costly for a critical project. The Centre for Environment, Fisheries and Aquaculture Science (Cefas) has already provided evidence that demonstrated that the deterrent would not have a significant impact on protected species. The difference in fish mortality would be about the same as the catch of a small fishing boat. That is no reason to obstruct or add cost to a major national infrastructure project that is vital to the fight against climate change and will prevent much larger land areas being used for alternative forms of energy generation.

Moreover, the maintenance of the equipment necessary to the AFD would pose risks for the divers responsible because the Bristol Channel has high tidal ranges and poor visibility. It is unacceptable in our view to add risks for humans involved in the operation of the station for such a small potential upside for local fish.

Nuclear and Biodiversity
There is also an overwhelming public interest in enabling a source of firm, low-carbon power generation to be brought into operation. Climate change presents the leading threat to the environment and to biodiversity: reducing greenhouse gas emissions is the most important thing we can do to benefit natural habitats of all kinds.

This power plant would save 9 million tonnes of emissions per year, for at least 60 years. If it were not to be brought into operation, we would still have to identify an alternative source of clean power generation to limit climate change’s effects on biodiversity. No other source of electricity, however, can replace what nuclear offers.

According to the United Nations Economic Commission for Europe (UNECE) 2022 study Carbon Neutrality in the UNECE Region: Integrated Life-cycle Assessment of Electricity Sources, nuclear has the lowest impact on ecosystems of any electricity generating source, even when the benefits of reducing emissions are ignored. This indicates that attempting to substitute for nuclear power generation would not have any benefit to biodiversity and could well create additional risk of harm.

The relevant tables from the UNECE report assessing the impact of different electricity generating technologies, with and without the benefits of emissions reduction, have been re-produced here:

The UNECE report also found that nuclear has the lowest land use of any electricity generating technology. The relevant table is re-produced here:

Hinkley Point C is exemplifies this: it will meet 7% of the country’s current electricity demand, or enough power for 6 million homes, from just a quarter of a square mile of operational land. Since land use is a key factor in impact on local species, this indicates that attempting to substitute for nuclear power generation would not have any net benefit to biodiversity and could well have greater impacts on ecosystems.

Conclusion

Given the marginal benefit of an AFD for the extra risks to humans involved, the strong and unprecedented measures already taken by Hinkley Point C to protect local species, and nuclear’s irreplaceable ability to provide clean energy from a minimal footprint , we repeat our strong endorsement of the Environment Agency’s intention to grant the permit variation.