Britain's civil nuclear programme stands at a critical juncture. With aging AGR reactors nearing the end of their lives and delays to new projects like Hinkley Point C, the UK faces a potential capacity crunch. Yet one of the most significant obstacles to progress is not technical, it is regulatory. For decades, nuclear has been neglected, its aging reactors closing one-by-one while new projects struggle to break through the increasing web of regulatory barriers. It's the corporate equivalent of hacking through dense jungle – there is no clear path and every last thing is trying to kill you.
On Friday, Shadow Energy Secretary, Claire Coutinho has proposed a set of amendments to the Planning and Infrastructure Bill that will slash the power of environmental regulators in the nuclear sphere. This axe needs to be swung more widely and cut down the nuclear regulator as well.
In this blog I will explain why our nuclear regulation is in such a mess and propose a way out of the jungle.
Risk elimination is not an appropriate regulatory goal
The Office for Nuclear Regulation ("ONR") though established with the aim of ensuring public safety, has in practice fostered a culture of excessive risk aversion that now undermines the very resilience it is supposed to protect.
In relation to the dwindling fleet of legacy Advanced Gas-Cooled reactors ("AGRs"), ONR requires operator EDF to demonstrate 100% control rod insertion in a 1-in-10,000 year seismic event, which would be ten times bigger than the biggest earthquake in UK history (Dogger Bank 1931). This, despite the fact that only around 15% of rods (12 out of 80) are needed to shut down the reactor, and that two independent backup shutdown systems also exist. As a result, reactors like Torness and Heysham 2 face premature closure, not for genuine safety concerns, but due to arbitrarily conservative modelling assumptions.
0% or 100% of anything are rarely justifiable in a regulatory context because they represent absolute positions that fail to account for uncertainty, proportionality, and system trade-offs. In regulatory frameworks, particularly those dealing with energy, environment, or safety, absolutist thresholds are typically flawed for a number of key reasons:
- They disregard diminishing returns: achieving the final few percent of any target often becomes exponentially more expensive or difficult than earlier progress. For example, reducing emissions from a gas plant by 95% might be economically and technically feasible, but squeezing out the final 5% may require disproportionate effort or cost, especially if it risks grid stability
- They exclude pragmatic flexibility: real-world systems need buffers, contingencies, and redundancies. For instance, a "100% renewable electricity system" may sound desirable, but it ignores the need for firm backup, inertia, voltage support, and security-of-supply under stress conditions. That last 1–2% of reliability may require synchronous machines or fossil backup unless much more mature alternatives emerge
- They ignore systemic interdependencies: energy systems operate across sectors, timeframes, and infrastructures. "0 nuclear risk" is unattainable without rejecting nuclear outright, which could worsen climate outcomes or grid resilience
- They limit adaptive governance: rigid targets undermine the ability of regulators to respond to changing technology, market signals, or geopolitical events (eg energy security crises). Regulation must retain optionality with the ability to pivot as information or circumstances evolve. Absolutes tend to lock systems into brittle positions
- They often signal ideology, not evidence: extreme targets are frequently the result of political or activist pressure, rather than engineering, economic, or risk-based analysis. Good regulation is risk-proportional and designed to reduce rather than eliminate harm (which is often impossible or counterproductive)
Effective regulation is about optimisation, not perfection. It weighs costs, benefits, trade-offs and uncertainties. Targets like "0% this" or "100% that" are rhetorically powerful but usually analytically weak. The goal should be a resilient, cost-effective system, not a purist one.
Of course, I am not arguing for less safety, but for a mature approach to safety and risk. A focus on component failure is inappropriate in a world where user error is increasingly a driving factor in accidents. Or where users operate in an environment that makes error more likely.
At Fukushima for example, regulators were blinkered, focusing on seismic risk while largely ignoring the well documented risks of tsunami. The ONR's approach to graphite cracking may make it feel better: it is clamping down on a known risk, but it is excessive and this type of rigid thinking may lead it to miss other, potentially more pertinent risks. I have advocated for the inclusion of risk experts from the financial sector to join nuclear regulatory taskforces because they can help to break down this type of siloed thinking.
"In the Japanese nuclear industry, there has been a focus on seismic safety to the exclusion of other possible risks. Bureaucratic and professional stovepiping made nuclear officials unwilling to take advice from experts outside of the field. Those nuclear professionals also may have failed to effectively utilize local knowledge. And, perhaps most importantly, many believed that a severe accident was simply impossible.
In the final analysis, the Fukushima accident does not reveal a previously unknown fatal flaw associated with nuclear power. Rather, it underscores the importance of periodically reevaluating plant safety in light of dynamic external threats and of evolving best practices, as well as the need for an effective regulator to oversee this process,"
– James M. Acton and Mark Hibbs, Carnegie Endowment for International Peace
Risk management must also be proportionate. There have only been three major accidents (and only one of which involving fatalities) in over 18,500 cumulative reactor-years of commercial nuclear power operation in 36 countries. The evidence from over six decades of civil nuclear deployment is that nuclear power is safe, and the risk of accidents in nuclear plants is low and declining.
A 2009 US Department of Energy Human Performance Handbook notes:
"The aviation industry, medical industry, commercial nuclear power industry, US Navy, DOE and its contractors, and other high-risk, technologically complex organizations have adopted human performance principles, concepts, and practices to consciously reduce human error and bolster controls in order to reduce accidents and events… About 80% of all events are attributed to human error. In some industries, this number is closer to 90%. Roughly 20% of events involve equipment failures.
When the 80% human error is broken down further, it reveals that the majority of errors associated with events stem from latent organizational weaknesses (perpetrated by humans in the past that lie dormant in the system), whereas about 30% are caused by the individual worker touching the equipment and systems in the facility. Clearly, focusing efforts on reducing human error will reduce the likelihood of events."
The evidence of these regulatory blinkers in the nuclear sector is also evident in relation to new reactors.
At Hinkley Point C, UK regulators (the ONR and others) imposed over 7,000 design changes on a design already approved by both the French and Finnish regulators which are hardly known for a cavalier approach to safety. Among the most costly was ONR's insistence on a redundant analogue control system, justified as protection against cybersecurity threats and rare, high-consequence events. This requirement forced a complete redesign of the control room and rerouting of extensive additional cabling.
However, these risks are already substantially mitigated in modern nuclear control systems because they are air-gapped, use hard-wired I/O rather than remote interfaces, have redundant, diverse power supplies and run on hardened, validated platforms like Teleperm XS. ONR's real concern appears to have been with black swan scenarios such as electromagnetic pulse ("EMP") attacks arising from military conflict rather than routine operational hazards. But if the UK were under EMP attack, we would likely face far greater problems than control system failure at a nuclear plant: hostile forces targeting our reactors would probably also be targeting cities. At that point, worrying about analogue backups might be the least of our concerns.
Another flaw in the modern approach to nuclear safety lies in the application of ALARP ("as low as reasonably practicable") and ALARA ("as low as reasonably achievable"). When applied to new reactor designs, these principles are interpreted by regulators to mean that worker radiation exposure must be lower than in existing reactors. This sounds sensible until you consider that even in older plants, like the AGRs, radiation exposure inside the controlled areas is lower than natural background levels outside the plant, including from cosmic rays. If workers receive a higher dose walking across the car park than they do inside the reactor building, what purpose is served by driving exposure even lower? The answer is: none. It adds cost and engineering complexity with no health benefit.
This is a distortion of the original ALARP /ALARA principles which were intended to guide practical, risk-informed decision-making, not enforce ever-decreasing thresholds regardless of actual risk. This misapplication has gone unchallenged for too long.
We need a new approach to nuclear regulation
One of the issues with the ONR (and indeed many other regulators) is lack of accountability. ONR actually sits within the Department for Work and Pensions ("DWP"), a historic decision partly due to the DWP's association with workplace safety, and partly to reduce the risk of undue pressure from energy ministers whose enthusiasm for new reactors could in theory lead to an erosion of safety standards. But the result has been a lack of oversight. No pensions minister has the slightest interest in nuclear safety beyond thinking regulation is a good thing. They have other priorities.
I'm not usually a fan of abolishing regulators. Typically this is little more than a re-branding exercise as new regulator is formed employing broadly the same people as the old one. However in this case I would make an exception: abolish the ONR and create a new nuclear regulator, within the Department for Energy Security and Net Zero (which should be re-named as the Department for Energy – let's stop trying to virtue signal with departmental names), and staff it with different people.
Crucially, the new regulator should have a board comprising risk experts from finance and aviation as well as nuclear safety to avoid the pitfalls into which the ONR has fallen. Risk professionals from the financial sector who routinely balance probabilistic outcomes, tail risks, and interdependencies would help correct the current regulatory tunnel vision. The new regulator should be mandated to take a full-system approach to risk, factoring in wider issues such as energy security in its decision-making, so that premature closure of safe reactors on spurious grounds (such as graphite cracking) does not increase the chances of blackouts which, as we saw in Iberia, can be fatal. Energy poverty carries similar risks. Just as the Bank of England has a remit to weigh multiple economic indicators, the UK's nuclear safety regime must operate within a wider framework of energy system integrity and national resilience.
Environmental regulation must be pruned
From bat tunnels to fish discos, environmental regulation has become pretty bonkers, going to extreme lengths to achieve minimal gains. The fact that such ridiculous solutions have been proposed in the first place highlights everything that is wrong with environmental regulation in the UK.
People are more important. This should be obvious. People are more important than bats, fish, newts and any other creature you could think of. People need secure, affordable housing, they need secure and affordable energy and they need fast and convenient transportation. Trains in fact are far more environmentally sustainable than cars, so delaying a new rail link for spurious environmental reasons is an overall dis-benefit to the environment even if a few bats suffer – and I have nothing against bats – my childhood home was shared with long-eared bats which left lots of half-eaten moths around.
In fact that's a good reminder that most of the creatures environmentalists try to "save" cause harm to other creatures, either by eating them, or by destroying their habitats or food sources. Campaigns to prevent culling deer mean result in a decline in woodland bird numbers, campaigns to stop shooting pest birds result in higher crop damage and even harm to livestock. And of course there are endless debates about whether badgers should be culled to prevent the spread of bovine tuberculosis. Successful wildlife campaigns tend to favour cuter animals over less cute ones, which is hardly scientific.
Environmental regulators apply a bottom-up approach to regulation. They assume if they protect every site then the whole country will be protected. This is a false assumption, as is very well demonstrated by nuclear energy. Nuclear power is a very dense source of energy in the sense that a huge amount of energy is produced from a geographically small site. Very little land is required compared to other forms of generation. John Constable of the Renewable Energy Foundation has calculated that wind and solar farms use up to 3,000 times more land than nuclear to produce the same amount of energy.
So building a new nuclear power station avoids using more land elsewhere for other forms of generation. It may be the case that even if a nuclear site was an environmental wasteland (which is not the case) national biodiversity would be better than with the alternatives.
As far as nuclear projects go, environmental regulators are as troublesome as the ONR. For Sizewell C, ONR, perhaps accepting its over-reach at Hinkley, agreed to allow EDF to build an exact replica of Hinkley Point C with no additional requirements. So it is an identical design, at an almost identical site to the currently operating Sizewell B and the decommissioned Sizewell A.
Yet the project has generated some 40,000 pages of environmental statements! How? Why? They should have amounted to a couple of pages outlining any differences with the new site and the adjacent one, which are minimal. I have been there, you can spit from one site to the other.
But a combination of obsessive environmental regulators and a fear of judicial review created this tsunami of paperwork (the idea is that if you create a lot of documents you reduce the number of people who can afford to pay lawyers to read them and bring legal action). Another problem is that, according to people close to the process, many of these regulators hire environmental activists to their staff because they are willing to work for less money, creating serious biases within these organisations, as well as a potential lack of skill if hiring decisions are made based on ideology rather than technical qualifications.
The Conservative amendments to the Planning and Infrastructure Bill
To prevent some of these abuses, Lord Offord of Garvel tabled the following amendments to the Planning and Infrastructure Bill:
Exemption for new nuclear power station sites from obligations under habitats regulations
- The Conservation of Habitats and Species Regulations 2017 (S.I. 2017/1012) do not apply to the development of new nuclear power station sites.
- Accordingly, no planning authority, statutory body, arms-length body, or court may—
- withhold planning permission,
- require mitigation or compensatory measures, or
- prevent or delay the grant of consent,for a new nuclear power station on the basis of any obligation, assessment, or procedure under the Conservation of Habitats and Species Regulations 2017
- -specific obligations from which nuclear power station site developers are exempted under subsection (1) include, but are not limited to—
- wildlife mitigation measures such as bat tunnels and acoustic deterrents for fish, and similar infrastructure, whether proposed under regulatory advice or statutory process, and
- application of mitigation hierarchies or appropriate assessments under the Conservation of Habitats and Species Regulations 2017.
Member's explanatory statement
This amendment disapplies all the provisions of the Conservation of Habitats and Species Regulations 2017 to the development of nuclear power stations, and so prevents planning authorities, statutory bodies, arms-length bodies, and courts from blocking development consent or imposing mitigations on the basis of those regulations.
.
- Notwithstanding any requirement under the planning enactments, no planning authority or statutory body—
- shall be required to withhold or delay development consent for a new nuclear power station on the basis of any anticipated environmental impact;
- may impose mitigation conditions or design alterations to a nuclear power station solely in consequence of an environmental impact assessment.
- Site-specific obligations which may not be required solely on the basis of an environmental impact assessment include, but are not limited to—
- wildlife mitigation measures such as bat tunnels and acoustic deterrents for fish, and
- application of mitigation hierarchies under the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (S.I. 2017/1012).
- For the purposes of this section, "planning enactments" means the Town and Country Planning Act 1990, the Planning Act 2004, the Planning Act 2008, the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, and this Act.
Member's explanatory statement
This amendment gives a planning authority, including the Secretary of State, the power to grant planning consent to a nuclear power station regardless of the findings of an environmental impact assessment, and prevents planning authorities and statutory bodies from imposing mitigations or conditions on nuclear power stations based on the findings of an environmental impact assessment.
.
Limitation of judicial review for new nuclear power station sites
- No court or tribunal may entertain—
- an application for judicial review of, or
- an appeal against, a decision by the Secretary of State to grant a development consent order for a nuclear power station and any associated infrastructure under the Planning Act 2008.
- Subsection (1) includes any claim brought on the basis that—
- the proposed development has not complied with the Conservation of Habitats and Species Regulations 2017 (S.I. 2017/1012),
- any environmental plan, programme or delivery obligation has not been fulfilled, or
- any provision of the planning enactments relating to environmental protection has not been complied with.
- Subsections (1) and (2) apply notwithstanding—
- any other provision or rule of domestic law (including any common law), and
- any interpretation of international law by the court or tribunal.
- For the purposes of this section, "Planning Acts" means the Town and Country Planning Act 1990, the Planning Act 2004, the Planning Act 2008, the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, and this Act.
Member's explanatory statement
This amendment prevents applications for judicial review of the Secretary of State's decision to grant development consent for a nuclear power station, including on the grounds of non-compliance with habitat regulations or environmental protection obligations.
Together, these amendments, if passed, will limit the ability of environmental regulators and activists to delay the approval of new nuclear power stations, and reduce the cost impact of both the delays, and the often excessive design changes they require. However, I would go further, and also require whole-system thinking from environmental regulators. They should not be immune from the consequences of blackouts and fuel poverty if their actions delay the construction of important new energy infrastructure. And they should be required to assess not just local impacts but the national footprint of alternative energy sources.
Pragmatism, not paralysis is needed in our regulatory ecosystem
The UK's pursuit of nuclear power has long been undermined by a self-imposed regulatory paralysis. The solution is not to weaken safety, but to redefine it. Safety must mean more than avoidance of accident, it must also include the ability to keep the lights on and to ensure that Britain's critical infrastructure is robust, affordable, and secure.
We need a new nuclear regulator that is not trying to eliminate risk but to manage it. Safety standards must be reasonable and not seek to improve on the natural environment. Absolutism should be avoided, as should tunnel vision. Today's regulation is like a requirement to force motorists to wear 57 seat-belts which any normal person would think was simply ridiculous.
Environmental regulators must not be allowed to complicate, delay or prevent new nuclear projects. These are schemes of critical national importance, and should take priority over a few newts or fish. They must approach biodiversity from the perspective of the wider national interest and not simply on a site-by-site basis, and the drive should be to reward developers for maintaining biodiversity rather than preventing them from reducing it.
And the number of people with standing to bring judicial review applications and the scope for such applications must be reduced for important national projects such as new nuclear power stations. I have argued this before and do so again. We must not allow people with an axe to grind to get in the way of critical infrastructure – it's considered critical for a reason.
This post is spot on. For far too long, we’ve allowed dogma and dubious motives to delay, add cost or even cancel new nuclear projects. Absolutely spot on.
Diminishing returns is easily explained by analogising three phase generation, transmission and distribution. Four phases would undoubtedly give you various advantages, but the effort and cost to install the extra phase is not worth the effort, while three phases are the happy medium. And you should always laugh at people who advocate for 0% or 100%. Call them “fundamentalists,” then watch them arc up.
Try telling all this to those on tge liberal left who idolise disaster as a way of life.
Why are you not running the Energy Dept of this country??? Everything you say makes perfect sense and I think most right – minded people ( those without blinkers or agendas) would agree IF they were allowed to hear this without the cries of “foul” from those in Government & Quangos.
Hi Kathryn, an interesting article. The Dogger Earthquake occurred towards the S end of the Central Graben, part of the complex network of rifts that underlie the N Sea and are instrumental in the formation of our oil and gas deposits. M 6.1 is fairly powerful, but it would be more sensible for the British Geological Survey to use the largest recorded on-shore earthquake. The tensional environment (rift, pull apart) tends to be less hazardous than the compressional environment (Fukushima) that can lead to giant tsunamis.
On the safety of civil nuclear, designs should be based on risk being As Low as Reasonably Practical (ALARP) but not incurring excessive cost.
I don’t go along with the above article, partly because it misses the point and fail to address the bigger issues. Regulatory reform might reduce some cost, but it’s tinkering with a technology which has no prospect of existing in a commercial market. This will “bake in” the following issues for decades.
I’m not a supporter of new nuclear power for the simple reasons that there are better alternatives, and nuclear power is not necessary today (maybe the position will change in a couple of centuries when technology will have move on in any case). In addition, the suggestion that I “could worsen climate outcomes” makes no sense to me (expanding the point might help).
It is no coincidence that the UK had a civil nuclear programme when the power industry was in the state sector (the CEGB), and when the UK had administered prices for power supply. In my view, this is where you are going when you push for new nuclear power stations – especially for a large share of supply. So I need to explain why I don’t consider civil nuclear power to be a commercial business, and why it is fundamentally a public-sector activity.
Nuclear power is not for limited liability companies and private markets (other than service providers). A private market has opportunity of market entry (invest because you want to make money and you are comfortable with the risks) and live with threat of market exit (closure if you are not competing and not making money).
It can be rewarding or it can be brutal, but the market is where there is a balance of private reward for taking private risk. Civil nuclear has no such balance. It will therefore never exist in anything approaching the above principles. As soon as a nuclear reactor and fuel is irradiated for the first time, we (and yes, I mean “we”) are left with activities which cannot go bust in anything resembling the commercial sense. Limitation of liability therefore cannot apply as a commercial concept, and the public sector (“we”) can never escape the role of “underwriter of last resort”. Nuclear funding plans for future liabilities doesn’t change this.
Civil nuclear will always need an administered price to “socialise” its risks, and this means the public is the main risk taker which leaves civil nuclear as fundamentally a public sector activity. Publicly-owned GB Energy and GB Nuclear are cases in point (they just might be a bit shy in admitting it).
The US has the Price Anderson Nuclear Indemnities Act. Why was the ever (and still is) necessary? Would nuclear operations have existed without this?
Some might suggest a private market can still exist alongside nuclear power stations, but I don’t accept this is realistic. Especially if the nuclear sector takes a large share of supply. It asks private investors to take market risk (as described above) when others cannot go bust. The UK CfD arrangement is a form of administered price arrangement (not quite as extreme as a protection against going bust), but the growing protected segment became a deterrent to other investors, and eventually led to the “capacity contract” another administered price. Today, there is pretty much nobody in UK power generation who invests without some form of administered arrangement, and it would be very difficult to argue that UK prices are cost competitive.
None of the above means I am a raging communist. I see Kathryn doing a good job in challenging some of the politically-selected winners in the technology contest, based on costs and technical merits. I therefore struggle to understand why she turns to uncommercial nuclear as though it is supposed to improve matters.
I’d rather see a new fleet of coal-fired power stations, with access to the international coal market (that is, NOT depending on opening UK mines if they are not internationally competitive). That’s what our international competitors are doing .
An interesting perspective and, yes, there is good reason for the whole of a social good to be in public ownership; the neoliberal views of the 1990s pretty much did away with the concept that the State and private enterprise should work in parallel, supporting each other. There was never an economic justification for the post-war nationalisation of many industries, but equally there was never a justification for Thatcherite whole sale privatisation of essential public goods, like power. Both are needed, but for ideological reasons the pendulum swung first too far left, then right.
As to your argument that we can never avoid society becoming the underwriter of last resort, that is true whether or not an industry is in public or private hands. Who ultimately picks is responsible for decommission and restoration of, say, a steel mill or an open cast mine? Who will pick up the tab if a wind farm operator becomes insolvent? The protections under planning law preventing decommissioning and restoration costs falling to the public purse are no where near as rigorous or financially onerous as, say, those applying to the offshore oil industry. That’s a situation which, in my mind at least, should not be allowed; certainly one that should not tolerated when developments are dependent on public subsidy.
Once commissioned nuclear plants can create a very stable cash flow over a period of decades. This should make them attractive assets for investors with long term liabilities.. The risk, particularly when nothing has been built for decades and everything is “first of a kind”, is the construction cost. Kathryn’s suggestion (made elsewhere) that government pays for at least the first few of a new series of reactors and then sells them strikes me as a good approach,. Government generally has access to cheaper capital than the private sector; it is the cost of capital (along with build time) that pretty much dictates the economics of major projects. A regular cash flow when operational makes projects easier to value, so government should be able to attain a fair price. And decommissioning liabilities can be handled, as at present, through the Nuclear Liabilities Fund,. The NLF has a special statutory status allowing annual contributions to be considered as opex (i.e. pre-tax expenditure) making contributions to it more tax efficient than in other industries, where decommissioning is considered a capital cost.
As an aside, that is one reason why the UK oil industry gets annoyed when people claim that decommissioning receives a subsidy from the tax payer. It doesn’t; decommissioning costs are treated in the same way as every other sector, carrying back capital costs against previously taxed profits and receiving a tax refund. If the government had allowed a scheme like the NLF for the oil industry that would never have happened.
Only a government could make malinvestments like Hinkley Point and Sizewell C (now claimed at £38bn for 3.2GW) , designed to serve a political purpose of pretending that wind is cheap. No-one else could possibly fund it: financiers would turn them down flat. Commercial nuclear is certainly possible, and has happened in the past in various countries. When we start getting SMRs the project costs are well within easy financing volumes.
When you look at the cost per effective GW, even on an up front basis, well chose nuclear is significantly cheaper than offshore wind. The risks have been regulatory, as Kathryn has explained. The other half has been the soread of false FUD to dissuade the public from support. We now have well establ8shedcprocedures for dealing with decommissioning and the long term handling of small volumes of high level waste.
Of *course* society is the underwriter of last resort. Often though the ways are complex. Take some large industry, imagine a top tier car manufacturer (evil because they produce fossil fueled vehicles obviously), do we let them go to the wall with no society bail out? Absolutely yes! Until you realise that 2/3 of the populations pensions are invested in them… Ah.. Now it’s starting to become more difficult, maybe you still let the company go to the wall, but society will somehow end up picking up the tab for the pensions.
So it’s not simply about the specific thing in question, it’s also about the web of dependencies – often invisible and not well/completely understood.. What about all of the suppliers to that company we’ve let fail? And their suppliers?
Energy is a difficult one, literally everything depends on energy. There are others, food supply – even though that’s typically a commercial enterprise (think rationing during wartime), clean water, sewage. There are likely others (sorry folks, iPhones don’t count). But start with just those and think of all the other things that depend on them. Dependencies, dependencies, dependencies….. It’s a complex web.
Some things are obvious – cheap reliable energy is key to all sorts of other pieces… Military security of the country from whoever your enemies are this week, NHS and response to a pandemic……… None of it works without a secure energy supply. Energy requires people to produce it, the people require food, water, heat, light, etc.. etc….
So what bits of a much bigger puzzle are basic social necessities that should be provided (or at least managed) by the state and not left to commercial whims?
I’m not a raging socialist either, but I do think there are certain things that probably should be managed for the common good of the country, not for the good of the shareholders of a commercial company. Which does bring you full circle to our pensions being invested in those same companies, so there’s no simple black/white answer. Certain political realities are there too, ‘Security’ – and that isn’t simply the armed forces, you want security of supply to sustain your population, their jobs/industries (and pensions). Energy security is a _very_ basic building block.
If our home grown stuff isn’t competitive due to high energy costs then it seems that we just outsource to some other place that doesn’t give a crap about using child/slave labour, or the environment, or H&S, or whatever the current adgenda is.
For ‘was never an economic justification for the post-war nationalisation’ probably true, but see ‘Security of…’ very oversimplification for a host of complex reasons.
To Jordan’s statement ‘there are better alternatives’, I’m all ears.. However it’s not sufficient to make a statemant like that, it has to be backed up by example that stands up to scrutiny (by Kathryn!) and satisfy all of the requirements, commercial and political. ‘Security’ of…. can mean lots of things and be really difficult to satisfy as it’s an intangible that’s only measurable against the current context, and in 20, 50, 100 years the current context may well appear completely bonkers.
Thanks for interesting comments from others, and I agree with very much of what has been said in reply. I will elaborate a couple of points.
Somebody suggested other countries have “commercial nuclear” activities. I don’t know of any without some form of public underwriting (my “underwriter of last resort”), and I gave the US as an example. Take away state underwriting, and see what happens to private sector willingness to get their hands dirty on civil nuclear.
Somebody suggested that all (or many) businesses socialise their legacy costs when they go under. Perhaps a fair comment, but remediation will usually be limited (time and/or value), whereas there is no way to quantify the liabilities of long-term nuclear waste management. Volume of waste is irrelevant, so calling it “small” doesn’t really mitigate the issue. Containment is extremely difficult to solve when the materials in question will change physically and chemically over many centuries. Find a private sector financial instrument which has a hope of lasting longer than the much-raided Egyptian pyramids, and you will have invented something truly astonishing. I haven’t seen a recent estimate of the cost of managing the UK’s future nuclear liabilities, but it will be many £billions, and expressed as an NPV with probably the “blue book” discount rate which is not a commercial investment rate of return.
Nuclear is often claimed to be “cheap”, but this claim rests on long-duration discounted cashflow models which therefore rests on some heroic assumptions about performance. In addition to timely delivery at the start of operation (with FOAK risk and a poor historic track record), these assumptions will include very high levels of reliable performance. Achieving that level of performance involves a lot of specialist knowledge and ready-to-deploy resources to address operational issues when they occur. You cannot just give your nuclear reactor a bash with the big mash hammer when it seems to be coughing and spluttering. Nuclear downtime is very expensive, and has to be minimised – this takes a huge support overhead. In fact, so huge that nuclear can only ever approach something that has a chance of being “cheap” if there is a very large fleet to pool resources around. Which means it has to dominate, the risks are high, and these are further barriers to entry.
Yes, there are better alternatives in the UK, and I stated my preference for a new coal-fired fleet of power generating units. The UK had a very valuable spark-dark spread fuel switching option until the coal-fired power stations were forced to close. (These coal-fired power stations were being taxed to death for CO2 emissions, but still had enough value to remain open the Government had to to take the brutal step of mandating their closure to create the gap in supply they wanted for ideological ends -all it achieved was a drive up scarcity and electricity clearing prices.) The dark-spark option gave the UK more choice in international fuel supply markets, with the ability to play-off the lowest of coal vs gas (in their GJ units). There is nothing wrong with modern clean coal-fired power stations with full abatement of particulates and sour gases …. unless we have some fear of those elusive “worsened climate outcomes”.
So it’s that dark-spark option that I’d like to see returned to the UK. Others have it, and we will never compete with them at the margin of electricity pricing until we can match them. Nuclear does nothing in this respect …. certainly nothing will happen for the next four or five decades if we try to build that large fleet.
Thanks anyway folks for the respectful replies.
Another brilliant essay. It would be interesting to see the same principles applied to the current debate about water and sewerage regulation. How much are the rest of us prepared to pay so that Fergal Sharkey can enjoy his fishing?
It does seem odd that some of the objections (and consequent delays) have been based on farcical scenarios. Such as the one by a member of “small fury animals” based upon an “argument from ignorance” fallacy about mud being contaminated and hence could not be dumped (near Cardiff, I think) or the ludicrous case of an annual 10 (approx) tons of fish being caught in the cooling water filters; I am not sure how such were allowed to be issues!
The lack of obvious transparency of the approval criteria (for the reactors) from either ONR or GBN makes it difficult to assess the reasoning.
The alarming delay in the certification of the (well-tried) Rolls-Royce reactors is perhaps more serious in its implications; unfortunately the reasons for these delays are not visible. In computer science complex systems are built from simple modules – each of which have testing procedures and criteria; thus simple (and safer) modules and easier development and integration tests.
Such a modular development allows for changes to be implemented at lower costs and more speedily – thus allowing the costs (including delays and testing) of improving systems to be reduced; delays in the approval (testing) severely impact the development as they make improvements too costly to make – an help keeps costs high ( by delays and by stopping innovative designs and manufacturing processes being included)
I do share a distaste with altering environmental regulators but given some of the strange (would they be classed as vexatious?) objections they have considered without too much criticism I appreciate the feeling that there wilder excesses need to be hobbled.
I’m 100% with you except for this bit (I added the CAPS):
“I have advocated for the inclusion of risk experts from the FINANCIAL SECTOR to join nuclear regulatory taskforces because they can help to break down this type of siloed thinking.”
Those dimwits were responsible for Credit Default Swaps and the 2008 Global Financial Crisis, and never suffered the consequences of their negligence. The aviation sector is a good choice though, maybe also IT (especially data center operators) – i.e. sectors where there are real consequences for those involved when the poop hits the propellor.
I think the key is that you need people from a different industry with a different viwepoint to offer perspective. Siloed thinking exists everywhere, in IT too.. You need people to challenge the ‘but that’s”the way we’ve always done it” mantra. One of the best ways to do that is to use someone who doesn’t do the thing you do and is able to look from the outside in.
My impression was that the “quants” (finance engineers) did warn of risks but were ignored. Feynman found something similar when reviewing the failure of the Challenger.
Not sure if this places real problem with senior managers or politicians….
I read that some now think the eventually cost of Sizewell C could exceed £100bn. If that has credibility then surely the project should be cancelled, and replaced by cheaper proven technology from Korea that can be built on time and on budget for perhaps 15% of the cost. Trying to demonstrate that wind is cheaper than nuclear is politics with unacceptable costs.
I have no deep understanding of the technology and likely cost of the projects that were being proposed by Nucleo, who recently decided to abandon attempts at securing a role in the UK. One thing is clear: the fact that they were planning to make high level fuel waste into fuel for their plants offered security of supply as well as burning up more troublesome residues – surely far better than the Miliband plan to bury them.
There is a recent government “Nuclear Regulatory Taskforce’s interim report” https://www.gov.uk/government/publications/nuclear-regulatory-taskforce
It makes some criticism of the complexity and resultant inconsistency of the regulators. And aims to address “culture of risk aversion and reluctance to challenge and debate, impacting costs and time, to ensure that risk management is proportionate; addressing complex and inconsistent regulations,..”
However it does not address issues of lack of transparency and accessibility (i.e. to general public) that are required for a reasoned and useful discussion and contributions from engineers and scientist. My feeling is that GBN could run and service a blog on this – though given their lack of interest in sharing or developing ideas with those not in their approved list of “stakeholders” I do not expect much useful from them….
Interestingly enough it mentions vexatious protests; are the inspectors capable of assessing or recognising these? – which would be better than a blanket ban on protests, by fiat.