149: NEWS - first new nuclear power station pre-application consultation launched

This is entry number 149, first published on 19 July 2010, of a blog on the implementation of the Planning Act 2008. Click here for a link to the whole blog. If you would like to be notified when the blog is updated, with links sent by email, click here.

Today's entry reports on the launch of the pre-application consultation for Hinkley Point C nuclear power station.

Proposed Hinkley Point C nuclear power station

EDF Energy, under the name of its subsidiary the NNB Generation Company Ltd (which I guess stands for 'new nuclear build'), has started the formal pre-application process for the authorisation of the Hinkley Point C nuclear power station.  The London Gazette notice can be found here - and note that a previous blog entry is being kept updated with all such notices. 

This will be the first nuclear power station in the UK since the application for Sizewell B was made on 1 October 1980.  The Hinkley Point C application is currently timetabled to be made in December 2010, and so there will be a gap of over 30 years between the next nuclear power station application and the previous one.

A short sidetrack on the Sizewell B application.  The application was made by the Central Electricity Generating Board on 1 October 1980, under the Electric Lighting Act 1909, enacted two years before Ernest Rutherford even established what an atom was made of.  That act was repealed in 1989, but was still used in the 1980s to authorise electricity generation.

A public inquiry was convened, with Sir Frank Layfield QC as the inspector and four assessors appointed on technical issues - Sir Christopher Foster (economics), Professor William Hall (nuclear angineering), Dr Jack Vennart (radiation safety) and Professor John Alexander (transport of radioactive fuel).  The inquiry sat at Snape Maltings in Suffolk for 340 days between 11 January 1983 and 7 March 1985.  At the time that was the longest ever public inquiry in the UK, but it has since been overtaken by the Heathrow Terminal 5 inquiry, which sat for 550 days between 16 May 1995 and 17 March 1999.  It could be said that the Campaign for the Protection of Rural England (CPRE), now a fixture of the environmental scene, first gained prominence at the Sizewell B inquiry.

The government issued its approval on 12 March 1987 (see Hansard extract here).  Thus, the time taken from application to approval was just under six and half years.

Compare and contrast with Hinkley Point C, which is to be authorised under the Planning Act 2008.  If it gets decided between the date that the Nuclear Power National Policy Statement (NPS) is finalised (expected early 2011) and the Infrastructure Planning Commission (IPC) is abolished (expected April 2012), then those six and half years will have to be crammed into a single year.  If the application is indeed made in December 2010, then the decision will be during that year-long window.  Even if the decision is taken before the NPS has been finalised or after the IPC has been abolished, then there will only be an extra three months allowed in the timetable.  It is possible to lengthen the timetable, but Sir Mike Pitt, chair of the IPC, will be reluctant to do this, as it is he who has to confess to the Secretary of State that the timetable needs to be extended.

It is likely that the IPC will appoint three commissioners to examine the application, and it is also open to the IPC to appoint assessors as for Sizewell, and may very well cover the same four subjects in doing so.

As its name suggests, Hinkley Point C will be the third nuclear power station at Hinkley Point in Somerset.  Hinkley Point A was a Magnox reactor that closed in 2000, and Hinkley Point B, a pair of Advanced Gas-cooled Reactors (AGRs), is operating but due to close in 2016.  Hinkley Point C will consist of two European Pressurised water Reactors (EPRs).

EDF Energy published its announcement of the start of its pre-application consultation to the general public on 9 July, and the consultation will close on 4 October 2010.  The consultation website is stated to be www.edfconsultation.info, but to get to the plans and other documents relating to the application, you need to click on 'Hinkley Point' in the left hand column and then 'Public documents' across the top (or just go straight here).  I think that the 442MB Environmental Appraisal, Volume 3, is the largest PDF I have ever seen.  It has also been compressed and broken down into chapters for ease of use, though.

Of interest is a document towards the bottom setting out the 'planning requirements and obligations' that EDF is offering up.  These are equivalent to conditions attached to a planning permission and elements of a section 106 agreement.  Promoters of projects are advised to submit these with the application rather than wait for the local authority or authorities, or the IPC, to impose them.

In tandem with the public consultation, EDF has also issued a second 'Statement of Community Consultation' (SoCC), which sets out how they propose to consult the community in the vicinity of the project.  They are adopting a five-mile radius for the most focused consulation, with events also held in surrounding towns.  The SoCC was first published on 29 June and the first public exhibition was on 10 July, so EDF have given a little more notice than the government did when it consulted on the NPS.  There are two public exhibitions yet to take place, on 8 and 11 September in Bridgwater (at Morrisons and Asda respectively - very balanced).  The documents can also be viewed at EDF's Bridgwater office from tomorrow onwards.  There will be other workplace exhibitions, workshops and focus groups, to be advertised in the local media.

Previous entry 148: NEWS - second consultation announced on energy National Policy Statements
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Anonymous's picture
01 Aug21:11

Legal Requirements

By Anonymous

It would be interesting if you were to consider if these consultation documents met all the legal requirements in a similar way to your comments on the validity of the NPS consultation.

It would be particularly interesting to read your thoughts on whether this is a "proposed application" and the extent to which the "preliminary environmental information" requirements have been met.

Angus_Walker's picture
05 Aug15:24

Reply to comment

By Angus_Walker

Thank you for this comment - it would be helpful if you could make yourself known to me.

I have not considered the consultation documents in detail and would not wish to comment on the content of the consultation anyway. In terms of process, the main area where mistakes have been made in consultation so far is omitting local authorities that need to be consulted. By my calculations West Somerset and Somerset are the host authorities and they have 15 neighbours between them.

I don't see why this wouldn't be a 'proposed application'. 'Preliminary environmental information' is a tricky concept because the EIA regulations do not deal with it properly, only mentioning it once, in reference to the SoCC, but I think that basically it means 'the information to be included in the Environmental Statement that has been prepared so far'.

Anonymous's picture
22 Jul11:51

Timescales for Hinkley C Planning Application

By Anonymous

I was struck by the suggested timescales from planning application to approval for Hinkley C being 12 – 15 months. From my experience in projects and programmes, I think this is a very good timescale for the dedicated teams from the Inquiry and the participating organisations, which is likely to optimise the quality of the output.

However, 12 – 15 months is an awkward timescale for the organisations themselves, which the dedicated teams represent. It is generally too long for an organisation to reprioritise away from its normal activities, but too short to build the work into its yearly planning cycles, so there will be constant tension between supporting the Inquiry teams and doing the day job.

A major part of my role as a Programme Manager is ensuring that the dedicated (project) teams have the support they need in order to interact most efficiently and effectively with their broader organisations. The sort of practical steps I would be looking for from the participating organisations would include:-

• Putting dates in diaries – the key strategic decision makers will need to meet regularly to be briefed by, and to direct, the dedicated teams. Space in their diaries is notoriously difficult to find and specific meetings need to be booked now, at least once a month but every fortnight is recommended.
• Committing resources – get adequate resources committed well in advance. Dealing with resource shortages later is costly and a time-consuming distraction for the dedicated teams
• Addressing the people issues – people will delay things, either blatantly or subtly, if they are not comfortable with the personal change which one or more of the possible outcomes will bring. In parallel with the mechanics of the inquiry itself, each organisation will need a workstream of activities to prepare its people for the possible outcomes.
• Monitoring progress – each organisation will need to measure progress and success in a way which is granular and meaningful for them. It should not be too difficult for the dedicated teams to relate progress measures used by the Inquiry to the progress measures used by their organisation.
• Planning – detailed planning of activities supporting the Inquiry will be the responsibility of the dedicated teams. An exception/change handling process will be needed to ensure a rapid response to unexpected events. It is also important for the broader organisation to plan early for the activities which will follow the Inquiry, planning different scenarios for each of the possible outcomes. This will assist in preparing the people in the organisation for the changes ahead. As risk mitigation activities are identified and agreed, they should be added to plans so that budgets and resources are secured.

I understand that the IPC will manage the direct interactions between the dedicated teams from participant organisations and the Inquiry. It does not seem clear who, if anyone, will be carrying out the broader Programme Management / Programme Assurance role which supports the interactions between the dedicated teams and their organisations. If this support is not provided then it is very unlikely that the timescales can be achieved.

Chris Ilett
chris@tibbsmorgan.com

Angus_Walker's picture
05 Aug14:22

Reply to Chris

By Angus_Walker

Chris,

Many thanks for your comments. You say that in some ways the 12-15 months is too long for the organisation to build into its processes. That may well be, but this is a much shorter timescale than has existed for the authorisation of any comparable project before, and this will be the main issue. The intensity of activity that will be required by the promoter in handling the examination process while simultaneously negotiating with the objectors will be extremely challenging.

If EDF need a programme manager, they know where to come!

Regards

Angus Walker

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