HINKLEY POINT C PRE-APPLICATION CONSULTATION 2 NEW NUCLEAR DEVELOPMENT AT HINKLEY POINT 2.1 Introduction 2.2 The Need for Nuclear 2.3 The Suitability of the Hinkley Point Site 2.4 Local Site Selection HINKLEY POINT C PRE-APPLICATION CONSULTAtion – CONTENTS 2 NEW NUCLEAR DEVELOPMENT AT HINKLEY POINT 2.1 Introduction 2.1.1 The Government’s draft Nuclear NPS will consider the need for and siting of new nuclear power stations at a strategic level. EDF Energy's DCO application will therefore not address these issues, but will focus on the potential local impact of the proposed development and the measures taken to minimise these so far as is reasonably practicable. EDF Energy will address this by providing detailed information on the development proposals together with a full assessment of environmental impacts in the Environmental Statement. Responses to this pre- application consultation will also play a key part in helping the IPC assess whether the development proposals on and off-site are appropriate to grant consent. 2.1.2 However, although this consultation is not about national energy policy or strategic site selection, EDF Energy believes it will be helpful to those reading this document to have a summary of these issues and the processes under way which address them. This section sets out to provide this. 2.2 The Need for Nuclear 2.2.1 EDF Energy believes there is a strong case for new nuclear development in the UK. The challenges of energy security and climate change pose enormous threats to society. Government has recognised the importance of tackling these challenges and has set out a course for transition to a low carbon economy. 2.2.2 Electricity is central to this transition, and is likely to be even more important in the future as it could provide a means of enabling low carbon transport and heating, as long as there is a means of generating low carbon electricity when and where it is needed. 2.2.3 The Government’s White Paper on Nuclear Power3 makes the case that it is in the public interest that new nuclear power stations should have a role to play in the future electricity generating mix for the UK alongside other low carbon sources. The Government’s Low Carbon Transition Plan4 states that new nuclear generation is needed as part of a low carbon energy mix and that there is a need for early delivery of new nuclear power. 2.2.4 Nuclear power is the most affordable, large-scale, low carbon generating technology currently available that can provide secure supplies of electricity for the UK. It is a technology that the UK has successfully exploited for more than 50 years for electricity generation and at its peak in 1998 accounted for 26% of UK generation. However, as the older nuclear power stations reach the end of their lives, this share has declined to below 15%. 2.2.5 Unless action is taken now to invest in new nuclear power stations, carbon emissions from electricity generation are likely to rise and energy security will be at increased risk. It is on this fundamental basis that EDF Energy believes there is a pressing need for new nuclear development. The proposed nuclear power development at Hinkley Point C will provide more than 6% of the UK’s electricity requirements. This will represent a significant contribution to the Government’s energy policy aims in its own right. a) Regulatory Justification of the UK EPR Reactor Unit Design 2.2.6 A regulatory process which is running parallel with the planning process is the justification necessary for a new nuclear practice to be adopted. Justification of Practices Involving Ionising Radiation Regulations 2004 (Justification Regulations) require a demonstration that the benefits of a new practice outweigh any detriment to health. 3 Department for Business Enterprise and Regulatory Reform (BERR) (January 2008) ‘Meeting the Energy Challenge – A white paper on nuclear power’ 4 HM Government (July 2009) ‘The UK Low Carbon Transition Plan, National strategy for climate and energy’ HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 1 | 11 2.2.7 The Nuclear Industry Association (NIA) has applied to Government to make the case that a practice covering the UK EPR reactor unit is justified. The Government has already consulted on this application and expects to consult on its draft decision5. A positive decision by the Justifying Authority (DECC) would satisfy the European and UK legal requirements to enable the UK EPR design to be used in the UK. This is necessary to allow the proposed development at Hinkley Point C to proceed. b) Alternative Solutions to Nuclear 2.2.8 The consideration of alternative solutions to nuclear power (expected to be assessed by Government in the draft Nuclear NPS) against the core objectives of energy policy which are to maintain security and affordable supplies and to help make the transformation to a low carbon economy. i) Renewables 2.2.9 The Government is committed to delivering 15% of final energy consumption from renewables by 2020, which implies around 30% of electricity from renewables compared with 5.5% in 2008. This is a demanding target and continued growth in deployment of renewables, primarily on-shore and off-shore wind and biomass, is dependent on financial incentives. The Government is also undertaking a feasibility study on various options for exploiting tidal power in the Severn Estuary, which could provide up to 5% of the UK’s electricity. Other forms of renewables, such as photovoltaics, wave and tidal power are much more costly at present and unlikely to make a significant contribution unless there are major developments in terms of the available technology. 2.2.10 Most renewables are intermittent in terms of electricity production, which sets a limit to the proportion of electricity generation that they can provide. A secure and reliable electricity system needs to include generation capable of continuous running, as well as more flexible output to meet the peaks and troughs of demand and the variability and vulnerability of renewable generation. ii) Carbon Capture and Storage 2.2.11 Coal and gas are likely to have to remain within the UK’s generation mix for the foreseeable future. It may, however, prove feasible to capture the carbon dioxide produced from these forms of generation and store it to avoid harmful emissions. At the moment Carbon Capture and Storage technology has not been proven for a full scale power station and it cannot be regarded in the short-term as a credible alternative to nuclear power, as a low carbon generating technology for immediate deployment. iii) Reduction in Demand 2.2.12 Measures to improve energy efficiency and reduce energy demand are also being promoted by the Government. However, demand for electricity is not expected to fall significantly in the short- term and is expected to grow overall in the medium to long-term, driven by economic growth and an increased role for electricity in providing low carbon energy for heating and transport. 2.3 The Suitability of the Hinkley Point Site a) New Nuclear at Hinkley Point 2.3.1 EDF Energy has nominated the Hinkley Point C site into the Government’s Strategic Siting Assessment (SSA) process. The nomination provided information on the site in response to a range of strategic criteria set by Government. 5 The draft Decision Document on regulatory justification of the UK EPR design is scheduled for consultation in Autumn 2009. At the time of printing this document the draft Decision Document had not been issued 12 | HINKLEY POINT C PRE-APPLICATION CONSULTATION – STAGE 1 2.3.2 EDF Energy believes the site is strategically suitable and will form part of national policy. The following factors, though not exhaustive, outline some of the key attributes of the site: i) Existing Nuclear Operation 2.3.3 There has been a nuclear power station operating at Hinkley Point since 1965 and the local community is familiar with the technology and the employment opportunities it can offer. The Hinkley Point Power Station Complex is a major local employer. New nuclear development adjacent to the existing site will provide socio-economic continuity to the local area. ii) Development Alongside an Existing Use 2.3.4 Development adjacent to the existing Hinkley Point Power Station Complex also minimises the landscape impact as the physical characteristics of the area are similar, compared with an equivalent development on a greenfield site. Co-locating alongside existing facilities provides other benefits including the ability to use existing infrastructure, for example access roads and transmission lines. iii) Planning Precedent 2.3.5 In 1990, planning consent was granted for a single Pressurised Water Reactor (PWR) on land within the proposed Hinkley Point C site. Although construction did not proceed due to commercial factors, the planning process examined the suitability of the site in detail and the Inquiry Inspector, Michael Barnes QC, recommended to the Secretary of State that consent should be granted, subject to conditions. EDF Energy believes this is an important indicator of the suitability of the site for new nuclear development. iv) Technical and Safety Conditions 2.3.6 Hinkley Point is well connected to the National Grid transmission network by means of four 400kV and two 275 kV circuits. New local connections from the Hinkley Point C site to the existing lines will be needed. It should be noted however that it will be necessary to undertake reinforcement to the transmission network further inland to accommodate the output from two UK EPR reactor units, in addition to that from the existing Hinkley Point B Nuclear Power Station and other new electricity generation that is likely to be connected in the region (see paragraphs 3.2.10 – 3.2.13).