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Policy Brief
EVIDENCE FROM SPRU TO THE
BRADWELL B PRE-APPLICATION
CONSULTATION
A: SUMMARY AND RECOMMENDATIONS
1. This evidence reviews the status of UK Government policy justication for its presently intense commitment to new nuclear
build, as compared with alternative low carbon energy strategies. This is a central issue for the present Consultation, because it is
a presumption that this justication is adequate, that forms the basis for the remarkable restriction on the Consultation scope
– effectively ruling out crucial general questions concerning the overall merits of the case for building a new UK nuclear power
station.
2. Despite uncertainties and latitude for many different reasonable informed views, what this evidence shows is that the
comparative case for new nuclear build is actually extremely poor. What are also substantiated, are a series of further
serious grounds for concern over the scope, quality and orientation of extant efforts over the past seventeen years, to justify this
persistent ofcial attachment to nuclear power. It emerges that major reasons for this intense commitment are strikingly
different to what is declared.
3. It is in light of this broad background, that key ofcial bodies with core mandates directly in this eld – including the National
Audit Office and the House of Commons Public Accounts Committee – have repeatedly strongly criticised Government for
failing to publish rigorous justication for nuclear policy.
4. On the grounds that the conditions justifying the Consultation remit are not in place, then, we therefore respectfully recommend
that the present proceedings be formally suspended until Government delivers on the calls from its own responsible
bodies that these conditions for the Consultation remit be fulfilled.
SPRU| JUNE 2020
5. The authors work in one of the UK’s leading energy policy
research institutes1. Over the past twenty-ve years, we
have witnessed many radical changes, but also a number
of oddly enduring patterns. In tension with well documented
evidence, wider international trends and growing practice in
other countries, one of these is the remarkably persistent
intensity of official UK policy entrenchment in favour
of nuclear power. This implacable attachment applies
across a succession of otherwise politically contrasting
Governments2.
6. The partisan bias in this position is evident, irrespective
of the perspective from which it is viewed. It is, for instance,
not necessary to be a nuclear critic to appreciate that a
UK Chief Scientist’s statement that “there is no alternative
to nuclear power”, is seriously decient as a balanced
reection of evidence based analysis3. When Ministers
declare that “investing in nuclear power is what this
Government is all about for the next twenty years” or that
there is “no limit” on the capacity the Government is be
prepared to build, it is similarly clear that something is
odd about the intensity of UK policy attachments to
nuclear power4.
7. The eccentricity of this position is also visible in other
ways – with many examples of this partisanshp shown
by Ministers or senior ofcials, only during their tenure
in ofce5 and not in their personal views either before or
afterwards6. Also evident, is a disturbing lack of national
capacity properly to interrogate this policy bias. Despite
the integrity and best intentions of individual professionals,
remits and framings of statutory procedures like the present
consultation remain – like wider policy processes – seriously
tilted.
8. For instance, there is the general mandate underlying
the present consultation exercise. This hightlights that
because “it is government policy that new nuclear power
stations should play a significant role in the future generation
of electricity in the UK”, the present consultation shall not
be permitted to take into account questions regarding “the
principle of building a new nuclear power station”7. Yet, it is
precisely this eccentrically assumed unconditional national
necessity for nuclear power, which forms the single most
important driver for approving the present application. And it
is this general single-sector bias that remains so remarkably
entirely unsubstantiated by rigorous policy analysis or wider
democratic accountability.
9. Among many severe criticisms of this state of affairs
are highly unusual interventions both from the National
Audit Office (NAO)8 and the House of Commons Public
Accounts Committee (PAC)9. These bodies have drawn
attention to the indefensibly long period that has passed
since the last substantive justication in the public domain,
of the general UK Government attachment to nuclear
power10.
10. The last full UK Energy White Paper (that was not at a
key stage successfully challenged by judicial review for being
inadequate), was published in 200311. Seventeen years
ago, this was at a time when the comparative economic
and strategic position of nuclear power was far less
disadvantaged than it is now by comparison with alternative
zero carbon renewable and energy service options. Yet even
in 2003, this last full general Energy White Paper found
that nuclear power presents an “unattractive” option
for the UK12.
11. In one of the most striking volte-faces in major UK
Government policymaking over the past half century – which
itself remains remarkably under-interrogated – this 2003
Energy White Paper was followed after an unprecedently
short interval in 2006, by a far more supercial further
review, revising the nuclear power position13. This further
Energy Review followed a period of very intense activity in
UK defence policy, with regard to the dependence of UK
military nuclear industrial capabilities on a continuing
civil sector14.
12. Key in preparing this later more supercial 2006 Energy
Review, was a private Number 10 advisory group, of which
full membership still remains undeclared and from which
no evidence or other documents have ever been published.
The secrecy of this process has been criticised even by
nuclear proponents15. It was on this basis, that the then
Prime Minister declared that “nuclear power is back with a
vengeance”16.
13. The analysis and consultation undertaken for this
more cursory and secretive 2006 Energy Review, was far
less substantial than the two-year process undertaken
for the 2003 Energy White Paper. Indeed, the House of
Commons Environmental Audit Committee noted of the
2006 Review that “the Government has failed to clarify the
nature of the review” and that “…the manner in which it is
being conducted appears far less structured and transparent
than the process by which the [2003] White Paper itself was
reached”17.
14. When the awed process running up to the 2006
Energy Review was duly challenged by judicial review,
the verdict (strikingly for a white paper) found in favour of
the complainants18. Yet the then Prime Minister simply
convened a further similarly rapid response and stated
“[this] won’t affect policy at all”19.
15. So, the judicially criticised and relatively insubstantial
2006 Energy Review reversed the position on nuclear
power taken in the far more deeply researched and widely
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
B: POLICY BACKGROUND
consulted 2003 Energy White Paper. No specific evidence
or development was pointed to, such as to justify this
shifted position20. The military rationales so intensely
advocated in defence policy during this period, remained
entirely unreferred to21.
16. Since then, global trends in rising costs and
deteriorating performance on the part of nuclear
power, and steeply growing relative competitiveness and
viable resources on the part of renewable energy, grid
management and energy storage have strongly underscored
the seriously unfavourable picture for nuclear power already
documented in the 2003 Energy White Paper22. Yet it is
this picture, which the Government has resolutely failed to
address in any full detailed energy policy justication over
the past 17 years23.
17. It is this situation that bodies like the NAO and PAC
have severely criticised in light of continuing growth in the
comparative disadvantages suffered by nuclear power. It is
on this basis that these duly responsible bodies have called
upon Government to revise and publish a formal strategic
case for new nuclear power24. Yet with the Government
remarkably persistently failing to do this, it is this
flawed basis that underpins the partisan mandate
imposed on the present inquiry simply to assume the
merits of nuclear power.
18. Under extraordinary circumstances like this – where
a particular partisan sectoral interest is evidently being
imposed in agrant disregard for due processes of policy
rigour and democratic accountability – a clearly over-
riding responsibility arises with regard to the present
consultation exercise. In short, it is a duty of all involved
actively to question a circumscribed remit that risks
seriously biasing the outcomes.
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
C: WIDER STRATEGIC CONTEXT
The economics and wider strategic performance of
diverse renewables and their associated grid and demand
management technologies have been advancing at an
accelerating rate28, with costs falling precipitously and
developments proceeding at a pace well beyond even
proponents’ earlier projections.
21. Take for instance, the status of offshore wind and solar
power. The economically realisable UK resource in these
two renewable options alone is clearly sufcient over time,
to maintain a supply that far exceeds foreseeable
national energy needs – including shifts towards electric
mobility and heating that are much needed for other
reasons29. Costs have plummeted far faster than ofcial
projections30. Despite measures to slow and restrict the
pace of development, these markets have expanded far
faster than predicted31.
22. As in any industry – especially one undergoing
transformation at this pace – many technical challenges
and uncertainties remain. But the speed with which these
challenges are being resolved in the renewables sector
contrasts starkly with the pattern of rising costs and
escalating problems in the nuclear sector. For instance,
measures to address intermittency and seasonal contrasts
in energy demand are already available at well below the
existing cost advantage of renewables over nuclear power32.
And this gap is growing fast.
23. Beyond wind and solar power, a host of more diverse
renewable energy, grid management, distributed service,
smart management and energy efciency measures are
also becoming available33. Taken together, these non-nuclear
engineering and organisational innovations are presenting
the UK, for the rst time in its industrial history, with the
opportunity to develop far more rapidly than a nuclear
programme, a cheap, diverse, secure, zero carbon
renewables-based energy system sufficient to meet all
emerging needs.
24. With regard to the crucial issue of employment, UK
Government statements are especially problematic – being
repeatedly restricted simply to noting the overall numbers
of jobs associated just with envisaged nuclear investments
alone34. That this should be thought a serious contribution
to debate is itself a sign of the kind of bias documented
above. It is obvious that any large-scale investment will
result in job creation. The salient issue lies not in
asserted numbers for any single investment option,
but in the comparative job-creation potential of each
individual option under rigorous comparison with
available alternatives.
25. When such evidence is analysed comparatively, the
nuclear case again emerges as far from favourable. Jobs
in the UK renewable sector already surpass those
19. The conclusions summarised above are further
underscored when detailed attention is given to the wider
strategic context for the comparative current position of
nuclear power in relation to available alternatives – which
the present consultation remit so unjustiably excludes
from consideration. In short, worsening comparative cost,
resource, employment and strategic disadvantages on
the part of nuclear power are prominent on the global
stage25. With particularly large and competitive renewable
resources and no internationally leading nuclear equipment
vendors, the predicament is especially acute in the UK26.
20. Around the world, nations without ambitions or
existing commitments to nuclear weapons or their
nuclear-powered military delivery systems, are
overwhelmingly turning away from nuclear power27.
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
associated with nuclear and this are continuing
to grow35. With a far greater existing UK comparative
advantage in renewables than in nuclear power; with global
nuclear markets seriously contracting; and with renewable
markets growing very fast; the export opportunities are
further significantly more favourable for UK renewable
jobs than for UK nuclear jobs36.
26. Yet despite this remarkably declining outlook, the
intensity of UK Government commitments to nuclear
infrastructures has remained strangely constant over time.
In a period when other countries with far more successful
and larger scale nuclear engineering industries are
completing rapid nuclear phase-outs37, UK governments
continue to proclaim a ‘nuclear renaissance’ – as if this
were a self-evident end in itself38.
27. The remarkable bias evident in UK policy statements
is made more concrete in a discrepancy between UK policy
measures enacted in support of nuclear power on the one
hand, or renewable energy and energy efciency on the
other. Around the same time that loan guarantees and
additional investment for nuclear were being announced in
201539, for instance, support for renewables was effectively
retracted40. Several support mechanisms for renewables
and energy efficiency were abruptly halted, leading
international commentators to question the ‘puzzling’
direction that UK energy policy seemed to be taking41.
28. These increasingly idiosyncratic developments are
leading the UK to become a growing world anomaly.
Despite a succession of setbacks (and lessons of history
concerning the dangers of fragmented nuclear development
plans), a bewildering diversity of nuclear projects stagger
on alongside the present plans for Bradwell, variously
championed by French, Japanese, Chinese – and (most
recently) UK defence interests. That the Bradwell B project
is beset with potentially prohibitive strategic foreign policy
problems, adds to the oddity that such incoherently-diverse
and manifestly problematic options are being pursued42.
29. In a further complication, diminishing global nuclear
orders are leading many international nuclear rms
elsewhere to be recognised as nearing insolvency43.
It is disproportionately in the UK that this ailing global
industry seeks to nd a market44. Yet despite holding no
significant track record in international civil nuclear
sales, UK defence suppliers now declare aims to enter
into this diminishing global market, by proposing an
entirely new and untested military-derived small modular
nuclear reactor design45.
30. With the picture so stark, it is not as if evidence for
concern over the above trends is undocumented in the
UK. Although typically relegated to the margins of national
energy policy communities, independent experts are
clearly on record as repeatedly pointing out all these and
other difculties. For example, poor performance and
even worse trends over time have been continuously
and robustly documented with respect to: nuclear
energy costs46; the comparative case for zero carbon
alternatives47; the potentialities for catastrophic
accidents; and the practical insolubility of waste
management challenges48.
31. Yet, despite the wider comparative strategic positon
of nuclear power becoming rapidly more unfavourable,
official UK commitments to nuclear power have
remained effectively unchanged. Data and appraisals
highlighted in high-level policy documents have become
increasingly detached from wider energy market analysis49.
Ever more ambitious new UK nuclear infrastructure
programmes grow, despite a persistent track record
(distinctively bad in the nuclear sector) of failure to deliver
on early promises50.
32. Numerous further eccentricities remain seriously
under-interrogated in official UK nuclear policy. For
instance: the recruitment of senior policy advisors. Despite
strong UK capabilities in energy policy analysis, individuals
have been selected for ‘scientic advisory’ positions in
this eld, who have no background at all in energy issues.
In the year of the volte-face discussed above (2006),
one such departmental chief scientist unprecedentedly
gained resources to publish in a freely-released and
widely publicised book, a series of eccentric statements
deprecating renewable energy technologies and falsely
implying that viable national renewable energy resources
are insufcient to power the UK51. Even at the time, these
claims clashed with available Government data. In less
than a decade, they have been manifestly refuted even by
unfolding events52. Yet neither this episode nor other similar
examples of bias are ever properly scrutinised.
33. Against this background, perhaps the most pressing
questions concern how and why it is that such an
anomalous situation could possibly continue? With the
starkness of these eccentricities in UK nuclear policy
processes being rather hard to believe, there are dangers
that the sheer severity of the problem might itself become
a major impediment to resolving it. But there is actually
no shortage of available evidence that helps clearly
to explain this situation. Indeed, it is notable that the
reasons for these eccentricities are openly provided by
ofcials and robustly documented in academic literatures53,
parliamentary deliberation54 and intermittent press
reports55. What is especially disturbing in this regard, is
that this underlying picture is so generally ignored in
mainstream UK energy policy debates and wider media
discussions.
34. The cause of this otherwise-inexplicable state of affairs
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
does not seem to be that UK policy processes are somehow
unable to grasp the transformed conditions of UK and
global energy markets. A key reason evidently lies instead
in that ofcial UK nuclear attachments are actually largely
driven by signicantly different rationales to those that are
formally declared (but which remain so tellingly unjustied).
In short, what is evidently strongly driving this situation, is
the openly unconditional priority attached by influential
elements in UK political culture to the perceived status
of the UK as a military nuclear power56. Without civilian
nuclear infrastructures, costs of maintaining this military
status are recognised to be prohibitive57.
35. Leading gures have long emphasised UK nuclear
military capabilities to remain essential “whatever the
cost”58. But grave concerns are now evident in military
circles, that these costs have now become too high to be
publicly supportable59. So, although under-discussed in the
energy eld, it is political pressures that are very clear in
defence strategies that are evidently (at least partly) driving
UK civil nuclear policy.
36. In short, implacable ofcial commitments to retaining
nuclear power in UK electricity supply (despite its cost),
is a way to ensure that electricity consumer revenues
are channelled into supporting a joint civil-military
national nuclear industrial base (including specialised
skills, training, research, design, regulatory, engineering and
special materials capacities) that relies indirectly for funding
on civil nuclear new build60.
37. This situation need not be taken to imply a narrow
‘conspiracy’61. It reects underlying political forces more
than individual agency. To the committed interests involved,
it is likely viewed simply as an elegant solution to an
intractable problem. Associated levels of secrecy are
routine in military nuclear affairs.
38. Despite the secrecy, there is much general evidence
for a growing ofcial priority attached to linking UK civil and
military nuclear activities. Repeatedly acknowledged by
ministers62 this was directly defended by a key responsible
ofcial under questioning by the Public Accounts
Committee63. Appearing repeatedly in national media,
detailed analysis by the authors (that has not been
refuted) highlights how this amounts to a hidden
subsidy64. Yet the massive economic implications remain
more widely entirely undiscussed65.
39. What is in effect happening, is that ordinary UK
electricity consumers are funding a major hidden de
facto subsidy of many tens of billions of pounds to
military interests. In this way, otherwise insupportable
costs of the military nuclear industrial base are covered
outside a hard-pressed defence budget, entirely off the
public books and – in absence of energy policy justication
– conveniently concealed from due scrutiny.
40. Whatever position is taken on pros and cons of
civil or military nuclear technologies, the lack of ofcial
energy-specic analysis and the under-scrutinised
intensity of UK Government bias towards nuclear power,
are a national embarrassment. That key drivers of this
bias are so obvious but so under-discussed is even
more troubling66. That UK media, policy and academic
institutions are failing adequately to interrogate this
situation, raises disturbing questions about the health of
British democracy in the widest sense67.
D: CONCLUSIONS
41. It is in the interests of citizens and stakeholders in
the Bradwell area – as in the rest of the country – that
these wider issues be subject to fair scrutiny. If the
UK Government and wider policy processes had shown
themselves to be open to justifying this commitment, then
it might be reasonable that local level consultations be
constrained by it. The circumscribed remit for this present
consultation might in this event be justied. But (as a
variety of statutory and parliamentary bodies have
noted) there is actually a serious deficit of rigorous,
transparent or accountable policy attention on these
wider issues at national level.
42. It is in this light, that our evidence points to a
duty in the national interest that we believe falls on all
involved in the present consultation exercise. Officials,
expert witnesses, news reporters, policy analysts,
stakeholder representatives, academic researchers,
as well as members of the public at large, all share a
responsibility in the public interest of healthy policy
making and robust energy strategy. This is to question
both the present unjustifiably closed remit and a wider
political environment, that are seriously biasing UK
energy decision making, incurring massively excessive
costs, and undermining UK democracy.
E: RECOMMENDATIONS
43. A feature of the remit for the Bradwell B Pre-Application
Stage One Consultation, is that consideration is excluded
for the comparative strategic case for nuclear power,
as compared with other zero carbon energy options.
This is on grounds that such issues are adequately dealt
with by national policy making processes. But it is clearly
documented in this evidence, not only that this condition
remains unfullled, but that there arise from this, important
implications that are directly material to the Consultation
findings.
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
44. That this grave situation pertains, has been shown
(inter alia) by a number of high-prole national governmental
bodies with mandates directly in this eld – including the
National Audit Office and the House of Commons Public
Accounts Committee – who have repeatedly strongly
criticised Government for persistently breaching its
responsibility in this regard in unprecedentedly protracted
and serious ways.
45. A clear recommendation therefore emerges on the basis
of the evidence presented in this submission. This points to
a duty and a responsibility on the part of this Consultation,
that is at the same time formally grounded in its own
remit and demonstrably justified in ethical and wider
substantive policy terms, as well as in the manifest
interest of citizens in the Bradwell area and throughout the
UK more widely.
46. On the grounds that the conditions justifying the
Consultation remit are not in place, then, we therefore
respectfully recommend that the present proceedings
be formally suspended until Government delivers on
the calls from its own responsible bodies that these
conditions for the Consultation remit be fulfilled.
1. The Science Policy Research Unit (SPRU), is located in the
Business School at the University of Sussex, Brighton.
With over 50 years of experience, SPRU is internationally
recognised as a leading centre of research on science,
technology and innovation policy. The Sussex Energy Group
(SEG) of which both authors are members (one of us for more
than twenty ve years), is one of the oldest energy research
groups in the United Kingdom and has conducted policy-
relevant research on a number of topics including extensive
research on all areas of nuclear power policy (see Johnstone
2016 for a brief overview).
2. Since the UK’s rst nuclear programme in 1955, There has
been no government (Conservative, Labour, or Coalition), that
has shifted from a rm commitment to nuclear energy. This
can therefore be considered to be the single most consistent
feature of UK electricity policy for the past seven decades.
As we discuss in this document, there is only one moment in
this long period (as a result of an unusually exhaustive and
unprecedentedly open white paper appraisal and consultation
process ending in 2003), when there was ever any serious
publically-documented ofcial consideration for not commiting
to nuclear power – by the Labour Government of Tony Blair.
However this was quickly reversed. It is only the devolved
Government of Scotland that has since 2008 eschewed
commitments to new nuclear power, pursuing ambitions for
100% renewables in electricity production.
3. In 2006, Sir David King intervened with an article in The
Independent outlining that “we have no alternative to nuclear
power” (King, 2006). In 2014 King conceded that in fact
nuclear may not be ‘needed’ after all (Lean, 2014).
4. Challenged on the agship UK national radio news programme
in March 2016, for instance, former UK Energy Minister Amber
Rudd clearly expressed the intensity of this position, in stating
that “investing in nuclear is what this Government is all about
for the next twenty years” (BBC Radio 4, 2016). Elsewhere,
the present Secretary of State for BEIS, Greg Clarke has said
in the past that there is “no limit” on how much new nuclear
capacity the Conservative Party would be prepared to build in
the UK (Greg Clarke quoted in Collins 2010).
5. There are many examples of this. One is discussed in endnote
3 above. Another striking example is that of Chris Huhne of
the Liberal Democrats. In 2007 Huhne stated that: “Ministers
must stop the side-show of new nuclear power stations now.
Nuclear is a tried, tested and failed technology, and the
Government must stop putting time, effort and subsidies into
reviving this outdated industry. The nuclear industry’s key skill
over the past half-century has not been generating electricity,
but extracting lashings of taxpayers’ money”. In 2010, now in
ofce as Secretary of State for Energy and Climate Change,
Huhne declared that nuclear was “vital” for the UK’s energy
needs, and that “we need nuclear to be a part of our energy
mix” (see Martin, 2014).
6. An example here, is the late Tony Benn. In his time as Energy
Minister, between 1975-1979 Benn supported the UK’s
use of nuclear power. However his views changed. As Benn
himself explains: “I advocated it as Minister of Technology.
I was told, and believed, that nuclear power was cheap and
ENDNOTES
Evidence provided by Andrew Stirling and
Philip Johnstone to the Bradwell B Pre-
Application Consultation.
Prof Andrew Stirling
Professor Of Science & Technology Policy
(SPRU - Science Policy Research Unit)
Email: A.C.Stirling@sussex.ac.uk
Dr Philip Johnstone
Research Fellow (SPRU - Science Policy
Research Unit)
Email: P.Johnstone@sussex.ac.uk
Picture: Bradwell A nuclear power station (Photo courtesy
of wikimedia commons). Permission was sought but
declined by developers, to use an image of Bradwell B
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
safe and peaceful. Having been in charge of nuclear power I
discovered it wasn’t cheap, wasn’t safe and when I left ofce
I was told that during my period as Secretary of State for
Energy plutonium from our nuclear power stations went to the
Pentagon to make nuclear weapons. So every nuclear power
station in Britain is a bomb factory for America. I was utterly
shaken by that. Nothing in the world would now induce me to
support nuclear power. It was a mistake.” (Benn, 2008).
7. CGN-BRB-EDF Energy (2020) Stage One Consultation
Document, p.4. Bradwell B Power Generation Company Limited
2020.
8. The National Audit Ofce (NAO) is an independent UK
Parliamentary body which is responsible for auditing central
government departments, government agencies and non-
departmental public bodies. In 2017 the NAO published their
report on Hinkley point C (NAO, 2017). Sir Amyas Morse,
at the time head of the National Audit Ofce, stated that
“the Department has committed electricity consumers and
taxpayers to a high cost and risky deal in a changing energy
marketplace. Time will tell whether the deal represents value
for money, but we cannot say the Department has maximised
the chances that it will be.”
9. The Public Accounts Committee (PAC) is a select committee
of the UK House of Commons. It is responsible for overseeing
government expenditures, and to ensure they are effective and
honest. The PAC held an inquiry into Hinkley C following the
NAO report of the same year, which raised signicant concerns
about the value for money and nancial risks of nuclear
developments in the UK (PAC, 2017).
10. As highlighted by the PAC, The Government have not
considered the strategic case specically for nuclear power
since 2008. Since then nuclear costs have increased
considerably while costs for renewables have plummeted
(PAC, 2017). As we detail in this evidence, a judicial review
and many ofcial bodies raised serious questions about this
Nuclear Review.
11. DTI (2003) Our Energy Future: creating a low carbon economy.
London: Stationery Ofce.
12. Page 44. DTI (2003) Our Energy Future states: “Although
nuclear power produces no carbon dioxide, its current
economics make new nuclear build an unattractive option and
there are important issues of nuclear waste to be resolved.
Against this background, we conclude it is right to concentrate
our efforts on energy efciency and renewables”.
13. The 2006 Energy Review concluded that new nuclear “had
a role to play” in UK energy policy (DTI, 2006: 8), which
signalled a decisive shift from the conclusions of the 2003
Energy White Paper which had referred to new nuclear as an
‘unattractive’ option that was not being pursued (DTI, 2003:
44). Steve Thomas (2016), a leading expert in nuclear policy,
explores this “remarkable” policy turnaround, concluding that
ofcial arguments around climate change and energy security
do not offer sufcient explanation. Without being able to nd a
more detailed explanation, many commentators put this policy
reversal down to what Thomas calls a “failure” (page. 421)
on the part of the civil service and policy making more widely,
in the face of what is simply described as the effects of the
nuclear “lobby” (page 421). But the nature and substance of
this ‘lobbying’ remains opaque, with Thomas concluding that
“There is a common perception that there is a strong nuclear
lobby in Britain… however, it is not readily apparent who that
lobby might contain.” (p. 88). The present evidence bears
directly on this issue. The new more nuclear-specic white
paper was published in Janauary 2008: BERR (2008) Meeting
the energy challenge: a white paper on nuclear power. London:
Stationery Ofce.
14. The MoD commissioned the inuential USA-based think
tank (the RAND Corporation) to research the industrial and
supply chain issues around maintaining the UK submarine
base – particularly highlighting the skills shor tages that
the UK faced in this area and the associated difculties in
sustaining a nuclear-qualied workforce between submarine
orders (Schank, Cook, et al. 2005). The Keep Our Future
Aoat (KOFAC) campaign was launched in 2004 representing
councils, industry and trade unions associated with the
submarine manufacturing base at Barrow and participated
in both civil and military consultations on nuclear during the
crucial period between 2003 and the White paper of 2008.
For example, in a Memorandum in 2006, KOFAC stated
that “we support development of new proposals for nuclear
generating capacity within the UK and, where possible,
utilisation of the skills and expertise that exists in Cumbria
at facilities such as the Barrow shipyard to design, test
commission, build and operate nuclear powered electricity
generating equipment” (KOFAC, 2006 submission to the DTI
energy consultation, document no longer online). In 2006, the
House of Commons Defence Select Committee undertook
an inquiry into the Future of the UK’s Strategic Nuclear
Detterent (HoC Defence Select Committee, 2006). Many
key actors in the submarine industrial base gave evidence
and highlighted the importance of a new programme of civil
nuclear power for sustaining the industrial base for nuclear
submarines. For example, Rolls Royce highlighted that “the
depletion of civil nuclear skills has…reduced the support
network available to the military programmes” (Ev59). The
Royal Academy of Engineering highlighted that: “Overall,
the decline of the civil nuclear programme has forced the
military nuclear programme, and in particular the nuclear
submarine programme, to develop and fund its own expertise
and personnel in order to remain operational.” (EV107). They
also stated that “Ultimately, a strong civil industry is very
much in the interests of the military, and this may become
the case in the future” (EV107). In early 2006, BAE Systems,
the company that constructs nuclear submarines formed the
“key supplier forum” to bring together and coordinate for the
purposes of cost reductions and future planning among the
key stakeholders in nuclear submarine construction. Then the
Future of the United Kingdom ’s Nuclear Deterrent paper was
unveiled by Government in 2006. Around this time, the DTI
unveiled plans to preserve nuclear skills and R&D capabilities
as part of the National Nuclear Laboratory (NNL). The NNL
also works with partners across both the civil and defence
nuclear sectors.
15. As nuclear advocate Simon Taylor (2016) documents in his
book The Fall and Rise of nuclear power, in 2005 a working
group inside the Cabinet Ofce headed by John Birt conducted
a review of energy policy specically focussed on a nuclear
new build programme. This was a “secret piece of work”
(p.61) conducted by a small group selected by then Prime
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
Minister Tony Blair where “other civil servants were not
involved…or even told”. A crucial part of the revival of new
nuclear was therefore orchestrated “behind the scenes” (p.64)
without transparency even within the civil service.
16. Speaking at the CBI’s annual conference Mr Blair told
delegates that energy policy was back on the agenda “with a
vengeance.”(Eddie Newsroom, 2005).
17. This quote is from page 60 of the following report:
Environmental Audit Committee (2006) Keeping the lights on:
nuclear, renewables and climate change. London: Stationery
Ofce.
18. Greenpeace won this legal challenge. This episode is reported
by the BBC News (2007). Mr Justice Sullivan described
the Government’s energy consultation at this time as
“awed”, “misleading” and “procedurally unfair”. He added
that “something has gone clearly and radically wrong…
There was therefore procedural unfairness and a breach of
Greenpeace’s legitimate expectation that there would be
the fullest consultation before a decision was taken” (BBC
News, 2007). Additionally, it has been suggested by senior
sources in the civil service that there were even more serious
forms of malpractice taking place within nuclear policy making
during this period. A senior civil servant working in the Ofce
for Nuclear Development (OND) commented of this episode
in an interview with one of the authors in 2011: “Well, this
was an example of what not to do…this was really bad…this
wasn’t a good period, and there was a lot they were doing
wrong with nuclear which we’ve learned from. The court case
was a bit similar to Al Capone you know…he was committing
many counts of gangsterism but then it was a small piece
of tax evasion which put him behind bars.” (Interview with a
civil servant in the OND, 2011, see: page 181 of Johnstone
2013). There is clearly a lot more to be illuimninated about
the unfolding of UK nuclear policy during this period. It is
clear from this and other evidence presented here, that an
important and pervasive feature seems to have been a striking
level of secrecy.
19. Following the decision by the Royal Courts of Justice, the
Prime Minister Tony Blair declared that the decision “won’t
affect policy at all” reafrming the importance of having
“nuclear back on the agenda” (BBC News, 2007). Esentially
following the same revised line on nuclear power adopted in
the awed 2006 Energy Review, the further duly amended
‘Nuclear Review’ paper was published in 2008 (BERR, 2008).
20. The Environmental Audit Committee (2006: 64) commented
that “we remain convinced that the vision contained in
the White Paper—with its focus on energy efciency and
renewables as cornerstones of a future sustainable energy
policy—remains correct” and that there had not been a
“proper explanation of how circumstances have altered
sufciently to justify such a change” in terms of the changed
position on nuclear power.
21. Across many discussions of the “nuclear renaissance”, ofcial
UK energy policy documentation has generally failed to make
any mention of the military rationale for pursuing civil nuclear
power that is so prominent in defence policy documentation.
One very rare but salient exception occurs in an external
report for DECC by the consultancy Oxford Economics which
stated that “the naval and civil reactor industries are often
viewed as separate and to some extent unrelated from a
government policy perspective. However, the timeline of
the UK nuclear industry has clear interactions between the
two, particularly from a supply chain development point of
view.”(Oxford Economics 2013. page 31). The report goes
on to state that “The UK nuclear supply chain grew from
investment in reactor technology to develop nuclear weapons,
then into civil reactors, then submarines, a new generation
of civil reactors and nally more investment in a new class of
submarine. Without this synergy the UK supply chain would
not have been sustainable. Therefore it is worth thinking about
this interrelationship in developing the future plan for the UK
nuclear supply chain.”(p. 31). As we discuss in this document,
the body language of UK Government began to change
somewhat only from 2017, at a stage when links between
civil and military nuclear industrial infrastructures became
increasingly acknowledged despite previous insistence on the
two programmes being distinct.
It was in 2017 for instance (following the rst publication of
academic evidence specically on this issue by the authors),
that a number of statements and reports began emerging in
the USA, openly acknowledgeing interdependencies between
civil nuclear and military submarine infrastructures. This
overturned ofcial decades-long claims by the nuclear industry
and governments that civil and military nuclear were separate.
Former US Energy Secretary Ernest Moniz launched a repor t
in 2017, which stated that “a strong domestic supply chain
is needed to provide for nuclear Navy requirements. This
supply chain has an inherent and very strong overlap with the
commercial nuclear energy” (Energy Futures Initiative, 2017:
7). The report goes on to note that “Without a strong nuclear
energy program, which is by far the largest nuclear activity in
the United States, sustaining the supply chain for both civilian
and national security objectives will be challenging” (p.9).
A Report by the Energy Innovation Reform Project (2017)
on the future costs of new nuclear in the USA notes that:
“A sustained decline in the commercial industry could also
have a negative impact on the U.S. nuclear naval program”
(Energy Innovation Reform Project, 2017:7). The pro-nuclear
Environmental Progress group also now highlight the national
security dimensions supposedly at risk by declining civil
nuclear (Gallucci & Shellenberger, 2017). The Nuclear Energy
Institute, now strongly lobbies for subsidies for failing nuclear
developments, on the grounds that abandonment of these will
“stunt development of the nation’s defense nuclear complex”
(Axios, 2017). In 2018 the links continued to be made with
‘75 senior US gures’ writing a letter highlighting the “national
security benets of a strong domestic nuclear energy sector”
(World Nuclear News, 2018). In October 2018, a symposium
on ‘nuclear energy, naval propulsion, and national security’
was held at the Centre for Strategic and International Studies
(CSIS) bringing together expertise highlighting how the fate
of the USA nuclear submarine capability is “tied to the fate
of the commercial nuclear sector” and to “mitigate the
impacts of a declining nuclear power industry on the Navy and
national security” (CSIS, 2018). As discussions around a
Green New Deal emerged in the USA in early 2019, politician
Representative Jeff Duncan wrote in support of constructing
new civil nuclear because of ‘national security reasons’
outlining that “the U.S. Navy benets from a shared supply
chain with the civilian nuclear eet” (Duncan, 2019).
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
A similar picture has become clear over recent years in
other nuclear weapons states. The major state-held Russian
nuclear construction and services company Rosatom is clear
that the “[r]eliable provision of Russia’s defense capability is
the main priority of the nuclear industry” (Rosatom, 2017).
In France, a series of policy intrigues in this area have led
Le Monde newspaper to highlight “the ultimate question an
expert dares asking”: “What would become of the credibility
of our nuclear weapons program and our position at the UN
[Security Council], if France were to renounce its [nuclear
power] plants?” (Bezat, 2017). If concerns should be raised in
such acute and high prole ways about the diminishing critical
mass joint civil-military national nuclear industrial bases in
two countries ion which these are so relatively when compared
with the UK, then the question is intensied as to why these is
so little policy acknowledgement of this issue in the UK.
22. In 2003, the share of renewables in the UK electricity
generation mix was around 4.6% (IEA, 2020). Wind contributed
around 0.3% of electricity supply in 2003 and solar’s
contribution was negligable. Fast forward to the present
day, and it can be seen that renewables generated 37% of
electricity generation in 2019 (BEIS, 2019), and in the rst
quarter of 2020, renewables became the main power source
in the UK generating 44.6% of total generation (Lempriere,
2020). While Scotland’s plan for 40% renewables generation
by 2020 was considered unfeasible and indeed “fanciful”
by the self-proclaimed “logical and practical” Supporters of
Nuclear Energy Group in 2003 (SONE, newsletter, document
no longer online but image available here, 2003), for the rst
six months of 2019, renewables produced twice the country’s
domestic power requirements (Cockburn, 2019). Much of this
new capacity has been built since 2010, so the transformation
of the British energy system has been rapid. As this has
occurred prices have fallen rapidly in the UK with onshore
wind, solar, and offshore wind cheaper than new nuclear. This
reects international trends where in the past decade with
solar costs reducing by 82% since 2010, onshore wind by
39%, and offshore wind by 29% (Frankfurt School-UNEP, 2020).
Meanwhile costs of nuclear in the UK have doubled in the past
decade (Ambrose, 2019a), and internationaly, nuclear costs
have increased by 29% in the past decade (Dunai & De Clercq,
2019). Yet, despite these new realities, the UK government
remains rmly committed to new nuclear.
23. Strictly speaking, the relevant time period for the lapse
between the last full UK energy white paper and the present
day is seventeen years. This is because it was the 2003
Energy White Paper (DTI 2003) that formed the last fully-
detailed, duly consulted policy statement with balanced
attention across energy strategies as a whole, that was not
– as was the 2006 Energy Review (DTI 2006) – subsequently
successfully challenged by judicial review. The further policy
statement issued in 2008 after the Prime Minister stated that
this successful judicial review “won’t effect policy at all” (BBC
2007) was focused (as its name suggests – and as was the
awed 2006 paper) specically on making a case for nuclear
power, rather than on offering a fully-detailed, duly consulted
policy statement with balanced attention across UK energy
strategies as a whole (BERR 2008).
24. In their report on Hinkley C in 2017, the NAO recommended
that Government “...reconsiders its strategic case for
supporting nuclear power” and “maintain and update a
‘Plan B’ for achieving its objectives in the event that HPC is
delayed or cancelled” (NAO, 2017. P.14). The PAC then made
the specic recommendation that “The Department should
re-evaluate and publish its strategic case for supporting
nuclear power before agreeing any further deals for nuclear
power stations” and that “the Department should ensure it
publishes its ‘Plan B’ for achieving energy security, while at the
same time delivering on its decarbonisation and affordability
ambitions” (PAC, 2017. P.6).
25. The World Nuclear Industry Status Reports documents in
detail the long term trends of slowing reactor construction and
escalating costs. See Shneider et al (2019).
26. The UK performs strikingly poorly overall on most international
comparisons related to plant performance. The UK has
not sold a nuclear reactor since the early 1960s, when
UKAEA sold a total of 2 to Japan and Italy. There is no UK
headquartered company that is a major nuclear power utility
company. The UK performs poorly in terms of international
comparisons of key indicators of industry performance such
as reactor performance, and the UK nuclear sector compares
poorly on key comparisons of industry innovation such
as the ‘innovation index’ and patent counts (Johnstone &
Stirling, 2020). While it is clear that the UK is if anything in a
disadvantageous position in terms of its nuclear industry, it is
in a uniquely advantageous position with regard to renewables
potential with the best renewables resource in Europe (DECC,
2011a). Yet, it is the UK that continues to intensely pursue
nuclear while countries with superior nuclear industries
and inferior renewables potential that move away from the
technology.
27. According to the positions asserted in national data published
by the global industry trade body – the World Nuclear
Association (WNA), the ve largest-scale prospective nuclear
new-build programmes in the world are in four of the ve
‘ofcial’ nuclear weapons states (excepting France). India
and Iran are also pursuing ambitious nuclear new-build
programmes. And France is an illuminating exception, in that
the scale of its existing reliance on nuclear power in itself
militates against further large-scale national expansion. Of
the relatively few other countries in the world presenting
themselves as pursuing the most ambitious civil nuclear
new-build plans, eleven out of thirteen hold the status of
being major (at least regional) military powers. With regard to
the next tier of stated national ambitions for nuclear power,
an association between civil nuclear and military interests is
also apparent. Of 23 countries widely designated as ‘major
regional powers’ or above, only Australia has never developed,
or is not seeking to develop, a civil nuclear programme.
Albeit circumstantial, it is quite obvious that it tends to be
the leading global military powers who are also the leaders
in civil nuclear power around the world – and the most
committed to large scale new nuclear build. There is no global
or regional military power, that has not displayed at least
some active history of strong strategic pressures to pursue
civil nuclear power capabilities. Conversely, no country with
a current nuclear moratorium or that is phasing out nuclear
power has either nuclear weapons, nuclear submarines
or plans to develop either. Countries with well-performing
nuclear sectors have signalled a shift away from nuclear,
including Germany, Switzerland, Spain, and South Korea. See:
Stirling & Johnstone (2018) A global picture of industrial
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
interdependencies between civil and military nuclear.
28. A sign of this rapidly change in global energy markets is
that global investment in renewable energy has for several
years exceeded that in all other generating technologies put
together, with the gap growing fast (Frankfurt School-UNEP
2016: 32).
29. See: Centre for Alternative Technology (2013) Zero carbon
Britain: rethinking the future (Allen et a, 2013); PWC (2011)
100% renewable electricity: a roadmap for Europe and North
Africa; Recent peer-reviewed articles and reports highlight
the technical feasibility and economic effectiveness of global
100% renewable energy systems (Brown et al 2018 & Pam et
al 2017). The UK has the best renewables resource in Europe
with Scotland alone accounting for 25% of wind potential in
Western Europe, so the UK should be in a leading position to
enact the goal of 100% renewables transition. Other European
countries with nuclear capacity, most recently Spain, have
set such a target for example (Nelsen, 2018) and there is
no reason that the UK could not, yet rarely is the idea ever
seriously considered in UK policy and academia, despite its
prevalence elsewhere.
30. This is evidenced by the fact that the UK’s 16 GWe nuclear
programme was justied on the basis of nuclear remaining
cost-competitive with renewables for several decades (BERR,
2008), and similarly, outlined by the Committee on Climate
Change (CCC) in 2013, that nuclear “…currently appears to
be the most cost-effective of the low-carbon technologies”
(Monbiot, 2011). Only a few years later, both the costs of
onshore wind and solar (BEIS, 2016), and then offshore wind
(BEIS, 2017) had fallen below that of nuclear. This highlights
the problematic nature of the Government’s lack of explanation
regarding why nuclear is still being so intensly pursued.
31. A particular example of how out of step actual deployments
of renewables have been compared to leading predictions, is
that the International Energy Agency (IEA) have consistently
vastly underestimated growth in solar power in particular,
and the rapid reductions in cost (Enkhardt & Beetz, 2018).
The same is true for the BP energy outlook forecasts (Simon,
2018). In the UK, the Committee on Climate Change in 2011
outlined an illustrative scenario for decarbonising electricity
by 2030, entailing 40% renewables, 40% nuclear, 15% carbon
capture and storage, and up to 10% natural gas (Monbiot,
2011). In 2019 the share of renewables in the UK electricity
generation mix was around 36% and in the third quarter of
2019 renewables generated more electricity than fossil fuels
for the rst time whereas at the start of the decade 10 times
as much electricity was generated by fossil fuels than by
renewables (Evans, 2019). Analysis indicates that in the rst
quarter of 2020 renewables have eclipsed other forms of
generation producing 44% of electricity in the UK (Edie News
Room, 2020a). These are indications that renewables have far
surpassed expectations that existed from ofcial bodies at the
start of the decade.
32. A host of means are available to manage intermittent wind
power at a fraction of its growing cost advantage. For instance
OFGEM quote UKERC (2017) when stating in their own 2017
report that “at these levels, the UK Energy Research Centre
(UKERC) estimates that integration costs are between £5 per
MWh and £10 per MWh of intermittent energy (up to £478
million in 2016)” (OFGEM, 2017: 8).
33. Energy systems are transforming rapidly worldwide. As
Froggatt & Quiggin (2018: 2) highlight: “Rapid cost reductions
in battery manufacturing, driven by increased deployment
of EVs, are enabling affordable static, grid-level storage, in
turn enhancing power system exibility; Digitalization of the
electricity sector will lead to signicant advances in system
efciency and exibility. Residential demand will become
exible and networks functionally ‘smarter’. Machine-learning
algorithms could be a game-changer, helping to manage the
increasing complexity of electricity systems and identify new
system-level efciencies.” Indeed, BNEF also analysed the
LCOE of battery storage, revealing that it is now the cheapest
new-build technology for peaking purposed in gas-importing
regions, including Europe and China (Edie News Room,
2020b). The LCOE of battery storage has fallen to $150 per
MWh for systems with a four-hour duration, almost half of
its LCOE cost recorded in 2018. Many in the energy industry
are now predicting that the energy storage sector will grow
on a trajectory comparable to the solar industry during the
early 2000s, as more large-scale renewable arrays come onto
the grid. The UK’s own National Grid has made it clear that
operating 100% renewables grid is technologically feasible
and that it only requires modifying business models and grid
management techniques (Wood, 2019). Ways of managing
the intergration of renewables include: using wind and solar
to provide reserve and response services by 2020; increasing
deployment of storage and its use in frequency markets;
rening new ancillary services that deliver the iner tia currently
provide by rotating fossil plant, so that new markets for
these services can be developed and put in place by 2022;
improved forecasting of wind and solar, along with embedded
generation; augmenting abilities to monitor and measure
inertia and new network analysis tools that allow it to be
modelled and different operating scenarios assessed in real
time. As stated by a spokesman for the National Grid: “We
know, through approaches that we have had to date, that there
are customers with the right technologies that can provide
these services”.
34. This was evident in the Government’s response to the Public
Accounts Committee report on Hinkley C. The Government’s
‘benets realisation plan’ simply presented numbers of
jobs, apprenticeships, and local investment associated with
the Hinkley C development (BEIS, 2018). Yet, these are not
discussed in the wider context of what jobs would be created
by similar investments in renewables or energy efciency.
This is the circular logic that has dominated UK discussions
of nuclear jobs. All large scale energy investments generate
jobs, therefore to justify a high cost energy option on the basis
that it generates jobs is irrational because jobs would also
be generated by alternatives. Yet this circular logic dominates
discussions on UK nuclear. For example, In a statement on the
future of the energy market, Greg Clark the permanent Under
Secretary of BEIS stated: “There has been some criticism of
the prospective cost of the Hinkley project, but one aspect of
the benet that has not been emphasised often enough is that
it restarts programme of civil nuclear power in this country
and conversely the loss of much of the supply chain and the
domestic skills in the civil nuclear sector was a set back which
could have been avoided if we’d thought ahead. We need to
have a supply chain that is active - engineers who understand
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
the technology, PhDs and university departments specialised
in it, welders, civil engineers, concrete pourers, and more…”
(Clarke, 2018). This quote highlights the circular logic of new
nuclear in the UK, where it is acknowledged that nuclear is
expensive but that it must be pursued in order to preserve the
British nuclear supply chain and skills. This rationale is not
used to justify investment in any other any technology.
35. There is no substantive reason to view the volume of jobs
available from UK renewable investments to be less than
that associated with nuclear power. A report by REA (2017)
highlighted that there are over 125,940 people employed
in the renewable energy sector in the UK. The UK nuclear
sector is said to currently employ 65,000 people with industry
estimates that 40,000 new jobs would be created through a
new build programme (World Nuclear News, 2016). However
a report in 2014 for the Ofce for National Statistics (ONS,
2014) found that in terms of direct jobs, there are 15,000
direct jobs in nuclear power and 43,500 direct jobs in the
renewables sector. Yet UK trade unions are particularly
vocal about the importance of nuclear jobs (Fairlie, 2016)
and notably aggressive to those questioning the orthodoxy
on prioritising nuclear jobs above job creation generated by
expanding renewables (Syal, 2017). Neither UK Government
nor trade unions seem to view jobs provided by renewables
with the same signicance however, with 12,000 jobs lost in
the solar sector in 2015 following cuts to the Feed in Tariff
with for example (Vaughan, 2016a).
36. Global investment in non-hydro renewables already outstrips
investment in nuclear and fossil fuels combined (Frankfurt
School-UNEP 2016: 32). Global renewable energy markets
are growing faster than anticipated and are expected to grow
by 50% in the next ve years, according to the IEA (Ambrose,
2019b), an organisation that has traditionally been cautious
with regards to growth in renewables. A recent report by Lazard
highlights that wind and solar have been beating coal and
nuclear on costs for a few years now, but the Lazard report
points out that both wind and solar are now matching both
coal and nuclear on even the “marginal”cost of generation,
which excludes, for instance, the huge capital cost of nuclear
plants (Parkinson, 2019). With these astonishing trends set
to continue, even companies tied to the fossil fuels industry
concede that renewables will be the main source of power
globally by 2040 (Mechant, 2019). Meanwhile, nancial
experts, expect a continued decline in global nuclear energy
markets (Goldsmith, 2018). Given this reality of expanding
global renewable energy markets and declining nuclear
markets, combined with the lack of UK industrial strength in
civil nuclear power, it is evident that UK export opportunities
and future job prospects are more favourable with regards to
renewables than nuclear.
37. Most notable here is the case of Germany. Despite having a
far superior nuclear industry to the UK in terms of innovation,
international market share, and performance of reactors and
an inferior renewables resource to the UK (see Johnstone &
Stirling, 2020), is on course to phase out nuclear by 2022.
38. During his maiden speech as Prime Minister, Boris Johnson
declared his support for a “nuclear renaissance” on July
25th 2020 (World Nuclear News, 2020). Ideas of a nuclear
renaissance began circulating in the UK since the early 2000s
and intensied between 2003-2006 as Prime Minister Tony
Blair made a spectacular U-turn on nuclear and declared
ambitions around a ‘nuclear renaissance’ in 2006. The
original aims of the UK’s nuclear renaissance was to have
several plants constructed “signicantly before 2025” (DECC,
2011b), so given no new capacity will be operating before
this date, perhaps Johnson was calling for a ‘new’ nuclear
renaissance to replace the failed initial nuclear renaissance.
39. The loan guarantees announced in 2015 were another
example of the exceptional privilege that the nuclear sector
receives on the part of the UK Government. The Global
Subsidies Initiative (Bridle, 2016), reviewed the cost of all
subsidies for Hinkley Point C in 2016, highlighting that the
project was subsidised not just by the generous guaranteed
‘strike price’ but also loan guarantees worth £2 billion
announced by George Osborne in 2015 (Phillips et al, 2015),
waste disposal costs that are capped by government so tax
payers will pick up the tab if costs soar (Doward, 2016), and
Decommissioning costs where the government will be liable
to pay beyond the initial £5 billion covered by EDF, as well
as a de facto insurance against a nuclear accident. Global
Subsidies Watch calculated that these subsidies were greater
than £40 billion, and this was before costs of Hinkley rose
signicantly again in 2017.
40. Labelled by some commentators as “the worst period for
environmental policy in three decades” (Vaghan & Macalister,
2015), several green policies were axed during this period.
This included scrapping support for onshore wind; the sharp
reduction in solar Feed-in-Tarriffs; removal of the biomass
conversion subsidy; ‘killing’ the green homes scheme; selling
off the green investment bank; watering down incentives to
buy greener cars; giving up the zero carbon homes policy; and
abandoning the green tax credit. Since then, other proposals
have also been abandoned such as plans for a Tidal Lagoon in
Swansea (Vaughan & Morris, 2018).
41. Former US Vice President and climate campaigner Al Gore
commented that he did not understand the retraction of
renewable support measures and described the UK’s energy
policy decisions as “puzzling” (Harvey, 2015). Jaqueline
McGlade, Chief Scientist at the UN Environment Programme
also criticised these decisions and commented that they
were giving the “wrong signal” and were out of step with
international developments (Clark, 2015).
42. The latest developments at the time of writing, is that China
has threatened to remove its support of new nuclear power
plants in the UK after Boris Johnson approved plans last
week to develop 5G network alternatives to Huawei (Kennedy,
2020). Given China General Nuclear Power Group (CGN) is
being lined up as a partner in similar schemes planned for
Sizewell in Suffolk, and Bradwell in Essex, these new tensions
could further jeapordize the UK’s already severly troubled
‘nuclear renaissance’ (Oliver, 2020). Japanese investors have
already pulled out of the Wylfa B project in Wales and EDF are
already heavily invested in UK nuclear but require additional
investors. There are so few players left in the reactor
construction business, and the company that dominates global
reactor construction outside of China is Russian state-owned
Rosatom who have already been ruled out as being allowed
to invest in UK nuclear (Macalister, 2016). The UK is running
out of options of how to sustain its new nuclear ambitions.
The USA has shown signs that it is willing to step in to assist
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
the UK in nancing and constructing new nuclear reactors
instead of China (Sheridan, 2020), yet the US nuclear industry
is in a precarious nancial position itself. Regadless, what
this episode shows is how deeply entwined nuclear decision
making is with the most sensitive areas of geopolitical
strategic thinking.
43. In 2017, in an “astonishing hammer blow to the industry”
Westinghouse, the original developer of the Pressurized
Water Reactor (PWR), led for Bankruptcy, while Toshiba –
the parent company of Westinghouse – admitted that there
was “substantial doubt” that it could continue its nuclear
operations (Pearce, 2017). By 2018 it was reported that
Toshiba was scaling back its nuclear activities to shift towards
renewables (Asada & Hanada, 2018), and in 2019, Toshiba
withdrew its investment in the proposed Wylfa nuclear project
in Wales citing that the decision was based on “economic
rationality” (BBC News, 2019). Meanwhile, the French nuclear
industry is said to being “nancial turmoil” (Ward & Keohane,
2018). In 2017, French nuclear giant Areva, after suffering
heavy losses due to the Olkiluoto project in Finland, was
bailed out by the French state and folded into EDF. However
the development of the European Pressurized Reactor (EPR)
has caused huge nancial pressure for EDF, and in 2016
the then nance director of EDF Thomas Piquemal resigned
after advising that the nancial burdens of the Olkilouto,
Flamanville, and Hinkley C new build projects would lead to the
bankruptcy of the company (Stothard, 2016). With substantial
debts, at the end of 2018 the French state began a process
of restructuring of EDF in an attempt to alleviate signicant
nancial pressures (Keohane, 2018). Other leading nuclear
companies have already left the nuclear power business
behind. In 2011, Siemens wound up its nuclear operations
to focus on renewables (BBC, News, 2011). With the
traditional nuclear giants in the West facing immense nancial
challenges, the state-owned Russian company Rosatom now
dominates the international nuclear power station export
market (Economist, 2018).
44. In the absence of global orders it has been reported that
nuclear companies have “ocked” to the UK (Vaughan,
2017a). In understanding why the UK is such a focus for
international nuclear companies, Peter Atherton from the
energy consultancy rm Cornwall Energy puts it simply: “We
are the only people building new nuclear power stations and
we have by far the biggest new nuclear programme outside
China for the next 10 years…the civil nuclear programme
globally doesn’t have any orders.” In relation to the relative
size of the UK electricity system, then, this nuclear attachment
is internationally disproportionate. As Nuclear expert Michael
Schneider comments in the same article, the UK is nuclear’s
“last hope” in the West.
45. British submarine reactor manufacturer, Rolls Royce, has
proposed the construction of entirely untested small modular
reactors (SMRs) for civil energy production and have received
signicant government support. Rolls Royce has no previous
experience of building reactors for civil energy production, yet
speculative claims are made about the affordability of these
reactors and that they can be operating by the early 2030s
and that SMRs will be ‘cheaper’ (Energy Technologies Institute,
2016). Unfortunately these claims are often simply repeated
as if they are matters of fact by inuential media outlets
in the UK (see Meechan, 2019). Elsewhere, the diversity
of proposed nuclear projects as part of the UK’s ‘nuclear
renaissance’ in the UK is staggering. This includes the
construction of EPR reactors at Hinkley point C and Sizewell C,
ABWR reactors at Wylfa, HPR1000 reactor at Bradwell B, and
until recently, an AP1000 in Cumbria. Only with Hinkley C has
ofcial construction begun.
46. The prohibitive costs of nuclear have been highlighted by
analysts for decades, for example, Steve Thomas, The
Realities of Nucler Power (1988); Gordon Mackerron , “Nuclear
costs why do they keep rising?” (1992). The Independent
expert review of UK energy undertaken by the Performance
Innovation Unit (PIU) at the request of the Cabinet Ofce also
highlighted the economic problems associated with nuclear
and concluded that new nuclear should not be constructed
(PIU, 2002), yet this expert advice was later ignored by
Government.
47. For several decades, energy policy researchers have
highlighted the vast potential of UK renewables to contribute
to electricity production, often basing analysis on ofcial data
from relevant UK governmental departments. See Stirling
(1994) Power technology choice: Putting the money where
the mouth is?; Grubb, A. (1990) “The Cinderalla options: a
study of modernized renewable energy technologies part 1-A
technical assessment” Energy Policy, 18, pp 525-542.
48. Since the 1970s, the problems of nuclear waste in the UK
have been highlighted leading to the inuential Flowers Report
in 1976 by the UK Royal Commission on Environmental
Pollution. The same problems persisted and were agged up
by the independent Performance and Innovation Unit (PIU) as a
reason the UK should not proceed with a new eet of nuclear
power stations (PIU, 2002). Despite the declaration by DECC
that there is a ‘solution’ for UK radioactive waste (BERR,
2008), no site has been found for the construction of a Deep
Geological Disposal Facility (GDF) (DECC, 2014). The cost of
dealing with the UK’s legacy waste is £121 billion according to
the National Audit Ofce (NAO, 2018). The nuclear waste and
reprocessing facility at Sellaeld is widely considered to be the
most ‘hazardous industrial site in Europe’ (McKie, 2009).
49. There are many ways in which the UK Government’s appraisal
of nuclear is seriously out of step with emerging energy
trends. In fact, the UK government’s approach to nuclear
is out of step with its own original justicatory rationale
based around climate mitigation, low cost energy, and
energy security. New nuclear has not delivered on climate
mitigation or energy security “signicantly before 2025” as
initially planned. Since 2016, the Government’s own gures
have shown that renewables including onshore wind and
solar are lower cost than new nuclear (Vaughan, 2016b).
By 2017, costs for offshore wind were down to 55 £/MWh
and still falling rapidly (BEIS, 2017). Costs for renewables
including onshore wind and solar are considerably cheaper
than nuclear power according to the Government’s own data.
Nuclear power is above the comparable cost ranges for both
large-scale solar PV (£65-92/MWh) and onshore wind (£49-
90/MWh) as noted in the Government’s ‘value for money’
statement on Hinkley Point C (BEIS, 2016). More recently,
onshore wind has been revealed to be cheaper than gas and
could be delivered at a maximum of 50-55 £/MWh across
15 years (Vaughan, 2017b). The costs of offshore in the UK
are expected to fall considerably more over the next decade
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
in the UK, accentuating further the high costs of new nuclear
(Aurora, 2018). The UK Government is also increasingly out
step with key advisory bodies. The UK’s National Infrastructure
Commission (NIC) stated that “we’re suggesting it’s not
necessary to rush ahead with nuclear”, highlighting that
wind and solar could deliver the same generating capacity
(Vaughan, 2018).
Furthermore, the UK Government remains attached to the
idea of ‘baseload’ that many energy experts feel is no longer
a relevant paradigm for understanding the functioning of
electricity grids as they evolve with increased renewables
capacity and demand side measures. For example, Steve
Holiday from the National Grid Company identies ‘base
load’ to be an “outdated” concept (Beckman 2015). This is
becoming a trend internationally, as McArdle writes, “across
the world it is hard to nd a grid operator that doesn’t admit
that the future of “base-load” in the world’s grids is either
lousy or non-existent.” (McArdle, 2019).
50. Previous UK nuclear programmes have not delivered on their
originally stated targets. For example, the 1964 programme
was signicantly scaled back and in the end dubbed one
of “the major blunders of British industrial policy” (Brown,
2008). In 1979, one of the rst major policies announced
under the new Thatcher government by Geoffrey Howell, the
minister for energy, was the construction of 8 new nuclear
reactors within a decade that were an apparent ‘necessity’
with 15GW of new capacity planned (Hansard, 1979). In the
end one new reactor was constructed (Sizewell B). The case
for nuclear power collapsed in 1990 when it became apparent
that Hinkley C could not be constructed and operated in a
privatised electricity market. Nuclear had to be ring fenced
from privatisation and given what was essentially a form of
subsidy through the Non-Fossil fuels obligation which was
dubbed the ‘nuclear fuels obligation’ (Pearson & Watson,
2010). Attempted privatisation of the nuclear industry did not
take place until the late 1990s with the creation of British
Energy, but this experiment did not last long as British Energy
had to be bailed out by the UK government to the tune of over
£650 million in 2001 and guarantees were given that the
tax payer would take on the costs of future liabilities arising
from the operations of British Energy. This is only with regards
to conventional civil nuclear power generation but the same
historical pattern of under-delivery, delays, and escalating
costs plays out with Fast Breeder Reactors, reprocessing
facilities, and MOX plants (Cox et al, 2016). The UK’s ‘nuclear
renaissance’ is facing the same fate, with new nuclear set to
make no contribution to new low carbon generating capacity
till at least 2026, despite promises of several new reactors in
operation by 2020 (Porter & Clover, 2008). While renewables
costs plummet, nuclear costs have increased markedly in the
UK. Instead of reconsidering options or outlining a Plan B (as
suggested by the Public Accounts Committee), the Government
has announced even more eccentric proposals around new
nuclear such as the Regulated Asset Based model of nancing
new nuclear that could see consumers paying upfront for
inevitable cost overruns, as well as proposals around entirely
untested Small Modular Reactors (SMRs).
51. For example, Professor Sir David Mackay, then Chief Scientic
Advisor to the Department of Energy and Climate Change
(DECC), continually emphasised the “worrying limitations on
our sustainable energy options” (Mackay, 2013). He stated in
2013, for instance, that “if you do want renewables to make a
substantial difference, for a country like the United Kingdom,
on the scale of today’s consumption, you need to be imagining
renewable facilities that are country sized…” (Mackay, 2013).
Remarkably, developments over only a few years since
this statement are already highlighting deep aws in this
reasoning. Despite being so assertively voiced, MacKay’s
analysis fails (for instance) to consider that: the area between
turbine towers is little more consumed by wind power than
is land between power stations, and offshore wind does not
involve consumption of land at all.
52. Several myths have been perpetrated against renewables by
the nuclear industry over the years including renewables being
more expensive than new nuclear, renewables not being ready
to replace fossil fuel generation, renewables diffusion requiring
a large land mass, and the necessity of baseload power
meaning renewables are unworkable (Diesendorf, 2016).
53. See Johnstone, P. Stirling, A. (2020) “Comparing nuclear
trajectories in Germany and the UK” Energy Res. & Social
Science 59, 101245 ; Johnstone, P. Sovacool, B. Stirling, A.
(2017) “Policy mixes for incumbency: Exploring the destructive
recreation of renewable energy, shale gas ‘fracking’, and
nuclear power in the United Kingdom” Energy Res. & Social
Science, 33, pp. 147-162.
54. See Stirling, A. Johnstone, P (2019) “Are Hidden Military
Pressures for Cross-Subsidies Driving Major UK Energy
Infrastructure Decisions?” Written evidence to the BEIS inquiry
on Financing Energy Infrastructure, June, 2019. Stirling, A.
Johnstone, P (2017) “Written evidence from the University of
Sussex, Science Policy Research Unit (BRN0015)” Department
of Business, Energy, and Industrial Strategy (BEIS) Brexit and
the implications for UK Business: Civil nuclear sector inquiry,
submitted, October 2017; See Stirling, A. Johnstone, P (2017)
“Some Queries over Neglected Strategic Factors in Public
Accounting for UK Nuclear Power:evidence to the House of
Commons Public Accounts Committee Inquiry on Hinkley Point
C” Public Accounts Committee (PAC) Hinkley Point C Inquiry,
submitted 25th September, 2017.
55. See Harrabin, R. (2019) “Nuclear: energy bills ‘used to
subsidize submarines’” BBC News, 5th June, 2019; Osborne,
S (2019) “Homeowners being forced to pay higher energy
bills to subsidise Britain’s nuclear submarines, MPs told” The
Independent, 5th June; Watt, H. (2017) “Hinkley point: the
‘dreadful deal’ behind the world’s most expensive power plant”
The Guardian, 21st December; Watt, H (2017) “Electricity
consumers to fund nuclear weapons through Hinkley C” The
Guardian, 12th October.
56. Without the research, engineering and skills infrastructure
provided by a continuing civil nuclear industry, it would be
impossible for the UK to maintain this platform for its nuclear
deterrent and its associated ‘top table’ standing at the UN. It
is widely discussed that ambitions to sustain Britain’s position
at this ‘top table’ may be a driving factor in motivations to
maintain a recognised militarily-credible nuclear weapons
capability (Barckham & Norton-Taylor 2010). Such a view, for
instance, has been emphasised by Britain’s key ally the United
States, with a rare intervention by US Defence Secretary
Ash Carter holding that the UK needs to maintain its nuclear
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
weapons capability in order to continue its “outsized role in
the world” (Press Association 2016). Tony Blair was clear
in his autobiography that with regard to nuclear weapons
“the expense is huge and the utility…non-existent in terms
of military use”, but that giving it up would be “too big a
downgrading of our status as a nation” (quoted in Norton-
Taylor, 2015).
57. Statements from UK nuclear submarine industry sources
are very clear about the importance of crucial interlinkages
between defence and civil nuclear – explicitly noting incentives
to “mask” the costs of this military programme behind the
related civilian industrial infrastructure (Ireland, 2007: 25).
The Keep our Future Aoat Campaign (KOFAC), a lobby group
representing industrial interests around the Barrow shipyards
that construct nuclear submarines stated that “The decline
of the UK civil nuclear programme has forced the military
nuclear programme, and in particular the nuclear submarine
programme, to develop and fund its own expertise and
personnel in order to remain operational” (KOFAC quoted
in House of Commons North West Regional Committee
2010: 109). The Dalton Institute has noted that “The UK
is not now in the position of having nancial or personnel
resources to develop both [civil and defence] programmes
in isolation. For example, reactor physicists on the military
programme can develop their skills and knowledge by
researching civil systems, and then only when necessary
divert to classied work to follow a specialist career path”
(Innovation Universities Science and Skills Committee 2009:
EV419). In the same year, Rolls Royce notes that “Skills are
considered to be transferable between military propulsion
and civil programmes”, where “a larger involvement in the
broader [civil] industry will also have a spillover benet to
military capability through skill development and experience
exchange”. More recently, UK naval reactor manufacturer Rolls
Royce dedicate an entire section of a recent report advocating
ostensibly civilian small modular reactors to the detailing of
“advantages to the UK’s nuclear deterrent programme”. They
state that a civil Small Modular Reactor (SMR) programme
would “relieve the Ministry of Defence of the burden of
developing and retaining skills and capability. This would free
up valuable resources for other investments.” (Rolls Royce
2017: 11).
In a secret report only obtained through a Freedom of
Information request by journalist Rob Edwards (Edwards,
2017), Sherry et al note that “the MOD’s programme had been
underwritten by civil nuclear research” but with a declining
civil nuclear industry “the expertise these activities generated
has atrophied.” (Sherry et al. 2014: 59) Thus emphasis has
been placed by Government and industry on strengthening the
overlaps between defence nuclear sector and the UK’s civil
‘nuclear renaissance’. The nuclear sector deal is particularly
focused on facilitating ‘mobility’ between the civil and defence
nuclear workforce as a key strategy to manage the skills
challenge (Nuclear Industry Council, 2017). It is stated in
“The Nuclear Sector Deal” that “the sector is committed to
increasing the opportunities for transferability between civil
and defence industries and generally increasing mobility to
ensure resources are positioned at required locations” (p.36)
and that 18 percent of projected skills gaps can be met by
‘transferability and mobility’. The document also states that
the skills gap can be met through “greater alignment of the
civil and defence sectors with increased proactive two-way
transfer of people and knowledge. As the military service
sector tends to be age and nationality limited, we propose that
we actively seek a recognisable career pathway between the
civil and sectors to ease transfer between the two”(36).
58. As eloquently expressed by Ernest Bevan, a leading gure in
the Attlee Labour administration (1945-51) that made crucial
decisions in this regard: “We’ve got to have this thing over
here whatever it costs [and] we’ve got to have the bloody
Union Jack on top of it” (Jack, 2016).
59. As reported in the Financial Times increasingly comments are
being heard from senior ofcials in the Royal Navy and the
MoD “about the disproportionate impact the deterrent has on
the overall defence budget” where “some people are asking,
‘can we really justify this?’” (Bond & Pfeifer, 2019).
60. A telling statement on this point is in a 2008 a report on the
UK’s strategic nuclear deterrent by the NAO where it is stated
that “[o]ne assumption of the future deterrent programme
is that the United Kingdom submarine industry will be
sustainable and that the costs of supporting it will not fall
directly on the future deterrent programme” (NAO 2008: 28).
The key question that follows from this, is that: if the costs of
supporting the nuclear submarine industry do not fall directly
on the future deterrent programme, where do these costs
fall? The evidence strongly suggests it is through civil nuclear
investments and supply chains that some of these costs will
be covered.
61. One widespread initial reaction to the authors raising of
these questions about civil-military links in UK nuclear policy,
were widespread accusations that the analysis amounts to a
“conspiracy theory”. Indeed, a number of commentaries were
written which explicitly voiced this criticism (Jewell, 2015 &
Lovering, 2016)? One such critic (among many others) was
the US Breakthrough Institute, then led by prominent nuclear
advocate Michael Shellenberger.
But what then became striking, was a series of high prole
reports in the US that began – for the rst time in the history
of ofcial documentation in this area – openly to emphasise
exactly dynamics drawn attention to in the analysis. Starkly
contrasting with the ofcial non-engagement on the part of
ofcial bodies and the mainstream media in the UK, a series
of US report acknowledged the military pressures to maintain
civil nuclear power at whatever cost, in order to support the
nuclear navy. With the ‘conspiracy’ thus openly acknowledged
as a high-level policy prescription, public accusations of
conspiracy theory have become muted.
62. In a parliamentary debate on the nuclear sector deal on the
11th of July 2018, Richard Harrington, the Parliamentary
Under Secretary for BEIS, stated that “I want to include the
MOD more in everything we do. It is quite time enough, and
the hon. Gentleman made a very good point, supported by
some of my hon. Friends. Because the MOD is a member
of the Nuclear Industry Council, it is time that that articial
distinction…[between civil and defence nuclear]…came to
an end, and I will do my absolute best to bring that about.”
(Hansard, 2018).
63. The PAC itself heard and published evidence for this subsidy
more than two years ago. And this formed the basis for a
EVIDENCE FROM SPRU TO THE BRADWELL B PRE-APPLICATION CONSULTATION
signicant question posed by PAC Chair Meg Hillier of a crucial
witness in October 2016. This witness was the most senior
civil servant in the Ministry of Defence, Stephen Lovegrove.
When asked if there are links between civil and military
nuclear programmes, Lovegrove remarkably conrmed the
necessity for exactly the “concerted government action”
represented by the subsidy. Yet the PAC has yet to investigate
this civil-military link – or, indeed, say anything further at all
(Watt, 2017).
64. Since 2015, the authors have written several commentaries
including in the Guardian (Johnstone & Stirling 2015; Stirling
& Johnstone 2018). A further blog post in The Conversation
(Johnstone & Stirling 2015) and a two part blog for the Oxford
Security Group (Johnstone & Stirling 2017a; Johnstone &
Stirling 2017b). None of the arguments presented in these
well-publicised commentaries have been refuted. This isn’t
to say there hasn’t been some critical feedback. Mike Clancy
(2018) from Prospect union recently wrote a letter in the
Guardian criticizing our 2018 Guardian commentary, however
this letter did not either address or refute any of the specic
points of evidence that we raise.
65. The issue remains unacknowledged in governmental policy
or parlimentary scrutiny in Westminster. Only in the Scottish
Parliament, where there is no new nuclear build programme,
has this issue been raised in a motion by Bill Kidd MSP (Kidd,
2019). Yet, in Westminster, which oversees the new nuclear
programme the issue has not been discussed in the context
of energy policy. However, it is also the case with regards to
energy expertise and academia that the militar y issue remains
largely undiscussed. Indeed, what is also remarkable about
mainstream UK policy debates on nuclear issues, is not just
the absence of discussion on military drivers, but how often
even those experts with a relatively independent or past
critical perspectives, are pressured by media interpretations or
policy patronage, into expressing positions that reinforce the
idea that nuclear is somehow especially difcult to exclude. In
this picture, it is as if there can be no realistic circumstances
under which nuclear power might reasonably be entirely
omitted from the pursued portfolio of UK electricity supply
options.
66. It is not necessary to be a critic of nuclear technologies to
recognise that – as with any policy choice – advocacy of these
strategic directions rather than others are most credible, when
supported by reasoned argument and policy debate. If the
unfolding of events is being driven by invisible pressures, then
the asking of questions and shining of light are non-partisan
interests.
67. One aspect of this secrecy is reected in a lack of
transparency concerning the basic question of why the UK is
so intensely committed to new nuclear power despite high
costs and the presence of cheaper renewable alternatives.
This was a point raised by the Citizen’s Advice Bureau stating
that:“We note that the government appears very committed
to new nuclear, eg that it is entering into a sector deal with
it, despite the headline cost (strike price) of such projects
appearing unfavourable when compared to many scale
renewable technologies. If this remains the case, we would
encourage BEIS to publish the thinking and evidence that
underlies this commitment, as to an external audience this
decision currently appears sub-optimal if it is seeking to keep
down consumer cost” (Hall 2017: 4-5). The NAO referred
repeatedly to the importance for Government of other “wider
strategic” considerations beyond the ofcially-stated “energy
trilemma” around ‘affordability’, ‘climate change’ and ‘energy
security’ (NAO 2017). However it is not clear what these
wider strategic benets of new nuclear are. It was noted that
“[t]he Department has not formally reviewed and consulted
on its published strategic case for nuclear power since the
publication of the 2008 white paper” (p.19). Ultimately,
energy bill-paying citizens should have the right to know
the reason why a particularly expensive source of energy is
being priviledged at a time when UK and global energy trends
highlight the affordability and practicality of alternatives.
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