Memorandum submitted by the Sustainable Energy Partnership (NPS 96)

Apology

This submission is late: we apologise to the Select Committee for this. The reason is that since attending the official consultation public meeting regarding Sizewell C in Leiston, Suffolk on 5th December we have been trying to obtain information from DECC about questions that we asked at the meeting.

After dozens of emails and phone messages, this finally arrived on 19th January1. DECC officials were aware of the delay and took the exceptional action of telephoning the Select Committee2 to explain that they were responsible. After considering the evidence that they gave us we are able to complete our submission. We again apologise to the Committee for this delay,

What is SEP?

1. SEP is a Partnership of almost all environmental and fuel poverty NGOs and relevant trade groupings. The full list of members is: All Party Parliamentary Group for Intelligent Energy, Association for the Conservation of Energy, Association for Environment Conscious Building, Association of Cola Mine Methane Operators, British Hydro, British Energy Efficiency Federation, British Wind Energy Association, Campaign to Protect Rural England, Combined Heat and Power Association, Consumer Focus, Cornwall Sustainable Energy Partnership, Country Land & Business Association, Energy Centre for Sustainable Communities, Friends of the Earth, GLOBE UK All-Party Parliamentary Group, Good Energy, Green Liberal Democrats, Green Party, Greenpeace, Help the Aged, London Energy Managers Group, Micropower Council, National Energy Action, National Federation of Women’s Institutes, National Home Improvement Council, nation Housing Federation, National Right to Fuel Campaign, PV-UK, PRASEG, RSPB, Renewable Energy Association, SERA, SHELTER, Solar Century, Tenants & Residents Organisation of England (TAROE), Tory Green Initiative, UNISON, WWF-UK.

SEP and nuclear power

2. SEP is NOT opposed to nuclear power in principle – but is totally committed to achieving climate change and fuel poverty targets and achieving energy security. We are also totally convinced that energy policy should be made on the basis of rational discussion and evidence.

Scope of this response

3. Thus this response simply assesses the evidence and answers just one of the questions in the government’s consultation: question 18. This asks

‘Does the draft Nuclear National Policy Statement provide suitable direction to the Infrastructure Planning Commission on the need and urgency for new nuclear power?’

4. Our answer is ‘no’: it does not provide ‘suitable direction’ on the need and urgency for new nuclear power – for four reasons:

· the absence of the need anyway; and

· the absence of a government assessment of electricity demand, on which need must be based; and

· the fundamentally flawed process used by the government in calculating the need for capacity from new nuclear power stations; and

· the fundamentally flawed figures used by the government in assessing the need for capacity.

The Absence of ‘need’

5. In fact the government does not show that there is a ‘need’ for new nuclear power stations in order to achieve energy objectives of

· ‘keeping the lights on’ or ‘the operating theatres going’ or meeting peak demand;

· Ensuring security of supply; and

· Achieving CO2 reduction targets.

The attached Table shows, year by year up to 2050, how we canmeet those objectives up to and including 2050 without recourse to new nuclear power stations. The figures in the Table are all referenced and based upon rigorous and widely accepted studies and modelling from credible sources. The only assumptions made are for figures for ‘in between’ years – i.e. where a study gives a potential for, say 2010 and 2020, we have assumed an even trajectory for 2015.

Regarding many of the figures, we have ‘erred on the side of caution’, as explained in the chart.

The absence of an assessment of long term need – i.e. electricity demand

6. The government’s strategy for new nuclear power stations is to supply our long term electricity needs.3 But that, of course, depends upon an assessment of what those electricity needs are. Yet this has not been done: no long term assessment of energy demand has been made. So, in fact, we have a strategy that is based not on a detailed analysis but more on guesswork or ‘might-be’s as demonstrated below.

7. We have spent some considerable time trying to get this information regarding future electricity needs/demand, and even to establish whether or not it exists. For instance

· We received a reply from the relevant official to whom we had been referred in DECC (Alan Clifford) on 9thth October 2009 which said

‘you also asked for details about the Government assessment of future electricity demand up to and beyond 2050. The Low Carbon Transition Plan (page 73, chart 5) shows projected peak electricity demand and generation capacity to 2024, but, at this point in time, we do not have any published assessments of this nature that extend as far as 2050.’ [our emphasis – SEP]

· We were also referred to Stephen Oxley, the Higher Statistical Officer in DECC. He replied in similar vein on 10th December 2009

‘DECC has not made any long-term projections of electricity demand / supply. Our latest projections were published up to 2022 and we have previously published figures to 2025. DECC is developing scenarios of potential electricity demand / supply to 2050 but don’t have any definite figures for this yet.’ [our emphasis – SEP]

· And in the recent protracted correspondence with the Office for the Nuclear Development section of DECC, during which we tried to establish whether any assessment of future need had been made, we were explicitly told that although there were statements as regards future possibilities (see para 8 below in which we refer to these) the full analysis will not be made until ‘Spring 2010’.4[our emphasis – SEP].

8. In other words, the government is proposing to put into place a programme to build 10 more nuclear power stations (‘all 10 sites are needed’)5 without having done even a basic assessment of what the demand for electricity might be. Rather it has decided upon this policy on the basis of statements like:

· ‘we can expect to see the demand for electricity at least stay the same and probably increase’ 6 [our emphasis – SEP] and

· ‘many (but not all) scenarios suggest that in the future more of the energy for heating and travel could come from electricity’7, [our emphasis – SEP]

· and even in the Draft Overarching National Policy Statement on which this consultation is based ‘by 2050 the UK may need to produce more electricity than today’8[our emphasis – SEP]

9. So there it is: no analysis of future need has been done; some but not all scenarios suggest that demand could increase; and the best the government can claim (in EN 1) is that there ‘may’ be a need for more electricity. Despite this, they have made up their minds already regarding the need for 10 new nuclear power stations to satisfy our unsubstantiated and un-assessed ‘long term need’

10. On the basis of this, the Select Committee and the general public are being asked to agree to this so-called ‘strategy’. This is rather like the Chancellor of the Exchequer saying ‘Under some (but not all) future spending scenarios there may be a need to raise income tax, so I’m going to do just that; I haven’t made an assessment yet but I’ll do that in future and I’ll publish my analysis of the need to do this at a later date’! It is untenable.

Medium term need – capacity up to 2025

11. The government’s case for new nuclear power stations in EN-6 is that ‘there will be a need for approximately 60GW of new capacity by 2025 – because of closures of existing power stations (nuclear and non-nuclear) amounting to a loss of 22GW 9 capacity.’ (Capacity is the amount of electricity required to be generated every day to ensure that we ‘keep the lights on’ and satisfy peak demand).

12. This is, in fact, a medium term demand claim based not on overall demand but on required capacity. The government’s case in EN-6 is that ‘under central assumptions there will be a need for approximately 60GW of new capacity by 2025’10 (i.e. to cover peak demand needs) and ‘of this 60 GW as much as 35GW could come from renewables (in line with our international obligations11) with 25 GW from other conventional generation capacity’12. In EN-6 the government specifically cites modelling carried out by Redpoint Energy13 for DECC as the source for these calculations.14. So it is worth investigating how they were arrived at (we do this in paras 13 and 14 below ), and then pointing out the fundamental flaws (we do this in paras 15 and 16 below).

13. The Redpoint Calculations

As noted above EN-6 states that ‘under central assumptions there will be a need for approximately 60GW of new capacity by 2025’ – and quotes Redpoint as the source for this. At the DECC public consultation meeting regarding Sizewell C held in Leiston Suffolk on 5th December our Sustainable Energy Partnership Organiser, Ron Bailey (a resident of Leiston) sought to find out where this assumption had come from. The official transcript produced by DECC of that meeting reads as follows:

‘Ron Bailey

You referred me to page six of EN-6 and I have looked at the modelling, but it does not substantiate the 60GW. It substantiates the 35/25 breakdown but it does not give any evidence for the assumption of 60GW. Could you undertake to send me more information on how you reach that figure?

Peter Erwin

Yes, of course’15

It is this information that took us dozens of emails and phone calls to obtain. In the end we were simply referred back to Redpoint as the source for the ‘central assumption’.16

So we looked again at Redpoint (the claimed source of the central assumption re the extra 60GW capacity being needed by 2025)– and particularly at Figures 11 and 1417, that we were directed to by the Office for Nuclear Development in their emails18 and what they show is this:

· There will be a loss of 24GW by 2020 and 32 GW by 2025 due to plant closures (Figure 14).

· On Redpoint’s ‘New Plant Build’ base case (Figure 11) there will be an extra 43GW by 2020 and 60GW by 2025 – including new nuclear and renewables.

· Based on current capacity of 80GW19 that means that there will be a capacity of 100GW by 2020 (80-24+43 = 100 rounded) and 110GW (80-32+60 = 110 rounded) by 2025.

Clearly, subject to some rounding, the maths is correct as regards the amount of capacity. Based on Redpoint’s figures there WILL be a capacity of 100GW by 2020 and 110GW by 2025. But what this did NOT provide us with is the information that we asked for on 5th December – the source of the ‘central assumption’ re the NEED for a total capacity of 110GW by 2025, thus requiring ‘approximately 60GW’ of new capacity by 2025.

As the Office for Nuclear Development has told us that Redpoint is the sole source of the ‘central assumption’ in EN-6 we therefore looked at HOW the figures were arrived at, in order to try to establish the source of the assumption of need. We do this in para 14 below.

14. The starting point must be what Redpoint was asked to do by DECC. This is stated at the very beginning of their report: ‘the scope of this study for DECC was to assess options for both the minimum and potential changes to the RO, with a goal of achieving around 28%-29% of electricity from renewables by 2020’. [our emphasis – SEP]. We will comment more on this (in paras 15 and 16 but for now let us just note it: achieving 28%-29% of electricity from renewables was the goal.

So Redpoint’s analysts did exactly what was asked of them: they deducted plant closures from current capacity in Table 14, then assumed 29% was required from renewables as per their brief from DECC (including 24.6GW of new plant), added on the government’s proposed nuclear new build programme, added on other proposed totals in the government’s programme and reached the total of 110GW total capacity in 202020. With the exception of the 28%-29% renewables figure (which was the ‘goal’) it was a mathematical exercise: adding up the electricity generation figures based on government policies.

The government then took those same figures and called them the ‘central assumption’ of need for an extra 60GW of new capacity by 2020 in EN-6. And, as our protracted correspondence with the Office for Nuclear Development demonstrated – this was the sole basis for that statement in EN-6.

In a nutshell what the government did was add up their proposed policies, including the 29% renewables figure and its proposed new nuclear capacity and call that a ‘central assumption’ of NEED – and then, as Redpoint had (perfectly legitimately) done the same thing, the government referenced Redpoint as the independent source for their ‘central assumption’.

Both the process and the figures used by the government are fundamentally flawed.

15. Why this process is fundamentally flawed

As stated in paragraph 12 above the use of the Redpoint modelling to demonstrate the need for new nuclear power station is invalid. This is because Redpoint was used for the Renewable Energy Strategy – to show a scenario whereby the government could meet its legal duty (under EU law) and supply 30% of electricity from renewables by 2020. That is ALL Redpoint was asked to model – NOT the potential for renewables, or CHP, or microgeneration, or greater energy efficiency – just HOW could the 30% renewables target be met. Redpoint did its job showing this – and the government then used this in support of the need for new nuclear. The trick is thus twofold:

(i) The sentence in EN -6 does not show that we need new nuclear because we can only get 35GW from renewables: what it shows is that if we simply assume ONLY 35GW from renewables then that does leave another 25GW.

(ii) The source quoted (Redpoint) is a not valid in this case because it was commissioned to show how to achieve 28%-29% of electricity from renewables – not how or whether we could generate enough electricity without nuclear to meet demand.

This really is an apples and pears situation – i.e. assume we need 15 pieces of fruit every week, of which a minimum of 10 must be apples; so commission experts to do some modelling to show how we can get the 10 apples – which they then do. Their model does not show how or whether we can get more than 10 apples (because they were not asked to do any such analysis). Therefore that means that we need 5 pears to make up the difference.

16. Why the government’s figures are flawed

(i) The figure of 35GW from renewables stated in EN-6 and EN-121 and taken from Redpoint is not the maximum that can be achieved or is feasible and practicable or cost-effective by renewables, simply the figures that they were asked to model on by DECC – the goal of achieving 28%-29% of electricity from renewables by 2020 as stated on page 4 of their report.

(ii) Indeed the Redpoint report itself points out that the potential is far grater than the 28%-29%.See for instance Figure 77 on page 104 of their Report. This shows a far larger potential. And although they do point out that the figures in Figure 77 ‘take no account of build rate constraints which restrict the speed at which these resources can be exploited’22 Redpoint did not do an analysis of the full potential after considering build rate constraints – because they weren’t asked to. But the likelihood of far greater potential is very clear from their Report.

(iii) In the government’s LCTP on page 73 (and quoted also in EN-123)it states that current peak demand is 60GW and current capacity is 80GW (i.e. 20GW above peak demand, so emergencies can be coped with) and that this peak demand is projected to remain virtually the same until 2024. So the government’s own calculations show no need for an increase in capacity to 100 and 110 as stated in Redpoint.

(iv) Perhaps even more importantly, the table and the text on page 7324 of the LCTP and page 18 of EN-1 also deals with the important issue of plant closures, as referred to in EN-6. And this shows quite clearly that there is sufficient new plant (none of which is nuclear) to replace the 22GW lost to closures to maintain the 80GW capacity – i.e. still the same 20GW above peak demand. Most of these figures are repeated in EN-1.25

(v) Indeed, taking Redpoint calculations (on which the government places so much weight) removing nuclear from the equation would, without any other replacement policies at all, only reduce 2020 capacity by 1.6GW – leaving the total capacity as 100GW – 1.6 = 98.4GW and only reduce 2025 capacity by 4.8GW - leaving total capacity as 110GW – 4.8 = 105.2GW. This is still 45.2GW or over 66% above peak demand of 60GW: far higher than the current capacity of 80GW is over peak demand of 60GW.

What does this mean?

17. It defies common sense to approve a massive building programme to achieve the long term objectives of energy policy without a proper assessment of the future long term need for electricity and with a flawed process of assessing the medium term capacity need. This is no way to run a strategy. It means either that

· the government has taken leave of its senses and behaved completely irrationally; or

· that there has been, for some time, a hidden agenda: that the government decided a long while ago to build more nuclear power stations, regardless of any evidence of need.

Whichever of the above scenarios is correct means that the government’s current consultation is a sham26 and that the policy itself is, to say the least, of questionable legality.

Nuclear come what may

18. We have described the irrationality above: below we cover in more detail the latter point– that the government decided sometime a while ago to build more nuclear power stations, whatever the evidence.

19. The government announced the decision to build more nuclear power stations in the Nuclear White Paper published in January 2008. The importance of the words of Gordon Brown referred to in footnote 3 above can now be seen. At that time the carbon dioxide reduction target was 60% by 2050. This would require a 30% increase in the use of electricity – which would all be offset by greater energy efficiency – according to the Nuclear White Paper itself:

"by 2050, with no carbon constraint, electricity demand is expected to increase by around 30% compared to today’s levels. Energy efficiency can make a significant contribution to achieving our policy goals cost effectively. When all options, including new nuclear power stations, are available, the model shows that improvements in the efficiency and the way we use energy could reduce demand by around 30% compared to what it would otherwise be. Total electricity demand would therefore remain at roughly today’s levels despite the UK’s GDP being three times larger than it is today."

We have asked officials as to whether our interpretation of this paragraph is correct (i.e. that it was the government’s view that savings and greater efficiency will make up for increased demand, thus meaning that the demand will remain at the 2020 level). This was confirmed in a reply from Stephen Oxley dated 5th January 2009.

Thus, at a time when the government’s view was that energy demand would not increase long term, it had nevertheless decided to build more nuclear power stations to satisfy long term energy requirements that its own assessments say did not exist.

20. Why use modelling carried out for one purpose (Redpoint and the RES modelling) in order to ‘prove’ another thing? This defies logic and common sense, unless the objective was to show a need rather than carry out a proper analysis.

21. The government talks of an energy mix being desirable for energy security reasons – but already the commitment to nuclear is narrowing the energy mix. For instance:

(a) The full potential for renewables, as clearly indicated in Redpoint, was NOT assessed as a result of ‘new nuclear’

(b) We refer to row 1b) of our chart – why has the government made no long term assessments of possible energy reductions and efficiency in all the non-domestic sectors, when it has repeatedly acknowledged that energy efficiency is the cheapest and cleanest way of achieving energy policy objectives?

(c) We refer to row 5e) and the footnote thereto of our chart. Why did the government ignore the advice it was given in a statutory report on the potential for microgeneration, that advised that 2-3 million installations was a realistic target by 2020 and not adopt this target? In particular, if the government is so concerned about the need for new capacity to cover peak demand, why did it not even assess the extra electricity capacity that would be generated by such a programme – new capacity that would come on line before any new nuclear plants were even built?

(d) We refer to row 5f) of our chart and the footnote thereto. Why has the government ignored advice it was given in its own modelling on the potential for feed-in tariffs when that very modelling shows that a proper feed in tariff would result in 3.2GW of extra capacity by 2020 (and much of it before that date – i.e. before new nuclear power stations are even built)?

(e) And why base policy on the possible increase in capacity needs, when demand-side management by dynamic demand technologies could reduce that? No assessment of that alternative has been carried out.27

The plan to build new nuclear plant is reducing the diversity – not widening it.

CONCLUSION

22. The only conclusion can be that the government made up its mind about new nuclear – whether it is needed or not.

23. As we said at the outset: SEP is not in principle opposed to new nuclear power stations. What we have done in this response is simply answer question 18 posed in the government’s consultation:

‘Does the draft Nuclear National Policy Statement provide suitable direction to the Infrastructure Planning Commission on the need and urgency for new nuclear power?’

It may be that there is a case for new nuclear plant. But the government has not made the case for it: so the answer to that question is simply ‘no’. And In our chart we have attempted (for the first time as far as we have been able to discover) that which the government should have done before making up its mind.

24. Thus, if the Select Committee approves the government’s ‘strategy’ to build more nuclear power stations it will be approving a (so-called) strategy for which there is not only no proven need, but also one based on guesswork rather than an assessment of long-term electricity requirements and flawed process and figures re capacity.

That is no way to run a strategy.

January 2010

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[1] Emails from Helen Dwyer, Office for Nuclear Development

[2] ‘ I have spoken to Jonathan Wright at the Energy and Climate Change Select Committee to alert him to the fact that you have been waiting for a response from us before submitting your evidence’,- email to us from, Helen Dwyer , Office for Nuclear Development 18.1.10 informing us that she had contacted the Select Committee.

[3] As made clear in the Nuclear White Paper (NWP), published in January 2008. For instance by the Prime Minister himself ‘we need to take determined long-term action to reduce carbon emissions ....' including the way we generate energy. That is why the government has today concluded that nuclear should have a role to play.’ Foreword to the NWP page 4 [Our emphasis – SEP ] . The relevance of this date is explained in para 19 below

[4] Letter from Nick Hodgson Office for Nuclear Development 13.1.10

[5] Draft National Polic y Statement for Nuclear Power ( EN - 6) November 2009 page 6. Subsequently referred to as EN -6)

[6] Low Carbon Transition Plan page 170 Subsequently referred to as LCTP

[7] L CTP page 173

[8] Draft Overarching National Policy Statement for Energy EN-1 page 10. Subsequently referred to as EN-1

[9] EN-6 page 8 para 2.2.1

[10] EN-6 page 6

[11] Our emphasis - SEP

[12] EN-6 page 6

[13] ‘ Implementation of the EU 2020 Renewables Target in the UK Electricity Sector: RO Reform’ Redpoint Energy June 2009.

[14] EN-6 page 6 footnotes 15 and 16

[15] DECC Transcript of Leiston Public Meeting : https://www.energynpsconsultation.decc.gov.uk/home/events/localevents/

[16] Emails from Helen Dwyer Office for Nuclear Development 18 th and 19 th January 2010

[17] Redpoint pages 42-45

[18] Email from Helen Dwyer Office for Nuclear Development 18.1.10

[19] LCTP pag e 74; EN-1 page 18

[20] See Figure 11 and the explanation thereto on pages 42-43

[21] Page 13

[22] Page 104

[23] At page 18

[24] This states that 2G W has been recently completed; 8Gw is already under construction and 10.5Gw has planning consent and agreement to connect to the grid. A further 7.5Gw has been contracted and has applied for planning consent; and a further 20Gw CHECK is listed as ’transmission contracted’ but has not yet applied for planning consent.

[25] Page 18

[26] Not, we emphasize, this investigation by the Select Committee

[27] Dynamic Demand is technology that automatically switches off un-used and un-needed appliances during periods of peak demand.