10 November 2022

Interest in SMRs in the UK has been steadily building momentum in recent years, with increasing pace as Net Zero becomes business usual, shaping more long term investment decisions. However, we have noticed a marked increase in activity resulting from developers applying to the Future Nuclear Enabling Fund, which has forced them to think a bit more seriously about project deliverability which includes their strategy for siting and consenting.

With two clear potential sites in Wales, the differences in consenting regime with England is getting a lot of attention. In England any application for a generating station over 50MW automatically becomes a Nationally Significant Infrastructure Project (an NSIP) determined by Westminster, but in Wales a generating station remains with Welsh Government to determine until it exceeds 350MW, at which point it becomes the responsibility of Westminster.

For SMRs it is an important distinction in deciding which sites to pursue, added to by proposals under 50MW in England potentially finding themselves being determined not be central government at all, but by the relevant local planning authority, although a procedure is available to request a scheme like that to be picked up by Government.

There is no one “best” consenting route, with much turning on the individual site, optimum reactor size and progress that has been made with central and local government to support that particular development.

Developers rightly want to know how important it is to have their site recognised in officially endorsed policy, in this case the Nuclear National Policy Statement (EN-6). In an ideal world all nuclear sites would be specifically named in approved plans before being the subject of an application, but that looks unlikely and unnecessary given the slow pace at which policy like that can be advanced, the increasingly urgent demand for SMRs and the relatively limited development impact that scale of reactor will have (compared to conventional GW-scale reactors).

With it now being over 10 years since the first of the new fleet of UK reactors were first considered by the planning system, lessons learned from those first three full GW-scale applications are being closely looked at to improve the efficiency of the process, particularly for SMR-scale development.

Current examples we are seeing of this include :

  • “Project Speed” the UK Government initiative to shorten NSIP consent processes, where SMRs with vastly lower construction impacts compared to GW-scale are in a strong position to be considered for this benefit;
  • the emerging Welsh Infrastructure Consent regime, which will apply to electricity schemes up to 350MW, for which a Bill is currently under preparation for the Senedd (Welsh Parliament), which is very consciously cherry-picking the best parts of the NSIP consent process for projects in Wales;
  • the potential move from multi developer applications, to a narrower range of quasi-public bodies being applicants, such as Cwmni Egino and Great British Nuclear, bringing a higher degree of standardisation and evidence of government buy-in to applications;
  • a strong move to seeing SMRs integrate with specific local power generation needs, direct to industry in regional hubs or linked to new energy vectors like hydrogen production, rather than simply straight to grid generation; and
  • intelligent use of project parameters on initial consents to avoid future delays in seeking consent variations on future scaling-up.

In an increasingly demanding and competitive environment it is not just reactor design that is being simplified for multiple and rapid deployment, consent processes are coming under the same scrutiny and having to adapt.

If you have any questions or would otherwise like to discuss any issue raised in this article, please contact Patrick Robinson or Alex Minhinick.

Key contact

Patrick Robinson

Patrick Robinson Consultant

  • Energy and Utilities
  • Infrastructure
  • Planning and Compulsory Purchase

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