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Home / News and Insights / Blogs / Planning Act 2008 / 897: Sizewell smashes question record plus carbon budget news

Today’s entry reports on the first set of questions issued on Sizewell and the government’s commitment on the sixth carbon budget.

Sizewell questions

The Sizewell nuclear power station DCO application was made back in May 2020 and its examination is finally under way. On Wednesday the Examining Authority of five inspectors issued its first set of written questions.

I have, as I always do, undertaken the task of counting the questions, making what I think are reasonable decisions along the way about what is a single question and what is more than one despite having one reference. Others’ calculated totals may therefore vary.

Before I reveal the total let us note that the first nuclear power DCO application was for Hinkley Point C in October 2011 and had just 17 questions in the first round. Those were the days. The second nuclear power DCO application was for Wylfa Newydd in June 2018 and had a record 1,006 questions, around 300 more than the previous record for any DCO application.

Each question can vary dramatically in the amount of work required to answer it. For example, Sizewell question DCO.1.115 merely says ‘Schedule 20 paragraph 45: Small typo “untilo”‘, whereas DCO.1.135 says (in essence); ‘please will the Applicant take into account any comments made by the Wylfa ExA [in its report] when preparing the next drafts of the DCO and the Explanatory Memorandum and explain why it proposes or rejects them’. OK, the answer could be ‘yes’ but that’s a lot of work for the next draft of the DCO. The raw number is therefore only a rough guide as to how much work is involved in preparing the answers, which must be submitted by 2 June – six weeks rather than the usual four!

So, on to the count. I am reminded of the Friends episode where Monica’s credit card is stolen and she gets a statement saying ‘Envelope 1 of 3’. The questions are divided into no fewer than six separate documents this time (I think the first time there have been more than one), with a covering document linking to them all and also containing abbreviations and definitions. One volume is devoted to biodiversity and habitats alone. In total, I make it, drum roll please, 2,229 questions. Yes, more than double, and an increase of over 1,200 on, the previous record. Woe betide anyone who submits another nuclear DCO as they are on track to get over 3,000 questions. Maybe the fact that the Examining Authority was appointed in July last year means they have had more time than usual to pore over the application come up with questions.

One is led to wonder how considered the answers will be (note that they aren’t nearly all for the applicant, though), but what alternative there might be to approaching this given a six month timetable? Perhaps something for the review of the regime that has just begun.

Incidentally the Examining Authority has accepted (for examination) the fifteen changes made by EdF to its application since it was made.

Carbon budget

Previous blogs, notably this one have referred to the five-yearly process of setting a carbon budget, which is to be done 12 years in advance. It is essentially how much CO2 is allowed to be produced over each period. The Climate Change Committee must make a recommendation by the end of the year 13 years before the budget period (ie 2020 for the sixth, 2033-37, period), and the government must actually set the budget taking the recommendation into account by 30 June the following year, ie this year for the sixth period.

The CCC recommended a 78% cut in carbon equivalent emissions from 1990 levels by this period, and that (the UK’s share of) international aviation and shipping be included in the total having not been included previously. (Interestingly the committee recommended that international shipping be included last time but the government did not agree).

On 20 April, two months early, the government announced that it would accept both elements of the recommendation: a cut in 78% and that international aviation and shipping be included. See this press release for more details.

The timing of the announcement may not be unadjacent to the 22-23 April US-convened climate summit (it was also Earth Day). The US has pledged to cut emissions by 50-55% by 2030 compared to 2005 levels. This is considerably below the UK target, which is for a cut of 68% on 1990 levels, which corresponds to a cut of about 63% of 2005 levels. Given that the US emits about 15 times as much CO2, though, the actual amount of carbon saved will be considerably more.

At the summit, our Prime Minister declared that the target was ‘not about some expensive green act of bunny hugging … this is about growth and jobs’, in response to which Greta Thunberg changed her twitter profile to ‘bunny hugger’.

Targets are all very well but steps must also be taken to achieve them. The government has already published a Ten Point Plan, an Energy White Paper and an Industrial Decarbonisation Plan. Two further documents are expected before the international climate change conference COP26 in Glasgow in November: the Transport Decarbonisation Strategy, apparently imminent, and a Net Zero Strategy later. These should help flesh out how the carbon reduction targets will be achieved by the sixth budget period and beyond.

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