Policy paper

Summary of our consultation activities for NNB Generation Company (Hinkley Point C) Ltd's water discharge activity permit variation [EPR/HP3228XT/V005]

Published 31 July 2023

Applies to England and Wales

Here is a summary of consultation and engagement activity we carried out during consultations for NNB Generation Company (Hinkley Point C) Ltd’s application to change its water discharge activity permit in 2023.

1. When we consulted

We consulted on NNB Generation Company (Hinkley Point C) Ltd’s application from 24 January to 2 March 2023.

We consulted on our proposed decision and draft permit from 25 April to 25 May 2023.

Both consultations were in line with our public participation statement and the government’s published consultation principles.

2. Preparing for the consultations

We reviewed our equality analysis and stakeholder mapping for Hinkley Point C to inform our public engagement and communication activities.

We asked national and local stakeholders for their views on our engagement plan for Hinkley Point C before our consultations began. They provided feedback about their communities, the channels they use to read information and their preferred methods of engagement.

We considered that an application to change this permit at Hinkley Point C nuclear power station would be of high public interest. Following the first consultation, we reviewed the content and number of responses, and noted the level of public interest. We then decided to carry out further consultation on our proposed decision and draft permit.

3. Who we consulted

Both consultations were open to everyone. We invited the following groups to take part:

• the public (including local interest and action groups) in west Somerset and south Wales near to the Hinkley site
• elected representatives, including local councillors and MPs
• angling and environmental groups
• academics, scientists and consultants with an interest in nuclear power, energy or the environment
• non-governmental organisations (NGOs) and campaign groups
• other organisations and public bodies

For each consultation, we wrote to organisations who are statutory consultees. We informed them of the application and directed them to copies of the application online. We wrote to the same organisations again for the consultation on our proposed decision and draft permit. We directed them to our consultation online. The statutory consultee organisations were:

• Natural England (NE)
• Natural Resources Wales (NRW)
• Marine Management Organisation (MMO)
• Devon and Severn Inshore Fisheries and Conservation Authority (IFCA)
• Welsh Government Marine and Fisheries Division
• Office for Nuclear Regulation (ONR)
• Health and Safety Executive (HSE)
• Food Standards Agency (FSA)
• Sedgemoor District Council [until 31 March 2023]
• Somerset West and Taunton Council [until 31 March 2023]
• Somerset County Council [until 31 March 2023]
• Mendip District Council [until 31 March 2023]
• Somerset Council [from 1 April 2023]
• North Somerset Council
• Bristol City Council
• North Devon Council
• West Devon District Council
• Devon County Council
• Plymouth Council
• South Hams District Council
• Cornwall Council
• Vale of Glamorgan Council
• Cardiff Council
• Newport Council
• Bridgend Council
• Neath Port Talbot Council
• Swansea Council
• Carmarthenshire Council
• Pembrokeshire Council
• Monmouthshire Council
• Bristol Port Company
• Cardiff Harbour Authority

4. How we promoted the consultation on the application

To raise awareness and encourage participation, we carried out a range of activities.

We issued e-bulletins to over 2,000 contacts on our stakeholder database. Our database includes:

• national organisations and people who live near the Hinkley site such as parish and local councils in west Somerset and south Wales
• NGOs
• environmental groups and angling organisations
• professional institutions
• nuclear and environmental academics
• the nuclear industry and trade unions

We published information and the company’s documents on our consultation website which allowed people to respond online. This included a plain English ‘about this consultation’ document and ‘overview’ in which we were clear about the consultation process, the scope of consultation and how to respond.

We published general information about regulating Hinkley and the consultation on GOV.UK. We also published a public notice advert on GOV.UK .

We also:

• provided information about the consultation to NNB Generation Company (Hinkley Point C) Ltd so that its communication team could use it in communications to its staff, stakeholders and the public
• updated local MPs through briefings
• advertised the consultation and how to access the documents in local print and online newspapers (including the Bridgwater Mercury, Burnham & Highbridge Weekly News, Western Daily Press, Somerset County Gazette, West Somerset Free Press, Angling Times, South Wales Evening Post, South Wales Echo and the Angling Times), which could be read by people living near the Hinkley site and nationally
• issued a press release to local media and published it on GOV.UK. This resulted in some coverage in print and online media
• posted information on social media (Twitter and LinkedIn) to promote links to our consultation pages
• shared information with third parties and advocates such as local parish councils, Natural Resources Wales, NGOs and environmental groups, securing their support to raise awareness
• attended the Hinkley Point C community forum to update attendees
• provided information to our staff closest to the site so they would be able to answer questions from the public in the area

To engage directly with stakeholders during the consultation, we:

• organised an online meeting on 2 February 2023, providing speakers from the Environment Agency with expert technical knowledge
• advertised the event to our Hinkley stakeholder contact list
• provided a postal address for those who did not want to, or could not use email or respond online to the consultation

We believe that the level of engagement was proportionate for the application consultation. We are also confident that this consultation was accessible to, and targeted at, the people and organisations it was intended for.

5. Results of the application consultation

We received 50 responses from organisations and individuals.

We put the responses to the consultation on the public register, except where the person making the response asked us not to do so. We also published the responses received on our consultation website.

We evaluated the consultation and engagement.

6. How we promoted the consultation on the proposed decision and draft permit

To raise awareness and encourage participation, we carried out a range of activities.

We issued e-bulletins to over 2,000 contacts on our stakeholder database. Our database includes:

• national organisations and people who live near the Hinkley site such as parish and local councils in west Somerset and south Wales
• NGOs
• environmental groups and angling organisations
• professional institutions
• nuclear and environmental academics
• the nuclear industry and trade unions

We published information and the company’s documents on our consultation website which allowed people to respond online. This included a plain English public summary in which we were clear about the consultation process, the scope of consultation and how to respond.

We updated our regulating Hinkley page on GOV.UK and published a notice of consultation on GOV.UK.

We used local media and social media to get information out to people, we:

• advertised the consultation and how to access the documents in local print and online newspapers (including the Bridgwater Mercury, Burnham & Highbridge Weekly News, Western Daily Press, Somerset County Gazette, West Somerset Free Press, Angling Times, South Wales Evening Post, South Wales Echo and the Angling Times), which could be read by people living near the Hinkley site and nationally
• issued a press release to local media and published it on GOV.UK. This resulted in some coverage in print and online media
• posted information on social media (Twitter and LinkedIn) to promote links to our consultation pages

We updated local MPs through briefings.

We worked with third parties and advocates such as:

• local parish, town and Somerset councils
• NGOs and environmental groups

We asked for their support to raise awareness with their networks and communities.

We said we would provide printed copies of the consultation documents and public summary on request.

We worked with NNB Generation Company (Hinkley Point C) Ltd to promote the consultation and:

• provided information about the consultation to its communication team to use in communications to its staff, stakeholders and the public
• sent information to the Hinkley Point C community forum to update attendees

We provided information to Environment Agency staff closest to the site so they would be able to answer questions from the public in the area.

To speak directly with stakeholders during the consultation, we organised an online presentation and meeting on 10 May 2023. We provided technical experts to help answer questions.

We also:

• responded to extra questions submitted by email before and after the meeting
• highlighted the consultation to members of the Department for Energy Security and Net Zero NGO forum
• provided a postal address for those who did not want to, or could not use email or respond to the consultation online

7. Documents we published

We published documents on GOV.UK and on our consultation website. We also printed copies and made them available to those who requested them.

We published a shorter, less technical summary version of the consultation document aimed at the public who have some interest in nuclear issues. We translated this document into Welsh for stakeholders in south Wales.

We also published a series of technical documents that may need specialist knowledge to understand them. These included our proposed decision document and draft permit and technical assessments to support our decision. These technical documents were:

• draft permit for water discharge activity
• proposed decision document for variation of the water discharge activity permit
• Habitats Regulations assessment report
• SSSI assessment report
• Water Framework Directive compliance assessment report

You can find all of these technical documents in the documents section of the permit consultation page on GOV.UK.

8. Results of the consultation on our proposed decision and draft permit

We received 193 responses from organisations and individuals.

We put the responses to the consultation on the public register, except where the person making the response asked us not to do so. We also published responses on our consultation website .

The decision document includes how we considered and addressed the issues raised by consultees.

Following the consultation, we evaluated our engagement and communications plan, and feedback from the public events. This review will inform our future work.

We are confident that we did all we should do to properly consult, and that this consultation was accessible to, and clearly targeted at, the people and organisations it was intended for.

We are grateful to all who took the time to respond or contribute to our consultation events.