Policy paper

Summary of our 2020 and 2022 consultation activities for NNB Generation Company (Sizewell C) Ltd's permits

Updated 28 March 2023

Applies to England

Here is a summary of consultation and engagement activity we carried out during 2020 and 2022 for NNB Generation Company (Sizewell C) Ltd’s environmental permit applications.

1. When we consulted

We advertised and consulted on NNB Generation Company (Sizewell C) Ltd’s application from 6 July to 2 October 2020.

We consulted on our proposed decision and draft permits for 12 weeks from 4 July to 25 September 2022

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

2. Preparing for the consultations

For each consultation, we carried out an equality analysis and a stakeholder mapping exercise to inform our public engagement activities. For the 2022 consultation, we reviewed the equality analysis and stakeholder mapping exercise that we had prepared for the 2020 consultation.

We considered that the development of Sizewell C nuclear power station is of high public interest so each consultation ran for 12 weeks.

We asked national and local stakeholders for their views on the consultation process 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 their responses and the extra challenges of consulting during coronavirus (COVID-19) restrictions and published our engagement plan.

The 2020 consultation was held during a period of government restrictions on the movements and activities of the public due to the COVID-19 pandemic. So, we were not able to hold consultation drop-in sessions or place copies of the application in local libraries and other local community buildings.

3. Who we consulted

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

• the public
• the energy industry
• academics with an interest in nuclear power, energy or the environment
• non-governmental organisations (NGOs) and other organisations
• 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 2022 consultation on our proposed decision and draft permits. We directed them to our consultation online. The statutory consultee organisations were:

• Office for Nuclear Regulation (ONR)
• Food Standards Agency
• Natural England
• Marine Management Organisation
• Centre for Environment, Fisheries and Aquaculture Science
• Eastern Inshore Fisheries and Conservation Authority
• Health and Safety Executive
• East Suffolk District Council
• Suffolk County Council
• Public Health England (now the UK Health Security Agency)
• Ipswich and East Suffolk Clinical Commissioning Group (now - NHS Suffolk and North East Essex Integrated Care Board)
• Anglian Water
• Department for Business, Energy and Industrial Strategy (BEIS) (now Department for Energy Security and Net Zero)
• Committee on Medical Aspects of Radiation in the Environment
• Low Level Waste Repository Limited
• The Broads Authority
• Historic England

4. How we promoted the 2020 consultation

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

We issued e-bulletins to over 800 contacts on our stakeholder database. Our database includes:

• national organisations and people who live near the Sizewell site such as parish and local councils
• NGOs
• environmental groups
• 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. We published the permit applications for the:

• combustion activity

• radioactive substances activities

• water discharge activity

We published general information about regulating Sizewell and the consultation on GOV.UK which included providing a plain English, high-level summary. In this, we were clear about the consultation process, the scope of consultation and how to respond. We also:

• worked with NNB Generation Company (Sizewell C) Ltd to make copies of the application available on USB memory sticks
• updated local MPs through briefings
• advertised the consultation in local print and online newspapers (East Anglian Daily Times and the Ipswich Star), which could be read by people living near the Sizewell site and nationally
• issued a press release to trade, national and local media. This resulted in some coverage in print and online media
• posted information on social media (Twitter) to promote links to our consultation pages
• worked with third parties and advocates such as local parish, town and county councils, NGOs and environmental groups, securing their support to raise awareness
• added information to NNB Generation Company (Sizewell C) Ltd’s community newsletters which are sent to all households in the area and an email subscriber list
• attended the Sizewell C community forum to update attendees on plans for consultations on permits
• provided information about the consultation to NNB Generation Company (Sizewell C) Ltd for their communication team to use in communications to its staff, stakeholders and the public
• 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 consultation, we:

• organised a public question and answer session by telephone on 20 July 2020 providing speakers from the Environment Agency with expert technical knowledge
• advertised the events widely online and sent details to our stakeholder database
• highlighted the consultation to members of the BEIS NGO forum
• informed attendees of our bi-annual nuclear regulator local engagement meetings which we hold with stakeholders in Essex and Suffolk
• provided a postal address for those who did not want to, or could not use email or respond online to the consultation
• put in place processes to enable people to respond to the consultation over the telephone

We believe that the level of local and national engagement was proportionate for the application consultation. We are confident that we did all we reasonably could and consulted properly during the period of COVID-19 restrictions. 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 2020 consultation

We received 79 responses from organisations and individuals:

• 27 for the radioactive substances activity application
• 24 for the combustion activity permit application
• 28 for the water discharge activity permit application

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 2022 consultation

To raise awareness and encourage participation, we issued e-bulletins to over 800 contacts on our stakeholder database, both at the start of the consultation and towards the end as a reminder. Our database includes national organisations and people who live near the Sizewell site such as:

• parish and local councils
• NGOs
• environmental groups,
• professional institutions
• nuclear and environmental academics
• the nuclear industry and trade unions

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

• advertised the consultation in local print and online newspapers (East Anglian Daily Times and the Ipswich Star), which could be read by people living near the Sizewell site and nationally
• issued a press release to trade, national and local media. This resulted in some coverage in print, broadcast and online media
• published a blog about our work regulating Sizewell
• posted information on social media (Twitter and LinkedIn) to promote links to our consultation pages
• published an A5 consultation information leaflet which was delivered by Royal Mail to 13,250 households local to the proposed power station

We updated local MPs through briefings.

We worked with third parties and advocates such as:

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

We asked for their support to raise awareness – including asking them to send posters to libraries, local organisations and parish councillors.

We distributed printed copies of the consultation documents and public summary at local offices and libraries such as:

• Environment Agency Horizon House (Bristol)
• Environment Agency Iceni House (Ipswich)
• East Suffolk Council
• Suffolk County Council,
• Leiston, Aldeburgh, Woodbridge and Saxmundham libraries
• Sizewell C’s information office in Leiston
• town council offices in Leiston, Saxmundham, Aldeburgh, Woodbridge

Printed copies of these documents were also available on request and sent proactively.

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

• added information to their newsletters which are sent to all households in the area and an email subscriber list
• provided information about the consultation to their communication team to use in communications to its staff, stakeholders and the public

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 public drop-in events at the following locations which were attended by 86 members of the community:

• Saxmundham Market Hall on 14 July 2022
• Aldeburgh Parish Church Hall on 15 July 2022
• Leiston Community Centre on 16 July 2022

We provided technical experts for all the public events to help answer questions.

We also:

• held a meeting with Leiston Town council on 1 September 2022
• held an online consultation event (advertised by ebulletin) on 8 September 2022 with presentations and an opportunity for attendees to ask questions and discuss issues raised
• advertised our events widely online and by ebulletin to our stakeholder database
• highlighted the consultation to members of the BEIS NGO forum
• informed attendees of our bi-annual nuclear regulator local engagement meetings which we hold with stakeholders in Essex and Suffolk
• provided a postal address for those who did not want to, or could not use email or respond to the consultation online
• offered telephone appointments for those who did not want to, or could not participate in online events or attend the drop-in events

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

• draft permit for radioactive substances activity
• consultation document for radioactive substances activity
• draft permit for water discharge activity
• consultation document for water discharge activity
• draft permit for combustion activity
• consultation document for combustion activity
• radiological impact assessment – we commissioned an independent assessment of the impact of radioactivity on members of the public, plants and animals using the proposed discharge limits
• SSSI assessment – covers all 3 permits
• Water Framework Directive assessment

We published a habitat regulations assessment (HRA) to cover all 3 permits which was broken down into:

• Book 1 radioactive substances activity permit HRA
• Book 2 combustion activity permit HRA
• Book 3 water discharge activities HRA
• Likely significant effect screening

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

On our consultation website we also published Schedule 5 legal notices specifying:

• the further information we need from NNB Generation Company (Sizewell C) Ltd and the date by which it must provide it
• NNB Generation Company (Sizewell C) Ltd’s Company Manual
• relevant letters

8. Results of the 2022 consultation

We received 133 responses from organisations and individuals:

• 57 for the radioactive substances activity permit application
• 33 for the combustion activity permit application
• 42 for the water discharge activity permit application

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.

Some of the consultation responses were outside of the scope of consultation and our remit. We passed these onto the relevant bodies such as ONR or BEIS. The decision documents cover 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.

*[NGOs}: Non-governmental organisations