Written evidence submitted EDF (NPE0002)

EDF is the UK’s largest producer of low carbon electricity. EDF operates low carbon nuclear power stations and is building the first two of a new generation of nuclear plants in the UK. EDF also has a large and growing portfolio of renewables, including onshore and offshore wind and solar generation, as well as energy storage. With over five and a half million electricity and gas customer accounts, including residential and business users, EDF aims to help Britain achieve net zero by building a smarter energy future that will support delivery of net zero carbon emissions, including through digital innovations and new customer offerings that encourage the transition to low carbon electric transport and heating.

EDF welcomes the draft National Policy Statement (NPS) EN7. Ensuring an effective nuclear siting policy is crucial to the continued growth of the sector which, in turn, will benefit the UK. Nuclear energy is reliable, affordable, and low carbon and contributes to greater energy independence and supports high-quality jobs and economic growth.

In summary:

•                                                               EDF broadly agrees that the draft NPS EN7 provides a clear and effective framework for planning new nuclear infrastructure. The NPS is future-proofed, given its technology agnostic approach and reliance on criteria which allows much greater flexibility for future siting.
•                                                               This flexibility is helpful, but some coordination from Government is still needed to deliver the best outcome overall for the UK. For instance:
•                                     The importance of the EN6 sites, which have previously been assessed, and their local supportive communities cannot be underestimated. These are likely to provide the best sites for the immediate next phase of new nuclear development.
•                                     Some sites are best suited for GW-scale technology, with more sites being able to accommodate smaller technology. Wylfa Newydd site is currently the best option in the UK for further large-scale nuclear technology beyond Hinkley Point C and Sizewell C.  An effective siting policy should keep these options open thereby maximising the potential for the UK from suitable sites.
•                                     Similarly, the NPS needs to effectively link to other policy developments such as the Government’s Modern Industrial Strategy, growth in AI and the NESO’s Strategic Spatial Energy Plan. Nuclear is well suited to decarbonising UK industry and providing much needed low carbon baseload power to support AI data infrastructure.

We have set out our response to the call for evidence questions in the annex to this letter.

Annex 1:

1. Does EN-7 provide a clear and effective framework for planning new nuclear infrastructure, including both large-scale and modular technologies? 

EDF broadly agrees that the document provides a clear and effective framework for planning new nuclear infrastructure. EDF agrees that the draft NPS is, for the most part, sufficiently future-proofed to accommodate different kinds of nuclear technology, whether large-scale or smaller technologies.

In our response to the consultation, EDF expressed some concern at the removal of deployment timelines. EDF suggested that there still needed to be emphasis behind timelines in the NPS, given our experiences with Hinkley Point C and Sizewell C. There should be urgency when it comes to consenting projects as maintaining momentum behind them is crucial to their delivery and, whilst urgency of building new generation and transmission is mentioned, EDF suggests that this is further emphasised in EN7.

As per our previous response, EDF welcomes the flexibility that is built into EN7, which marks a more open approach to new nuclear siting. In follow-up conversations with DESNZ, EDF expressed some concern that the references to EN6 sites in the NPS were not definitive enough. Our concern was that the importance of the sites to future nuclear strategy had not been sufficiently reflected in the draft.

EDF still emphasises that the existing EN6 sites are crucial to delivering new nuclear projects in the UK and should remain a central focus of government strategy. These sites are among the few that are de-risked, construction-ready, and supported by local communities—an invaluable asset when initiating new projects. EDF supports a logical, phased approach to nuclear siting that prioritises the use of these known sites, recognising their spatial, infrastructural, and grid advantages. The Government owned Oldbury site is a good example which will provide for early development of Great British Energy- Nuclear (GBEN)’s Small Modular Reactor (SMR) programme and can accommodate the recently selected Rolls Royce SMR technology.

While EDF welcomes the flexibility offered by the new NPS, it cautions against an overly open-ended approach. For instance, some sites are likely to be better suited to larger scale (GW) new nuclear while other sites are better suited to different types of technology which can more easily decarbonise industrial processes or can meet locations of new demand for baseload low-carbon power such as data centres.

Unless there is some form of coordination then a fully open policy could undermine the future viability of large-scale GW nuclear developments. Beyond Hinkley Point C and Sizewell C, Wylfa Newydd is likely the only feasible site in the UK for GW-scale deployment. It is therefore vital that siting policy remains definitive enough to guide developers in making efficient use of land and selecting the right technology for each site, while also promoting effective co-location to maximise benefits to the UK.

Nuclear is uniquely constrained in terms of viable sites that can realistically be developed within the necessary timelines to meet the UK’s clean power goals. This reinforces the need for a staged, prioritised spatial assessment approach—one that starts with proven EN6 sites and gradually expands into wider spatial analysis. This future siting policy must align with broader strategic objectives, including the Strategic Spatial Energy Plan, AI Growth Zones, and industrial cluster development, to ensure a balanced, deliverable energy transition.

A good example is the Hartlepool site. This site presents unique opportunities for industrial synergies due to its location within a cluster of industrial activity and the potential for Advanced Modular Reactor (AMR) development. The station's existing infrastructure, skilled workforce, and proximity to industrial heat and hydrogen users create a favourable environment for innovative projects like AMRs, which can provide both electricity and high-temperature heat for industrial processes

Similarly, some of the potential feasible sites will be much better aligned to support the rapidly growing data centre market due to their proximity to communication links. Some overall coordination will be helpful to maximise the value from the available sites to the UK economy.

2. Is the proposed criteria-based approach to siting appropriate, and does it adequately balance flexibility, safety, and impact on communities and the environment? 

EDF broadly agrees that the approach adequately balances flexibility, safety and impact on communities and the environment. However, as noted above, if the flexibility of the policy means that the potential of different sites is not maximised for the benefit of the UK, then this may lead to sub-optimal outcomes. Once again, having a welcoming community at the site of a nuclear development should not be underestimated in the process of building new nuclear.

The differing characteristics of EN6 sites must therefore be fully considered, as the speed of delivery will depend significantly on local infrastructure and community support. EDF welcomes government consideration on how best to utilise the Wylfa Newydd site. The site remains the best site for deploying nuclear capacity because of its supportive community, the strong history of nuclear deployment and the significant amount of work that has already been done to plan for potential deployment at the site. Any viable continuation of the transformation of the nuclear sector in the UK must involve Wylfa and the community are, rightly, calling for progress.

Maximising the Wylfa opportunity means recognising that it is the best site in the UK for further GW scale plants. The site has enough space and sufficient lay-down areas that makes deployment of multiple units at the site a real prospect. The size of the site could also mean that SMRs could be deployed alongside GW scale, however any firm decision to move forward with a SMR programme at Wylfa presently could curtail the option for future GW scale development unless co-development is planned from the beginning.

Another area where we believe the approach is less balanced is with regards to the Semi-Urban Population Density Criterion (see below).

3. The draft EN-7 retains a Semi-Urban Population Density Criterion (SUPDC) for siting. Is this criterion, as drafted, appropriate for all potential nuclear technologies, including SMRs? 

EDF suggests that the inclusion of this criterion in the NPS should be reviewed. This is in line with our previous response. An over-cautious approach that is not led by risk could mean less effective deployment of advanced nuclear technologies at certain sites.

Government should therefore consider, with the help of industry, reviewing this criterion in line with enhanced safety features of new reactors, availability of stronger safety case evidence and better emergency planning arrangements for GW-scale technology.

4. Is EN-7 adequately future-proofed to accommodate advancements in nuclear technologies? 

EDF agrees that the new NPS is adequately future-proofed to accommodate advancements in nuclear technologies. This is because of the technology agnostic approach and its recognition that deployment of nuclear will look different in future, given the different technologies, sizes and options for co-location that are becoming available as technology changes.

5. How does EN-7 compare to international approaches? Are there lessons to be learned from other countries’ planning systems? 

No comment.

6. Are there any other issues, concerns, or opportunities the Committee should consider in relation to EN-7? 

The Committee should also consider the additional criteria proposed in the draft NPS. EDF is concerned with the inclusion of additional criteria that were not proposed during the 2024 consultation: Seismic Hazard and Ground Conditions, Emergency Planning and Meteorological Conditions. EDF are concerned that bringing new criteria, that are better suited to being considered by regulators and local authorities, into the NSIP process will lead to inefficiencies. Inclusion is unhelpful as it can lead to the duplication of work between regulating bodies and unhelpful resequencing of work (i.e. starting work on emergency planning arrangements much earlier than would normally happen).

Separately, EDF are concerned with the number of overarching strategic documents being iterated simultaneously at the moment, and how they all fit together to provide a coherent framework. In particular, how the NESO’s Strategic Spatial Energy Plan, grid connections reform and the Centralised Strategic Network Plan will consider Government’s Modern Industrial Strategy, and how this will work alongside the NPS. A good example of this is Government’s current assessment of AI Growth Zones. Nuclear has the potential to play an important role to support substantial future UK data needs. We note that former coal sites such as the Trent Valley including the Cottam site, can generally offer a faster route to licencing than brownfield sites. This sort of coordination will bring greater benefits to the UK.

Finally, planning and environmental regulations are a key part of the overall framework impacting the future deployment of new nuclear. While not in scope of EN7, there is a clear need for reform of these regulations to tackle inefficiencies and address disproportionate approaches. Suggestions for how to improve the nuclear regulatory landscape can be found in our response to the ongoing taskforce review.[1] Regulation is important to consider in tandem with the draft NPS, so that the framework surrounding future nuclear siting is as robust and effective as it can be.

August 2025