Neglected Large-Scale Value for Money Issues in Public Accounting for Costs of the Defence Nuclear Enterprise

evidence to the House of Commons Public Accounts Committee Inquiry on the Defence Nuclear Enterprise, 9th July 2018

Prof. Andy Stirling FAcSS and Dr Phil Johnstone, Science Policy Research Unit, University of Sussex

19th June 2018



1: Introduction and Summary

1.1: This document offers as written evidence a review of issues that are of direct relevance to the core topic of the National Audit Office (NAO) report of 2018 concerning ‘the Defence Nuclear Enterprise(henceforth ‘NAO Report’) [1] on which we understand that the Public Accounts Committee (PAC) will hear evidence on 2nd July 2018 [2]. As such, the material summarized here supplements and updates evidence published by the PAC Inquiry of October 2017, that was taken as a basis for oral questions on the Hinkley Point C nuclear power station [3]. The authors believe on grounds of many years of research at the Science Policy Research Unit at the University of Sussex [4], that the matters documented here raise large-scale, long-run value for money issues of pressing national importance, which remain seriously neglected in work to date either by the NAO, the PAC or any other official bodies – and which are therefore gravely under-scrutinized by Parliament or wider UK policy debates.

1.2: In short, the central question that we raise here concerns an evidently major risk of under-estimation of the full indirect costs to the UK of maintaining the national nuclear industrial infrastructures that underpin the Defence Nuclear Enterprise. In the past, it has effectively been taken for granted that these wider indirect costs will be supported by a civilian national nuclear power industry. We document in this evidence, that a practice has evolved under these conditions, of simply assuming that these flows of resources on the civilian side can be excluded from any accounting for the total costs of the Defence Nuclear Enterprise. But recent dramatic developments in the energy sector reviewed by the NAO in relation to the Hinkley Point C project substantively undermine such assumptions. Fundamental questions now arise over the viability of civil nuclear power as a reasonable means for the UK to seek to secure affordable, secure, low carbon energy services. So, it is no longer analytically tenable or politically justifiable simply to assume that the Defence Nuclear Enterprise will be supported by these revenue streams. Under circumstances where nuclear power is recognised on balance to be an unfavourable electricity supply technology for the UK, the only reasonable or rigorous way to account for costs of the Defence Nuclear Enterprise will be to associate them fully with military nuclear commitments.

1.3: This raises potentially extremely large value for money issues of direct relevance to the remit of the current PAC Inquiry. If the accounting practices that inform Parliamentary scrutiny fail to consider the implications of the possible discontinuing of an uneconomic UK civil nuclear power industry, then they will seriously underestimate the full costs of the UK Defence Nuclear Enterprise. The actual costs that would eventually need to be borne in this instance by the defence budget, would be very significantly higher. Conversely, if an otherwise uneconomic UK civil nuclear power industry were to be supported partly on grounds that this would help spread the costs of the Defence Nuclear Enterprise, then foregone benefits of substitution by more economic alternative low carbon electricity supply technologies would entail a potentially very large additional long-term cost that would fall on electricity consumers. The broad magnitude of economic flows involved are indicated by the NAO estimate that (even when discounted) the “top-up payments” associated with the Hinkley Point C contracts (by comparison with default anticipated wholesale electricity prices) amount to £30 billion [5]. If questions around these issues are not examined at this early stage, then major policy decisions in the near future may incur contractual or infrastructure commitments that effectively make the associated major elevated costs for the UK defence budget or electricity consumers irreversible.

1.4: Crucial to recognise here, is that raising these issues implies no prejudgement of wider arguments over the case for or against nuclear power as an energy source, or indeed, on either side of arguments around national nuclear weapons capabilities. When examining long-run policy commitments of the kind represented by both civil and military nuclear infrastructures, it is simply a matter of rigour, integrity and accountability to give attention to all relevant emerging scenarios. A failure fully and rigorously to examine such manifestly salient questions at this stage around the full costs of the UK Defence Nuclear Enterprise, would also raise important issues of transparency, accountability and democracy in UK Parliamentary and wider policy processes [6]. More specifically, a failure fully to examine these large scale economic and political implications might gravely jeopardise the reputations of the political and administrative bodies concerned with exercise of due diligence in accounting for economic implications of UK public policy decisions.


2: The Background

2.1: The analysis reported in this evidence has been widely published without refutation [7], including in earlier evidence to the PAC [8]. Questioned by the Committee on the basis of this evidence, Stephen Lovegrove (the former Permanent Secretary of DECC responsible for negotiating civil nuclear contracts and now Permanent Secretary at MoD) briefly confirmed key points at issue [9]. At the centre of resulting questions lie major value for money concerns beyond those already scrutinized by NAO in relation to arrangements for supporting UK civil nuclear power. The 2017 NAO Hinkley Point C report found that this support “…has locked consumers into a risky and expensive project with uncertain strategic and economic benefits[10]. With regard to possible reasons for this, NAO referred repeatedly to the importance for Government of other “wider strategic” considerations [11]  beyond the officially-stated “energy trilemma” around ‘affordability’, ‘climate change’ and ‘energy security’ [12].

2.2: What is crucial about recent developments in global energy markets – however they are viewed – is that it is now clear that in respect of all three horns of this trilemma, earlier Government rationales for nuclear support are now seriously overturned [13]. Official UK data repeatedly documents that non-nuclear sustainable energy options are: at least equally favourable with regard to carbon emissions; more secure from various threats of disruption; and available at unambiguously lower cost [14]. Longstanding trends suggest the economic advantages will continue to grow over time. With UK renewable resources established as ample to accommodate foreseeable demand, the National Grid Company identifies ‘base load’ to be an “obsoleteconcept [15] . A host of means are available to manage intermittent wind power at a fraction of its growing cost advantage [16]. Although definitive analysis is complicated, there is no reason to view jobs available from renewable investments to be less than those associated with nuclear power [17]. It is a reflection of this picture, that global investment in renewable energy already exceeds that in all other generating technologies put together, with the gap growing fast [18]. So the intensity of continued UK Government commitments to a “nuclear renaissance[19] is a clear international anomaly [20].

2.3: Central to any determination of value for money in these continued arrangements for strong official UK support for civil nuclear power, is therefore to ask why the Government remains so distinctively attached under these circumstances to this increasingly obviously unfavourable energy source [21]? The question is compounded, when it is noted that the UK does not host an internationally competitive civil nuclear industry of its own [22] (of a kind that might help cause such evident lock-in [23]). Instead, the official data actually confirms the UK to stand to benefit from a cost-effective renewable energy resource that is the envy of most other countries [24]. It is on all these grounds that it is so remarkable that the question has nowhere been directly, thoroughly or systematically addressed in any UK energy policy process over the past decade, as to why this situation should persist.

2.4: Instead of rigorously examining such questions, much mainstream expert policy analysis in this field tends simply to take for granted a continuing imperative to maintain some level of nuclear power in the UK energy mix [25]  and then ask merely how this assumed necessity might most effectively be delivered [26]. A close reading of the 2017 report referred to above, for instance, shows the NAO themselves to be very clear about these highly idiosyncratic constraints. For instance, NAO are explicit that the grounds for strategic support for nuclear power is not interrogated in their analysis, but taken as a given [27]. Indeed, they are as critical in this discussion as it is reasonably possible for them to be about wider Government strategy, when they note that the “[t]he Department has not formally reviewed and consulted on its published strategic case for nuclear power since the publication of the 2008 white paper[28]. The picture could hardly be clearer, that there exists a serous gap in substantiating major value for money issues in this crucial policy area [29].


3: Links Between Civil and Military Nuclear Commitments in the UK

3.1: Highly relevant to establishing why such pressing questions over value for money should have been neglected for so long in such an important policy area, is to ask about the possible reasons for the stark dearth of timely strategic scrutiny diagnosed by the NAO [30]. It is in seeking to address this gap, that our own research in SPRU has interrogated a very wide range of public documents and grey literature also extending outside energy policy [31]. The results of this analysis – and elaborations and substantiation for all the argumentation outlined in this letter – are detailed in our recent evidence published by the PAC  [32]. In short, a prima facie case emerges quite clearly from our research, which we believe to be sufficient to warrant rigorous, comprehensive and detailed further formal scrutiny both by the NAO and by the PAC. This is, that the “other strategic factors” noted by the NAO to be necessary to explain continued official UK support for civil nuclear power (but which remain officially entirely undiscussed elsewhere) are not so much related to stated energy policy aims, but are in fact more to do with a perceived military imperative to maintain national capabilities to build and operate nuclear-propelled submarines [33].

3.2: We are aware of the gravity of identifying such an under-addressed problem with such significant value for money implications in a country taking such pride in rigorous and democratic policy procedures. To urge that such issues form a focus for formal investigation by the NAO or PAC (with so many other pressing duties), imposes a high burden of plausibility. But it is for reasons documented here, that we believe the available evidence demonstrably satisfies this demanding criterion. In short, it is very openly argued in UK policy documents on the military side, that there exist serious concerns that the national nuclear ‘submarine industrial base’ would not be sustainable, if a decision were taken to discontinue UK civil nuclear power. [34]. Statements from UK nuclear submarine industry sources are very clear about the crucial interlinkages [35] – explicitly noting incentives to “mask” the costs of this military programme behind the related civilian industrial infrastructure [36]. Indeed, UK naval reactor manufacturer Rolls Royce dedicate an entire section of a recent report advocating ostensibly civilian small modular reactors to the detailing of “advantages to the UK’s nuclear deterrent programme[37]. With similar dependencies increasingly openly discussed in other countries [38], it was these linkages that were briefly acknowledged (but not yet followed up on) in the evidence referred to above to the PAC from a senior civil servant fulfilling key roles both in DECC and MoD 5.

3.3: But perhaps the most salient point in this regard, for purposes of the present Inquiry, is that the 2008 NAO analysis of UK military nuclear activities should also be so clear about this same dynamic. Most significantly, this report found that “[o]ne assumption of the future deterrent programme is that the United Kingdom submarine industry will be sustainable and that the costs of supporting it will not fall directly on the future deterrent programme[39]. If the costs of keeping the national nuclear submarine industry in business must fall elsewhere, what could that other budget be? Remarkably, this question remains entirely unanswered – even by the most recent NAO report of May 2018 on the ‘The Defence Nuclear Enterprise’, which still leaves the central queries here unaddressed [40]. So the prima facie case remains very clear that it is this military rationale around national nuclear submarine capabilities that dominates what the NAO refers to in the view of the “the Department” (but does not itself endorse) as “unquantified strategic benefits” that are driving UK Government support for uneconomic civil nuclear power [41]. This is the situation that we believe justifies direct further analysis both by the NAO and by the PAC.


4: Conclusions

4.1: To conclude, the depth and significance of the resulting value for money issues are readily summarized. We present compelling evidence that UK policy arrangements addressed at supporting uneconomic civil nuclear power are engineering a large scale long term transfer of resources away from UK electricity markets and into joint civil/military provision for the specialist skills and supply chain seen to be essential to maintaining UK nuclear submarine capabilities. With electricity prices thus elevated over what they would otherwise be if renewable energy were supported instead of nuclear power, this under-interrogated process amounts to a large but as-yet undetermined de facto subsidy at the expense of electricity consumers and to the benefit of military interests. A broad picture of the order of magnitude of the associated costs are indicated by the NAO estimate of Hinkley Point C “top-up payments” at around £30 billion [42]. Although there is no public policy discussion of the rationales or pressures underlying this remarkable state of affairs, an attraction to Government appears to lie in the triple aim of: (1) finding a means to cover the otherwise insupportable costs of a major military commitment; (2) whilst keeping the resulting expenditures away from inconvenient public scrutiny; and (3) entirely off the public books.

4.2: In attending to these matters, this evidence raises serious value for money issues equally at the overall level of UK Government procedures for ensuring due diligence, scrutiny and accountability in general national expenditure, and with regard to both UK energy policy and UK defence strategies in particular. In the case of energy policy, this is because it is now beyond reasonable contention, that the economic and wider strategic case for nuclear power has collapsed, with other low carbon energy service strategies based on renewable energy and energy efficiency offering manifestly superior value for money. On the defence side, the value for money concerns arise in the situation documented by the NAO in 2008 (but since oddly neglected), that current estimates of the costs of maintaining UK nuclear submarine capabilities effectively account only for the purchase and operation of the submarines themselves and not for additional expenses attached to sustaining the associated necessary wider nuclear engineering industry. Such an accounting gap would have the effect of seriously understating the full costs of maintaining the UK nuclear submarine programme.

4.3: It is on these grounds that we respectfully urge the PAC to consider making a request to the NAO, to undertake a dedicated comprehensive analysis of the strategic value for money issues associated with linkages between civil and military nuclear infrastructures in the UK [43]. Put simply, a key practical query at the core of this issue is: “what would be the impact on the total indirect as well as direct costs of the UK Defence Nuclear Enterprise, of a national decision that growing obsolescence has now undermined the case for further developing a UK civil nuclear power infrastructure?”. Conversely:what would be the impact on the total costs of electricity borne by UK consumers over the course of civil nuclear contracts, if these otherwise unfavourable contracts terms were justified by the aim of supporting the Defence Nuclear Enterprise?Both as specialist researchers in this field and as citizens concerned about rigour, transparency and accountability – as well as value for money – in UK policy, we stand ready to assist this process in whatever ways we are able.



              NAO, 2018.

[2]               As notified (as of 30th May 2018) at:

[3]               As published (as of 30th May 2018) at:

[4]  This research has led to various outputs including a working paper (Cox et al., 2016) and journal article (Johnstone and Stirling, 2016), and articles in The Guardian here and here (Phil Johnstone and Stirling, 2015a; Stirling and Johnstone, 2018). A further blog post in The Conversation (Johnstone and Stirling, 2015) and a two part blog for the Oxford Security Group (Johnstone and Stirling, 2017a, 2017b) available here and here. The work has also been discussed in a news story and long read article in The Guardian (Watt, 2017a, 2017b), and has been covered in the New York Times in 2016 (Wynn-Kirby, 2016), and the German daily Die Tageszeitung (Sotscheck, 2016). See also: Stirling & Johnstone, (2018). Why is the UK government so infatuated with nuclear power? Guard Online. Available here.

[5]               NAO, (2017) p37.             

[6]               As discussed in Stirling & Johnstone (2018). The Public Accounts Committee (PAC, 2017) concluded that “no one protected interests of consumers in Hinkley power deal” as stated here. If the policy process has failed to take properly into consideration the citizens to whom the policy process is ultimately accountable then this can be considered a serious democratic issue.

[7]               This is not to say there hasn’t been some critical feedback. Mike Clancy (Clancy, 2018) from Prospect union recently wrote a letter in the Guardian criticizing our latest article regarding the submarine-related drivers behind the UK’s civil nuclear programme. However this letter did not either address or refute any of the specific points of evidence that we raise (available here). Other critiques have similarly not engaged with the substantive arguments but rather expressed the view that this analysis is a ‘conspiracy theory’ – see Jewell (2015) and Lovering (2016). In none of these critical responses has there been any refutation of the sbstantive points raised here. 

[8]               See Stirling & Johnstone, (2017) Some Queries over Neglected Strategic Factors in Public Accounting for UK Nuclear Power: evidence to the House of Commons Public Accounts Committee Inquiry on Hinkley Point C. Available here.

[9]               Response by Stephen Lovegrove, as reported in Watt, (2017). Electricity consumers “to fund nuclear weapons through Hinkley Point C.” in The Guardian. Available here.

[10]               NAO (2017) on Hinkley Point C, p12.

[11]               NAO, (2017) p7.

[12]               NAO, (2017) p6.             

[13] That te economic case for nuclear power has been undermined by the falling costs of renewables like solar and onshore wind is confirmed in the Government’s own ‘value for money statement’ for Hinkley C (DECC, 2016). The economic case for Hinkley C was further undermined when the allocation round in September 2017 revealed offshore wind to be significantly cheaper than the cost of new nuclear power See BEIS, (2017). The Government’s climate mitigation and energy security arguments were strongly based on the “urgent need” to be built for energy security and climate change mitigation reasons “significantly earlier than 2025” as stated on p30, DECC, (2011) National Policy Statement EN-1. In fact, new nuclear is very unlikely to contribute to climate change mitigation or energy security until after 2025. Instead, new low carbon generation has been provided by the rapid and affordable growth in renewables.

[14] This is again highlighted by the Government’s value for money statement on Hinkley C showing decentralised renewables to be manifestly cheaper than new nuclear (DECC, 2016) and by the second round allocation results announced in September 2017, where offshore wind is cheaper than new nuclear. The trends are the same worldwide. Record auction costs for solar and wind have been reported around the world and in many places these technologies are undercutting conventionally cheap coal fired power stations (IRENA, 2018). Many new nuclear projects continue to face significant cost overruns, and the global nuclear industry faces significant crises for example the bankruptcy of Westinghouse and cancellation of new build projects in the USA (Green, 2017).

[15] Beckman, (2015). Head of UK’s National Grid says “idea of large power stations for baseload is outdated” [WWW Document]. Renew. Econ. Available here.

[16] For instance OFGEM quote UKERC (2017) when stating in their own 2017 report that "At these levels, the UK Energy Research Centre (UKERC) estimates that integration costs are between £5 per MWh and £10 per MWh of intermittent energy (up to £478 million in 2016)" (OFGEM, 2017).

[17] A report by REA (2017) highlighted that there are over 125,940 people employed in the renewable energy sector in the UK, available here. The UK nuclear sector is said to currently employ 65,000 people with industry estimates that 40,000 new jobs would be created through a new build programme, reported in World Nuclear News (2016), available here. However a report in 2014 for the Office for National Statistics (ONS, 2014) found that in terms of direct jobs, there are 15,000 direct jobs in nuclear power and 43, 500 direct jobs in the renewables sector, available here.

[18] See Frankfurt School-UNEP, (2016). Global Trends in Renewable Energy. Available here.

[19] Successive UK administrations have become the main global governmental proponents of what is repeatedly referred to as an impending “nuclear renaissance”(HM Government, 2013) Challenged on the flagship UK national radio news programme in March 2016, for instance, former British Energy Minister Amber Rudd clearly expressed the intensity of this position, in stating that "investing in nuclear is what this Government is all about for the next twenty years" (BBC Radio 4, 2016). The present Energy Minister, Greg Clarke has said in the past that there is “no limit” to how much new nuclear capacity the Conservative Party would be prepared to build in the UK (Clarke quoted in Collins, 2010).

[20] The UK is one of the only countries worldwide to be undertaking a large scale nuclear new build programme, and the only country in Europe to be doing so (Schneider et al., 2017) Additionally, the Government’s decision to cut policies in support of renewables while bolstering support for new nuclear in 2015 has been described as ‘puzzling’ by former US Vice President Al Gore (Harvey 2015) and criticized by a UN Chief Scientist.

[21] This is a point that has been raised by the Citizen’s Advice Bureau who highlight that “We note that the government appears very committed to new nuclear, eg that it is entering into a sector deal with it, despite the headline cost (strike price) of such projects appearing unfavourable when compared to many scale renewable technologies. If this remains the case, we would encourage BEIS to publish the thinking and evidence that underlies this commitment, as to an external audience this decision currently appears sub-optimal if it is seeking to keep down consumer costs.” P. 5. Hall, (2017) commenting on the Helm review of energy costs. Available here.

[22] UK-based companies in the nuclear sector tend are centred around decommissioning rather than new build. The UK has not sold a nuclear reactor since the 1960s, there is no UK company involved in constructing civil nuclear reactors, and there is no company headquartered in the UK that is a major nuclear utility. As discussed in Johnstone and Stirling, (2015b). Comparing Nuclear Power Trajectories in Germany And the UK Available here.

[23] See: Johnstone, P., Stirling, A., 2015b.

[24] The UK has the best onshore and offshore wind and tidal resource in Europe as stated by the Department of Energy & Climate Change (DECC, 2013). The great advantage of the UK’s renewables potential has long been recognized in official policy (DTI, 2003). Studies show the UK has the most cost-effective wind potential in Europe (European Environment Agency, 2009; Held, 2010) .

[25] For example in the UK’s main Industrial Strategy document (BEIS, 2017b) nuclear power is uniquely identified as somehow ‘integral’ and ‘vital’ for the UK’s energy future but there is no sufficient reasons given for why this is the case.

[26] Most recently this has manifested in policy reactions to the acknowledged prohibitive costs of new nuclear. Instead of considering a low carbon energy policy, entirely new public financing models are being considered. See Butler, (2018). Should the UK government fund new nuclear? Available here

[27] The remit of the NAO mean that their report into Hinkley Point C (2017) consistently discusses perceptions of “strategic benefits” by reference to the view reported on behalf of “the Department”, rather than endorsing these in the voice of the NAO itself.

[28] NAO. 2017 p19.

[29] See Watt (2017). The ‘dreadful deal’ behind the world’s most expensive nuclear power plant. The Guardian. Available here

[30] As indicated by the critical references to the long period since the last Government analysis of strategic issues around nuclear power cited above (NAO, 2017 p19).

[31] This includes work on the military side by influential think tanks (Oxford Economics, 2013; Raman et al., 2005; Schank et al., 2005a, 2005b); Defence Committee consultations and reports (House of Commons Defence Committee, 2007, 2006); reports by nuclear industry skills bodies and engineering skills discussions (BEIS, 2018; Bennet et al., 2011; Innovation Universities Science and Skills Committee, 2009; Nuclear Industry Council, 2017) and government reports (Ministry Of Defence, 2005).

[32] Stirling & Johnstone,(2017). Some Queries over Neglected Strategic Factors in Public Accounting for UK Nuclear Power: evidence to the House of Commons Public Accounts Committee Inquiry on Hinkley Point C.

[33] As discussed recently in Stirling & Johnstone (2018). The Guardian.

[34] This is implied in evidence from the Dalton Institute as part of the Innovation, Universities, Science and Skills Committee (2009: EV419) “Engineering the Future” report, where it is stated that “The UK is not now in the position of having financial or personnel resources to develop both programmes in isolation. For example, reactor physicists on the military programme can develop their skills and knowledge by researching civil systems, and then only when necessary divert to classified work to follow a specialist career path. This link does however need to be carefully managed to avoid the perception that civil and military nuclear programmes are one and the same.” (Innovation Universities Science and Skills Committee 2009).

[35] For example, Rolls Royce have noted that the depletion of nuclear skills in the civil sector would “reduce the support network available to the military programmes (House of Commons Defence Committee, 2006, EV 60. 16). Available here.

[36] As stated by Gavin Ireland from BAE Systems Submarine Solutions,: “In comparison to other [defence] capability areas, nuclear submarines suffer criticism because their through-life costs cannot be absorbed or masked by other programmes as can be the case with fast jets or large standing land forces” (Ireland, 2007: 25). Available here.

[37] Rolls Royce, 2017 p.22.

[38] A Report by the Energy Innovation Reform Project, (2017) on the future costs of new nuclear in the USA notes that: “A sustained decline in the commercial industry could also have a negative impact on the U.S. nuclear naval program” (p.7). Available here. At a similar time, a report by the Energy Futures Initiative (2017) clearly highlights the risks posed by US civilian nuclear decline to US naval supply chains.

[39] NAO, 2008 p28.


[40] NAO, 2018.

[41] See note 24 above.

[42]               NAO, (2017) p37.             

[43] The present authors have already written to the Comptroller and Auditor General, Sir Amyas Morse, to urge that he consider taking this course of action. We have received a response that declines our request in terms that we believe to be significantly illuminating. If sight of this correspondence would be useful to the Committee, we would be pleased to provide it.









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