Why the Nuclear Regulatory Review is flawed – and how itcould turn the nature crisis into a catastrophe.

January 2026, Research commissioned by The Wildlife Trusts

“…………………………………………………. Large nuclear projects, using potentially risky technology, have potential for significant environmental impacts on sensitive places and so it is right for there to be robust environmental assessments of these projects. The Government has an ambitious programme of nuclear
deployment. It has published a new National Policy Statement for nuclear power.3
It has removed the restriction on new nuclear power to eight sites around the UK. It has said it will aid
the completion of Hinkley Point C, provide additional funding for Sizewell C, and consider one
large new nuclear power plant alongside the deployment of Small Modular Reactors. Due to
their requirements and the types of site needed, nuclear projects have often impacted on
ecologically sensitive areas. The new National Policy Statement on nuclear reiterates the
importance of the Habitats Regulations and the protection of legally protected sites and wildlife.

As part of its efforts to boost nuclear deployment, the Government commissioned John
Fingleton to lead a taskforce review of nuclear regulation. The final report of the Nuclear
Regulatory Review was published in November 2025.
It diagnosed environmental regulations
as a blocker to nuclear deployment and included recommendations to water down those
regulations. The Prime Minister and the Chancellor have said that the Government accepts the
principles of the Review, that within three months a plan will be published by DESNZ to
implement the Review, and that its recommendations will be implemented within two years
using legislation.6 Environmental groups are very concerned the recommendations will be
adopted for the nuclear sector using legislation and potentially applied to other types of major
infrastructure.

The Nuclear Regulatory Review is part of a wider pattern of the Government adopting the
arguments of developers to pinpoint where delays are coming from; however, it is inaccurate
and does not represent reality. Research by The Wildlife Trusts already shows that – despite
the headlines and claims by the Chancellor and others – bats and newts, for example, were a
factor in just 3.3% of planning appeals.7 This briefing will highlight how the claims made by the
Nuclear Regulatory Review are similarly short on evidence and, if adopted, will do little to speed
up planning decisions but, instead, will turn the nature crisis into a catastrophe. Many industries
already say that the uncertainty caused by constantly changing regulations holds back
development; the Nuclear Regulatory Review threatens to do just that.

Flaws and Inaccuracies in the Nuclear Regulatory Review
The Review, commissioned by the Government, identifies three major areas for reform: risk
aversion, process over outcomes, and a lack of incentives. The Review also turns nature into a
scapegoat for a failure to deliver nuclear projects.

Recommendation 11 calls for various changes to the Habitats Regulations, including removing
the requirement for compensation to be like-for-like. Recommendation 12 calls for nuclear
developers to be allowed to comply with the regulations simply by paying a fixed sum (an
amount per acre), which would be used by Natural England for nature somewhere else. When it
comes to local planning, The Wildlife Trusts remain concerned with the related idea of
payments for Environmental Delivery Plans as a way for developers to meet their legal
obligations. A strategic approach might be appropriate when it comes to, for example, pollution
impacts, but would not be suitable for irreplaceable habitats or species that cannot re-establish
elsewhere easily.8

Recommendation 19 would remove the duty on Local Authorities to seek and further National
Parks and Landscapes, returning to the old language of “have regard to”. The combination of
these changes would not only substantially weaken protections for nature but would also
introduce significant uncertainty in the nuclear sector and for other sectors about whether
standards and regulations that are bedding in and increasingly becoming well understood are in
fact about to change.

The Review was produced without enough environmental expertise – and this shows. It
contains a number of errors when it comes to environmental evidence, which has led to a
misdiagnosis of the problem and to damaging recommendations about environmental
regulations.

The Review relies heavily on the case study of the Hinkley Point C nuclear power station. It is
quick to use the case study to blame nature without examining the actions and decisions of the
developer. A large amount of confusing and misleading information has been issued to the
media and in the Review itself to further this narrative.

Here are some of the facts:

Hinkley Point C is on the edge of one of the most highly ecologically protected sites in
Europe and will draw through a swimming pool’s worth of water every second for 70
years of operation. This will have enormous impacts on surrounding ecosystems, fish,
and other species.9
A £700 million figure has been widely circulated in the press relating to fish deterrents
and is quoted in the Review. This is incorrect. The cost of the fish deterrent system is
£50 million.10
EDF themselves unilaterally decided in 2017 not to proceed with the fish deterrent
system, despite it being a requirement. They then proceeded to apply for permit
variations, undertake further environmental assessments and initiate a public inquiry to
attempt to remove the requirement. These developer decisions have caused selfinflicted delays.11
Hinkley Point C’s original budget was £18 billion. It has since risen to an estimated £46
billion. The fish deterrent (at £50 million) comes to just 0.1% of this increased £46
billion budget. Nearly £30 billion in cost increases for Hinkley Point C have nothing to
do with nature.12
The Nuclear Regulatory Review says (for example) that just 0.08 salmon, 0.02 trout,
and 6 lamprey per year would be saved. This deliberately downplays the impact on
nature. This statement relies on analysis by the developer EDF, who captured fish and
put trackers on them and used old data from Hinkley B power station. Since then ,a
more thorough analysis has been completed for the Environment Agency, who have found that 4.6 million adult fish per year being killed is a more accurate number, or 182 million fish in total over sixty years.13 These fish populations are a foundation stone for the wider ecosystem of the Severn Estuary, supporting internationally important migratory bird populations and other species. Many of the fish are rare or endangered. Damage on the scale suggested by the Environment Agency figures could have calamitous impacts on that ecosystem and the economic and social activities that rely on it………………………………………………………………………………

Environmental Damage of Nuclear Regulatory Recommendations………………………………………………………………………………………………………………………………………………………………………………………………

Conclusion

The Nuclear Regulatory Review recommendations 11, 12 and 19 will harm nature and
biodiversity. They are based on flawed evidence relating to environmental regulations and how
they have been applied. As discussed, the true reasons for nuclear delay lie elsewhere.
Implementing the Nuclear Regulatory recommendations would devastate nature without
speeding up the nuclear planning and delivery process. The Government must reject the three
Nuclear Regulatory Review’s recommendations on environmental regulations and end its
confected war on nature as a barrier to planning.

20th January 2026
Research commissioned by The Wildlife Trusts and conducted by Matt Williams, https://www.wildlifetrusts.org/sites/default/files/2026-01/WhyTheNuclearRegulatoryReviewIsFlawed_TheWildlifeTrusts.pdf