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The Nuclear Free Local Authorities have called on government ministers to make the operators of nuclear plants pay their neighbouring communities ‘danger money’ to properly compensate them for living with the risk.
The Department of Energy Security and Net Zero has just concluded a consultation on plans to introduce a mandatory scheme obliging energy generators to pay community benefits. The amount of money payable annually would be based on one of two models, the potential generating capacity of the plant or the actual amount of electricity generated.
Ministers would make the scheme applicable to nuclear plants, as well as larger renewable energy projects, but the NFLAs want them to factor in a premium on payments made by nuclear operators to reflect the potential for accidents, the environmental contamination caused during their operations, and their legacy of deadly radioactive waste. We also want nuclear plants to make payments through their lifecycle, including during the period of decommissioning and waste management after closure.
In our submission, we state:
‘Our view is that nuclear projects should be subject to making community benefit payments at a higher level and that these payments should continue throughout the lifecycle of the project, from inception, through operations and beyond into decommissioning as such projects are delivered at a significant cost to their ‘host’ communities.
Not only does their imposition massively impact upon the quality of life of the people living alongside them during the prolonged period of construction, but that construction also necessitates the infliction of considerable damage upon their local environment. Furthermore, to pile more misery upon adjoining residents, such projects are inevitably delivered late and vastly over budget, unlike most truly low carbon energy projects which are delivered on time and at cost.
During operations, nuclear generation inevitably leads to the release of radioactive contamination into the local environment, whether by authorised controlled discharges into watercourses, the atmosphere or into the ground, or unauthorised ones by human error or equipment failure.
Studies also show that exposure to manmade radiation impacts human health, with cancer clusters occurring alongside nuclear plants and with recorded levels of heightened risk in cardiovascular disease and strokes amongst nuclear workers. This damage can be multigenerational.
The adjoining community also must live day-to-day with the ever-present possibility, however small, of an accident taking place on site which might expose them to danger.
For history demonstrates that there is no certainty that nuclear operations can ever be accident free.
Furthermore, upon the conclusion of operations, the community will be saddled with a nuclear plant that will be subject to decades of disruptive decommissioning work and the knowledge that they will be living alongside a legacy of on-site toxic radioactive waste.
Given that nuclear operations can never be risk free, that there is no ‘safe’ level of exposure to manmade radiation, and that communities are bequeathed a toxic legacy following their conclusion, it is the NFLAs view that any community obliged to live alongside a nuclear facility – with many being forced to do so rather than acquiesce – that they at least should receive a significantly heightened level of community benefit during construction, during operations, throughout decommissioning, and into the period of waste management; indeed they should be entitled to significant compensation throughout the entire nuclear lifecycle. ‘
In our submission, NFLA Chair Councillor Lawrence O’Neill sums up the peculiar risks associated with nuclear power over other genuine ‘green’ energy technologies:
“Nuclear is then not an energy technology like any other.
For solar farms do NOT drip-feed radioactive poison into the soil as a recent Parliamentary Audit Committee report found has happened, and continues to happen, at one facility within the Sellafield nuclear complex.
And wind turbines can NOT release a toxic cloud of radioactivity across Northern Europe as the Windscale Fire of 1957 did.
And, unlike nuclear, both can be decommissioned very quickly, with minimal disruption and without leaving behind any ‘nasties’.
This is why we want to see communities living with nuclear projects paid danger money”.
Ends//..For more information please email Richard Outram, NFLA Secretary at richard.outram@manchester.gov.uk
The full response of the NFLAs reads:
Community Benefits,
Energy Infrastructure Planning Reform,
Department for Energy Security and Net Zero,
55, Whitehall, London SW1A 2HP
By email to energy.infrastructure.benefits@energysecurity.gov.uk
15 July 2025
Consultation on Community Benefits and Shared Ownership for Low Carbon Energy Infrastructure: Working Paper CD 16 July 2025
Response of the UK/Ireland Nuclear Free Local Authorities
Dear DESNZ Colleagues,
I am responding to this consultation as Chair on behalf of the UK/Ireland Nuclear Free Local Authorities (NFLAs).
The NFLAs were established in 1981 to provide a voice for local authorities in the constituent nations of the United Kingdom and the Republic of Ireland which are opposed to nuclear power and wish to campaign for their nations to be powered 100% by renewable energy technologies.
It is disappointing that the working paper did not start with a comprehensive assessment of the effectiveness of existing voluntary schemes, nor is there any summary of existing mandatory schemes elsewhere in Europe, for example the compensation arrangements in Spain applicable to projects involving the management of radioactive waste. A summation of both would have been most helpful.
Addressing the questions where we have comments:
- Do you agree with the principle that developers must provide community benefit funds? Please explain why/why not?
Yes. To the NFLAs the payment of a community benefit should form part of a social contract with the community that is ‘host’ to the energy project, particularly where that community was opposed to its imposition in the first place. We strongly support the introduction of a mandatory scheme to ensure that all energy projects operate on a level playing field.It seems entirely fair that a commercial project should share some of the profits that it makes with the community from which it derives that profit, and it seems fair to ensure that all such projects pay in accordance with an established legal framework.
- Considering the policy parameters for the scope proposed above, what types of low carbon energy infrastructure should be included within the scope of the policy. Please provide your reasoning.
All non-domestic low carbon energy infrastructure should be included within the policy, other than projects owned by community members through a Community Benefit Society or a Co-operative model or owned by Council or other public sector bodies where profits are already redistributed as community benefits. Please also see our response to Question 9.Whilst we reject the notion that nuclear is ‘low carbon’, ‘green’ or ‘clean’ (given the carbon footprint throughout its lifecycle, the dangers and hazards posed by nuclear operations, and its legacy of environmental damage and deadly radioactive waste), the NFLAs do support in principle nuclear generators and decommissioners providing a monetary benefit to their ‘host’ community.We make especial comments under Question 14 about why nuclear projects should 1. Pay a greater community benefit and 2. Pay such a benefit even after the conclusion of their operations because of their unique nature and legacy.
- What would be the impacts on specific low carbon energy infrastructure technologies of bringing them into the scope of this potential scheme?
Please see our comments under Question 1.
- Do you agree that there needs to be provision for amending the scope of the policy in future to ensure that it can be adapted to fit future technological changes, and remains inline with the criteria set out above?
Yes. The policy should provide for periodic reviews as technologies advance or are adapted.
- Do you agree with the approach outlined for the provision of community benefits for co-located infrastructure?
It would be best if, within a co-located infrastructure (for example, a renewable energy generation ‘estate’), where several projects utilising different technologies are all owned by the same owner that the owner makes a single payment based on the output of all these technologies. This could be pooled by agreement with contributions made by any other owner of similar projects within that infrastructure, in which case there should be provision made in legislation to permit a single Administrative Body and a single Fund Administrator.
- Do you agree with the proposed mandatory community benefits threshold of 5MW for power generating and storage assets?
Yes. This seems logical, especially as it ties in with the Contract-for-Difference threshold.
- Should the threshold vary by technology in order to accommodate nascent technology (such as floating offshore wind)?No. Nascent technologies will include so-called ‘Small’ and ‘Advanced’ Modular Reactors, and potential in the long-term nuclear fusion plants.We would particularly like to see all these nuclear facilities subject to making payments of community benefits for their first day of operation as per the regime outlined in our additional comments under Question 14.
- How should shared ownership arrangements interact with any mandated community benefit fund contributions?
Please see our comments about not-for-profit shared ownership or public sector projects under Question 9.
- Are there any project types that should be exempt from a potential mandatory community benefits scheme?
The NFLAs supports the Government’s aspiration to ‘encourage and enable’ the shared ownership of community energy schemes and would urge Ministers to make this commitment to ‘enablement’ more tangible by significantly increasing the Community Energy Fund assigned to support new projects and by reintroducing tax incentives to encourage public investment in such schemes as existed during the period of Coalition Government.It is right to exempt energy co-operatives and similar not-for-profit enterprises engaged in activities such as promoting the adoption of energy efficiency measures or generating electricity from renewable technologies, from a mandatory community benefits scheme. Such projects already deliver significant community benefits by reason of their purpose.Members investing in such projects generally receive a modest return of interest on their investment on the understanding that most of the ‘profit’ generated is recirculated back into the host community, usually in the form of grants to worthy community causes carrying out activities as per your list on Page 27.By way of example, during Community Energy Fortnight in 2023, the NFLA Secretary Richard Outram visited his local community owned hydro project, Saddleworth Hydro. This is a Community Benefit Society, ‘owned’ by approximately 200 local members. He commented:‘Saddleworth Community Hydro https://www.saddleworthhydro.co.uk/ operates a Hydro Sustainability Fund[i] https://www.saddleworthhydro.co.uk/sustainability-grants to support renewable energy and carbon reduction projects in Oldham and surrounding areas. Grants are available at a range of different levels up to about £20,000 and applications are particularly welcome from local organisations working with young people on renewable energy activities or for projects that will reduce carbon emissions, improve biodiversity, tackle climate change, or repair, and recycle household items.‘One recent recipient has been St Barnabas’s Church in Clarksfield, which operates a food co-operative. The Church was keen to reduce its bills and carbon footprint by using electricity from a renewable source to keep food items chilled in its fridges, and it turned to Saddleworth Community Hydro for help. A grant from the project agreed last week will enable the Church to install roof-mounted solar panels to power refrigeration – truly manna from heaven.’
It is unclear from the working paper whether the Government intends to also exempt renewable energy projects owned by local authorities (or indeed any other public sector body).
We would urge them to do so.
Council owned facilities are by their nature held in trust by the local authority for the community that it serves. Electricity or heat generated by their operation may be utilised directly by that authority to light or heat its buildings, reducing its energy bill. Alternately, if sold to the National Grid any profit generated will be recycled into the Council’s coffers for redeployment towards delivering other essential services.
Consequently, Council Taxpayers in effect already derive a community benefit through having to pay a reduced energy bill or having services in part paid for through an energy derived income. This helps reduce the burden of Council Tax.
- How can significantly larger community funds be best managed (requirements to use regional funds, introduction of a cap on funding, limit on cap duration)?
Elected mayors and local authorities should be consulted on the employment of regional funds.
- Do you have a preference for either of the proposed methods for calculating the level of contribution payable in respect of energy generating stations (i.e. by reference to either installed capacity or generation output?
The NFLA’s preference would be for Option Two: a fund contribution based on generation output.This would reflect the actual income received by the generator.However, the paper makes no mention of the Government’s position on considering ‘Constraint Payments’ made to wind power generators as income. We believe that these payments should somehow be included in the calculation of income and so the level of community benefit payable.Are there any further considerations relating to either option which require exploration?Additional levy re nuclear powerThe Energy Act of 2004 places upon the Nuclear Decommissioning Authority a duty to support the economic, social and environmental wellbeing of communities living alongside redundant nuclear facilities, but any similar commitment made by the current nuclear generator EDF Energy towards communities living with operational plants is wholly voluntary.
In both cases any benefits are not prescribed, nor are they consistent.
The NFLAs believe that a mandatory arrangement cannot come soon enough.
Our view is that nuclear projects should be subject to making community benefit payments at a higher level and that these payments should continue throughout the lifecycle of the project, from inception, through operations and beyond into decommissioning as such projects are delivered at a significant cost to their ‘host’ communities.
Not only does their imposition massively impact upon the quality of life of the people living alongside them during the prolonged period of construction, but that construction also necessitates the infliction of considerable damage upon their local environment. Furthermore, to pile more misery upon adjoining residents, such projects are inevitably delivered late and vastly over budget, unlike most truly low carbon energy projects which are delivered on time and at cost.
During operations, nuclear generation inevitably leads to the release of radioactive contamination into the local environment, whether by authorised controlled discharges into watercourses, the atmosphere or into the ground, or unauthorised ones by human error or equipment failure.
Studies also show that exposure to manmade radiation impacts human health, with cancer clusters occurring alongside nuclear plants and with recorded levels of heightened risk in cardiovascular disease and strokes amongst nuclear workers. This damage can be multigenerational.
The adjoining community also must live day-to-day with the ever-present possibility, however small, of an accident taking place on site which might expose them to danger.
For history demonstrates that there is no certainty that nuclear operations can ever be accident free.
Furthermore, upon the conclusion of operations, the community will be saddled with a nuclear plant that will be subject to decades of disruptive decommissioning work and the knowledge that they will be living alongside a legacy of on-site toxic radioactive waste.
Nuclear is then not an energy technology like any other.
For solar farms do NOT drip-feed radioactive poison into the soil as a recent Parliamentary Audit Committee report found has happened, and continues to happen, at one facility within the Sellafield nuclear complex.
And wind turbines can NOT release a toxic cloud of radioactivity across Northern Europe as the Windscale Fire of 1957 did.
And, unlike nuclear, both can be decommissioned very quickly, with minimal disruption and without leaving behind any ‘nasties’.
Given that nuclear operations can never be risk free, that there is no ‘safe’ level of exposure to manmade radiation, and that communities are bequeathed a toxic legacy following their conclusion, it is the NFLAs view that any community obliged to live alongside a nuclear facility – with many being forced to do so rather than acquiesce – that they at least should receive a significantly heightened level of community benefit during construction, during operations, throughout decommissioning, and into the period of waste management; indeed they should be entitled to significant compensation throughout the entire nuclear lifecycle.
We would call this community compensation DANGER MONEY.
Community Infrastructure Levy
It is unclear how the mandatory requirement for energy projects to pay a community benefit sits alongside any requirement for a payment of a Community Infrastructure Levy imposed by a planning authority upon a new build. The NFLAs would hope the requirement to pay CIL will not be compromised as the CIL payment assists financially stretched local authorities in providing additional community facilities.
- Do you agree with the principles of seeking to enable combining funds and utilising regional funds?
Elected mayors and local authorities should be consulted on the employment of regional funds.
- Do you agree with the outline proposals for a) when payments apply b) index-linking, c) changes to project lifespan/capacity/ownership and d) suspension of payments?
Yes. These are all logical proposals.
- Do you agree with the proposals to place the developer obligations for community benefits on the relevant licence-holder?
Yes. This is a logical proposal.
- Are there any other aspects on funding that should be considered?Please refer to our comments under Question 14 above.
- Do you agree or disagree that we should not produce prescriptive guidance on what the fund can be used for?
The NFLAs believe that such prescriptive guidance should be introduced for the mandatory scheme.We agree with the tenor that community benefit funds should be spent locally and used ‘for enhancements to the local community, economy and environment’, with priorities being determined in large part by members and stakeholders of that community.We also concur that the potential projects listed on Page 27 of the paper would fall within this definition and that similar prohibitions should apply as generally appertain to other forms of grant funding, i.e. nothing for religious or political purposes, personal gain, or for deployment in replacement of statutory funding etc.However, we believe that in addition such funds should specifically not be used to invest in ‘dirty’ energy projects, particularly anything related to the employment or transport of fossil fuels, to the exploitation of shale gas, or, frankly, to new nuclear.Are there any other factors that should be considered?In addition, where community benefits are derived from nuclear operations, our view is that it is legitimate to provide for investment in retraining and job search support for local employees being displaced from a downsized nuclear workforce as the plant transitions from operations into decommissioning.
- Do you agree with the suggested roles and responsibilities defined for the developer, fund administrator, administrative body, community representatives and community, and with the proposed governance structure?
Broadly speaking yes.In addition to requesting a full evaluation of existing voluntary schemes for lessons learned, as we alluded in our opening remarks, we would recommend that the Government looks also at the management structure and operational experience of the bodies which distribute the Community Investment Fund in each of the Search Areas where investigations have taken place for a potential site for a Geological Disposal Facility. The bodies were established by Nuclear Waste Services with membership comprising local stakeholders.Would you suggest any amendments?Care needs to be taken to ensure that a Register of Interest is compiled and maintained of all individuals involved in decision-making over the disbursement and outcome monitoring of the funds.Decision makers should have no connection to the energy project, nor should they be involved in disbursements to any external organisation with which they have a connection, by virtue of being a staff or board member etc.Reference is made to an external Adjudicator to which complaints can ultimately be referred. We would suggest that an Office of the Adjudicator be established, modelled on those of the established Ombudsman schemes and perhaps co-located within the Charity Commission.
The NFLAs would urge the government to also have this individual maintain a national register of all community benefit funds, that can be interrogated online by members of the public.
This register would contain the details of every scheme, including its name, contact details and defined area of benefit (the ‘community’), the Register of Interest, the disbursements made, the outcomes achieved through the application of these funds, and total spent on administration.
This would promote transparency and accountability.
The Adjudicator could also produce model documents on the governance structure and training materials for stakeholders involved in the Administrative Body.
It would be nice if the Government could look to establish a Kitemark or Awards scheme to recognise exemplary schemes administered by the Adjudicator, and where necessary, the Adjudicator could also levy the civil penalties; in effect, the final arbiter of the application of the ‘carrot’ and ‘stick’.
- Do you agree that some flexibility in the governance structure is needed?
Yes.
If yes, do you think that the suggested ‘truncated’ governance approach would adequately capture and reflect the needs of smaller funds or communities with less capacity?
Yes. The ‘truncated’ governance approach appears logical for smaller funds or communities with less capacity.
- Do you agree with the proposed approach to the decision-making process?
Broadly speaking, yes. Please see our earlier comments under Question 20.Under Page 37, Gathering Views, please can we make an appeal that civil servants and Ministers avoid the use of the appalling phrase ‘town halls’, which is an Americanism creeping into use in the UK. We would prefer for such occasions to be referred to as ‘public meetings’.Under Pages 43-44, Defining Communities, we agree that the definition of the eligible community which should be the recipient of the community benefit is indeed of crucial importance. We are glad that it is proposed to support fund administrator with ‘comprehensive guidance and examples of industry best practice to inform their proposals’.A failure to appropriately define the eligible community would cause public resentment and community division, and herein we would cite a cautionary tale. In the case of the two Search Areas in Cumbria – Mid and South Copeland – under investigation to identify prospective sites for the Geological Disposal Facility, these each comprise electoral wards. Most of the area encompassed by these wards is however rightly exempted from consideration by virtue of lying within the Lake District National Park yet the residents remain eligible to apply for the CIF despite facing no threat from the GDF. This seems singularly unfair.
- Do you agree with the deadline of one year before payment is due for having governance procedures in place?
Yes, but this rather assumes that the lead-in time before an energy project commences operation will be at least one year. No objection, so long as payments are backdated to when the project becomes operational.
- What would be an appropriate cap on spending from the fund for administrative functions?The working paper references that the Irish Government’s ORESS and RESS schemes sets a 30% limit on administrative fees. This seems ridiculously high. 10% maximum would seem a more reasonable limit. It also needs to be clear that the Fund Administrator should be arms-length from the energy project providing the community benefit; if the two are linked then unscrupulous energy projects might seek to maximise the administrative fee to claw back a large part of the community benefit fund into the business.Do you think we should set out a sliding scale for larger projects?Yes, this is worth exploring as it may have merits. In addition, there should be a lower administrative fee for any community benefit fund that is used solely to support one single project (for example, if it is wholly utilised to sustain the operations of a local community centre).
- Do you agree with the suggested approach to enforcement of this potential scheme?Yes.
To what extent do you think the enforcement mechanism outlined above is appropriate and proportionate for this potential scheme?
Yes.What other details could be considered?Please see our comments under Question 20.
- Do you agree with the proposed chain for dispute resolution between communities and administrators?
Yes. Appears logical.Is the proposed escalating chain for resolving disputes appropriate and proportionate?Yes. Appears logical.
Do you think we should include any more specific instances or reasons for enforcement action to ensure the robustness of the scheme?
As per our comments under Question 20, there should be civil penalties applied where a Fund Administrator has failed to create or maintain their entry on the national register or the Register of Interests.As this will be a mandatory scheme, the Government should enforce transparency via the Office of the Adjudicator as a legal requirement.
- Should consideration be given to imposing any of the proposed enforcement action on other persons or groups under the scheme?
The NFLAs would advocate that the owner of the energy project should be responsible for the payment of any civil penalties, rather than the Fund Administrator. This would ensure that the community benefit fund would not be denuded by the application of these penalties, and it would also incentivise the energy project owner to ensure that the Fund Administrator remains in full compliance with the law and established good practice.
- What do respondents think would be a practical use for any additional revenue generated from civil penalties?
The civil penalties should be utilised to offset the costs of running the Office of the Adjudicator.Measures to address fuel poverty or promote energy efficiency should be funded specifically by Government via a ringfenced budget from that of Great British Energy – Nuclear, rather than being reliant on civil penalties which are far from certain and inconsistent. Furthermore, in an ideal world, we would not wish to see any civil penalties applied as all schemes would remain fully compliant with the law and best practice.
[i] https://www.saddleworthhydro.co.uk/sustainability-grants
