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WHOLESALE ENERGY PRICES: SEPTEMBER – OCTOBER 2017:

In this article, Dominic Whittome covers recent changes to wholesale energy prices.

Oil

Crude prices rallied as OPEC and non-OPEC countries continued to show strong quota compliance, with just two cartel producers, Libya and Nigeria, bucking the trend. However, 0in oil trading circles, OPEC’s 1.2 million barrel per day curtailment in export volumes is still remaining on track. Refining inventories have been reported healthy amid a warm start to winter which has suppressed demand for heating oil and related petroleum products. Over the two month period, the Dated Brent contract price closed up by 20%. This spot price has almost doubled in the last two years although it is still just below half the peak it reached barely two years before that.

Traders will be looking for evidence that the ongoing ‘shuttle diplomacy’ in the run up to the cartel’s key 30th November meeting in Vienna is paying off. Given high compliance rates, notably amongst non OPEC countries, there is no reason to expect oil prices to soften with the wind now in the market’s sales.

Natural Gas

The forward calendar year NBP contact finished the period 6% up, with good supply availability and subdued demand both outweighing the effect of steadily strengthening oil prices over the year.

The UK gas market is now into its first winter without any high space (long-duration) storage cover to fall back on. This follows the closure of the Rough gas facility in the Southern Gas Basin. A sustained cold snap could put the market to the test if the UK then has to import (effectively accessing surplus storage overseas) through inter-connectors with Scandinavia and the Continent. Although such pipeline capacity may usually (though not always) be guaranteed on the day, the gas itself is not. Even if so, it will possibly be supplied at higher distress clearing prices than before.

Centrica’s application to withdraw 0.9 billion cubic meters from the 3.2 bcm Rough facility – for site integrity and pressure reduction reasons – has been approved by the UK Oil and Gas Authority and this could keep the market well supplied in the interim. However, the volume is still quite modest and the withdrawals will be phased over time. The impact on the market will be limited, if not discounted already.

With crude prices back above $50/bl for some six months now, the oil markets could soon be nudging gas prices up through long-term contract indexation, especially with increasing reliance on inter-connector supplies given contractual indexation to petroleum product prices is generally more dominant on the Continent than it is in the UK.

Electricity

The annual base-load power price headed back up towards £45/MWh, rising 4% over the period. Although, electricity trading is increasingly becoming ‘a tale of two markets’. Whilst wholesale prices are increasing and may perhaps continue to increase gradually, industrial and commercial tariffs are continuing to climb quite steeply, amid higher transmission, distribution and balancing charges, as well as higher taxes and subsidy-related surcharges applied to industrial and commercial users.

Transit costs and taxes aside, a third factor driving industrial and commercial prices is the increase in renewables generation.

Transmission and distribution networks are known to be struggling to offset the intermittent export supply, current-harmonic and voltage-stability problems which renewable exports onto the system induce. The significant infrastructure investment needed to manage this will be passed on to the end user and increases in producer price inflation will also be an influencing factor. The consensus of recent market research suggests that in less than three year’s time, commodity electricity will account for less than 30% of a typical I&C user’s bill. Five taxes and subsidy surcharges and three grid-system fees will make up the remainder, bar a trace profit for the supplier. Therefore, the rising cost of mains electricity alone could well incentivise more end users to self generate where this is feasible. Fundamental changes to the power market and its subsidy framework to facilitate this trend have been tabled and concrete proposals may be available to report on in the New Year.

This article remains the copyright property of Prospect Law and Prospect Advisory and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

Prices quoted are indicative and may be based on approximate or readjusted prices, indices or mean levels discussed in the market. No warranty is given to the accuracy of any view, statement or price information made here which readers must verify.

Dominic Whittome is an economist with 25 years of commercial experience in oil & gas exploration, power generation, business development and supply & trading. Dominic has served as an analyst, contract negotiator and Head of Trading with four energy majors (Statoil, Mobil, ENI and EDF). As a consultant, Dominic has also advised government clients (including the UK Treasury, Met Office and Consumer Focus) and private entities on a range of energy origination, strategy and trading issues.

For more information please contact us on 020 7947 5354 or by email on: info@prospectlaw.co.uk.

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PUBLIC BILL COMMITTEE: 31 OCTOBER 2017 OUTLINE OF VIEWS ON NUCLEAR SAFEGUARDS BILL

The Nuclear Safeguards Bill (https://services.parliament.uk/bills/2017-19/nuclearsafeguards.html) represents an important but limited step in the process of withdrawal from Euratom, and this article focuses on the context and effects of that step.

Background

If the UK is to maintain involvement in the international nuclear community, it must have in place an internationally acceptable safeguards regime. Detailed regulations and adequate resource within the Office for Nuclear Regulation will be needed to operate and enforce that regime.

An acceptable safeguards regime is the first step towards replacement of the existing Euratom and bilateral nuclear cooperation agreements (NCAs) on which the UK relies. It will not be possible to conclude or even make meaningful progress with the negotiation of replacement NCAs until the UK can demonstrate that it will have an acceptable replacement safeguards regime in place on withdrawal from Euratom.

In context of the challenging withdrawal timetable, the replacement UK safeguards regime will need to be such that no reasonable counterparty to any NCA negotiation can delay or disagree on the basis of inadequate safeguarding. To avoid any perceived competitive advantage and to facilitate agreement of replacement NCAs, the new regime is likely to need to carry forward the full scope of the Euratom safeguards regime, which goes beyond the current UK Voluntary Offer Safeguards Agreement (VOSA) and Additional Protocol.

To maintain international acceptance, the UK will also need to conclude negotiations with the IAEA on a replacement VOSA and Additional Protocol, both of which are currently predicated on Euratom membership. The new UK domestic safeguarding regime must then fulfil those agreements.

Purpose of Nuclear Safeguards Bill

Within its limited ambit, the Nuclear Safeguards Bill is broadly an effective but small step towards implementation of an internationally acceptable safeguards regime (https://publications.parliament.uk/pa/bills/cbill/2017-2019/0109/18109.pdf).

The Bill is limited to the creation of enabling powers for subsequent safeguards regulations. To avoid a disruptive hiatus in international nuclear cooperation, primary focus should already be on:

  • Preparation of those regulations;
  • Ensuring that ONR has sufficient resources to take over full responsibility for safeguards in 2019; and
  • Detailed proposals and assurances surrounding negotiations with Euratom and IAEA, and with states with which the UK will need to enter into replacement NCAs.

Crucially, the Nuclear Safeguards Bill cannot be regarded as a “contingency” (as stated by Greg Clark in the second reading debate https://hansard.parliament.uk/commons/2017-10-16/debates/84828D23-EAA6-4855-99D0-4C47BD5D3633/NuclearSafeguardsBill) to be used only if the UK is not able to conclude a satisfactory agreement with Euratom.

  • Unless the UK remains a full member of Euratom (whether permanently or during any transitional phase following exit from the EU), the legislative powers and additional ONR responsibilities set out in the Bill are required as a matter of urgency. Any delay in relation to the above tasks on the basis that the Bill may not be required would be an extremely high-risk strategy (hansard.parliament.uk/commons/2017-10-16/debates/84828D23-EAA6-4855-99D0-4C47BD5D3633/NuclearSafeguardsBill)
  • In the absence of full Euratom membership, continued reliance on Euratom safeguarding arrangements would entail acceptance and payment for full application of relevant treaty obligations, regulations (including Commission Regulation (Euratom) 302/2005), inspections, enforcement powers and ECJ jurisdiction. Even then, it is likely that the UK could continue to operate within Euratom NCAs only with the agreement of each state counterparty to those NCAs. The UK would still need to replace the IAEA VOSA and Additional Protocol to reflect the UK’s changed status in relation to Euratom, so amendments to Section 93 of the Energy Act and other legislation referred to in the Bill would remain necessary.

If in referring to the Nuclear Safeguards Bill as a “contingency”, government is indicating a desire to continue full Euratom membership, at least during a transitional phase, this is to be welcomed (although unnecessary express reference to Euratom in the UK’s notification of withdrawal under Article 50 will not have assisted in achieving this).

Contrary to the government’s stated position, there are good legal arguments against any necessity to exit Euratom at the same time as exiting the EU. The Commission statement in its recommendation for a European Council decision authorising opening of negotiations on UK withdrawal simply acknowledges that Article 50 applies to Euratom. This is correct, but does not address the question as to what application of Article 50 means in context of the Euratom Treaty.

Jonathan Leech & Rupert Cowen, 6 November 2017

Prospect Law is a multi-disciplinary practice with specialist expertise in the energy and environmental sectors with particular experience in the low carbon energy sector. The firm is made up of lawyers, engineers, surveyors and finance experts.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

For more information please contact Jonathan Leech or Rupert Cowen on 020 7947 5354 or by email on: rcc@prospectlaw.co.uk and jrl@prospectlaw.co.uk.

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OFGEM’S CONSULTATION ON THE PROPOSED DEFINITION OF ENERGY STORAGE

Introduction

Ofgem are consulting on the legal definition of “energy storage” and the introduction of a new condition in the electricity distribution licence designed to ensure that distribution system operators, also known as distribution network operators or DNOs, cannot operate energy storage assets (https://www.ofgem.gov.uk/publications-and-updates/clarifying-regulatory-framework-electricity-storage-licensing). The Ofgem consultations both close on 27 November 2017.

The UK has eight distribution network operators (DNOs). They operate the regional networks that deliver electricity to consumers after it has been transmitted on the UK’s national high voltage transmission network. As natural monopoly service providers, DNOs are arguably well placed to develop energy storage facilities.  Indeed, several DNOs are already actively developing energy storage projects, including Western Power Distribution and UK Power Networks.                                          (http://innovation.ukpowernetworks.co.uk/innovation/en/Projects/tier-2-projects/Smarter-Network-Storage-(SNS)/Smarter%20Network%20Storage%20FAQs.pdf).

Proposed change to EU law

Ofgem’s position appears to be influenced by proposed changes to EU law. The European Commission’s recast of the Electricity Directive recognises the need for consumers to actively participate in electricity markets, including storage, it provides:

“The electricity market of the next decade will be characterised by more variable and decentralised electricity production, an increased interdependence between Member States and new technological opportunities for consumers to reduce their bills and actively participate in electricity markets through demand response, self-consumption or storage.

The present electricity market design initiative thus aims to adapt the current market rules to new market realities, by allowing electricity to move freely to where it is most needed when it is most needed via undistorted price signals, whilst empowering consumers, reaping maximum benefits for society from cross-border competition and providing the right signals and incentives to drive the necessary investments to decarbonise our energy system. It will also give priority to energy efficiency solutions, and contribute to the goal of becoming a world leader in energy production from renewable energy sources, thus contributing to the Union’s target to create jobs, growth and attract investments”. 

In terms of specific detail, Article 36 of the recast for the Electricity Directive proposes a general prohibition on DNOs owning, operating or managing energy storage facilities:

Article 36
Ownership of storage facilities
  1. Distribution system operators shall not be allowed to own, develop, manage or operate energy storage facilities.
  2. By way of derogation from paragraph 1, Member States may allow distribution system operators to own, develop, manage or operate storage facilities only if the following conditions are fulfilled:
(a) other parties, following an open and transparent tendering procedure, have not expressed their interest to own, develop, manage or operate storage facilities;
(b) such facilities are necessary for the distribution system operators to fulfil its obligations under this regulation for the efficient, reliable and secure operation of the distribution system; and
(c) the regulatory authority has assessed the necessity of such derogation taking into account the conditions under points (a) and (b) of this paragraph and has granted its approval.
  1. Articles 35 and Article 56 shall apply to distribution system operators engaged in ownership, development, operation or management of energy storage facilities.
  2. Regulatory authorities shall perform at regular intervals or at least every five years a public consultation in order to re-assess the potential interest of market parties to invest, develop, operate or manage energy storage facilities. In case the public consultation indicates that third parties are able to own, develop, operate or manage such facilities, Member States shall ensure that distribution system operators’ activities in this regard are phased-out. (http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52016PC0864&from=EN)

The prohibition on DNOs owning energy storage in paragraph 1 of the proposed Article 36 is subject to a derogation in paragraph 2 that provides that DNOs can own, develop, manage and operate energy storage facilities if they are needed to ensure that a distribution network is efficient, reliable and operates securely. Paragraph 2(c) provides that it is for the regulatory authority of a Member State to assess the necessity of a derogation.

DNOs as neutral market facilitators and the new reality of the UK’s energy market

The rationale for the proposed prohibition in Article 36 is that DNOs should act as neutral market facilitators. A white paper published by the Agency for the Cooperation of Energy Regulators (ACER) on 15 May 2017 explains the decision to adopt this policy position:

“European Energy Regulators advocate that DSOs must act as neutral market facilitators performing regulated core activities and not activities that can efficiently and practicably be left to a competitive market. This approach is important because:

  • Competitive markets are generally better than regulated markets in delivering outcomes that provide best value for money for consumers;
  • When DSOs get involved in competitive activities – such as storage – there is a risk that they would favour their service over potentially cheaper services (e.g. storage over demand-side response), thereby raising costs and deterring investment and innovation;
  • DSOs could unfairly favour different types of consumers if they are direct market participants for these services; and
  • Confidence in the neutrality of DSOs is a key element of the market.”

In contrast, 10:10, a UK registered charity that focuses on tackling climate change at community level, has argued against the UK adopting a general prohibition on DNOs owning energy storage facilities:

“If [DNOs] are not permitted to own and operate their own storage assets, this is likely to increase costs for end users as a consequence of increased transaction costs between network and storage operators. Network companies should be allowed to judge where and when to procure storage from a third party, and when and where to own it themselves.”

A recent survey by Energyst, the energy magazine, has also noted National Grid’s need for more firms to help it balance the power system (https://theenergyst.com/20-firms-outline-what-is-stopping-them-providing-demand-side-response/). According to Energyst:

“With some 35GW of renewables on the system, more than a third of it solar PV, summer may become as much of a challenge as winter. That equates to a year-round revenue opportunity from National Grid alone. Yet relatively few firms provide balancing services via their onsite generation or ability to shift loads. Why?

According to The Energyst’s reader surveys, this is for a few key reasons, mainly fear of technical failure and/or incompatible processes and insufficient financial reward. But lack of understanding and the fact that the most UK firms have not been approached by either aggregators or energy suppliers regarding DSR are also factors…

…But these early survey findings suggest there remains a need for better communication and cost effective technology solutions if DSR is genuinely going to trickle down from large power users to the broader market.”

The problem with DNOs acting merely as neutral market facilitators is that a lot of energy storage is likely to be needed in the UK (http://fes.nationalgrid.com/media/1253/final-fes-2017-updated-interactive-pdf-44-amended.pdf – see pages 104-105).

Energyst’s research suggests that there may not be sufficient interest from third parties to provide energy storage. 10:10 have put forward the argument that DNOs would be well placed to provide storage at the lowest cost. If this is correct, a complete prohibition on DNOs owning energy storage facilities would not reflect the “new reality” of the UK’s energy market and would also overlook the derogation in paragraph 2 of the proposed Article 36.

Conclusion: Are DNO energy storage targets a potential solution?

Notwithstanding Brexit, Ofgem seem to want to follow the EU’s proposed position on this issue.

A potential solution would be for the UK to set individual targets challenging each DNO to procure a certain level of energy storage facilities. Should a DNO be unable to meet its target through an open and transparent tendering process, then it should need to develop, own, manage and operate the balance to ensure that it has an efficient, reliable and secure distribution system.

It should be possible for the UK to draft a regulatory solution that is compatible with the derogation set out in paragraph 2 of Article 36 of the proposed Electricity Directive.  However, whether or not this solution would satisfy Professor Helm’s desire to remove all regulatory interventions from the UK energy market is another question.

Tim Malloch, 03 November 2017

About the Author

Tim Malloch trained at Macfarlanes and subsequently moved to Freshfields Bruckhaus Deringer, where he advised on corporate transactions and finance projects. After 7 years at Freshfields and a sabbatical spent abroad, Tim joined ClientEarth, an award-winning legal NGO, and devised a litigation strategy that helped persuade the UK Government to abandon its plans to build a new generation of coal power stations.  Tim returned to private practice in 2010 and has advised on a wide range of high-value commercial disputes.

Prospect Law is a multi-disciplinary practice with specialist expertise in the energy and environmental sectors with particular experience in the low carbon energy sector. The firm is made up of lawyers, engineers, surveyors and finance experts.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

For more information please contact Tim Malloch on 020 7947 5354 or by email on: tmm@prospectlaw.co.uk.

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THE ENERGY STORAGE QUESTION: SPINNING FLYWHEELS, PUMPED HYDRO AND COMPRESSED AIR

Introduction:

E-ON recently completed a 10MW lithium iron battery, designed to hold roughly the same amount of power as 100 family cars, at the 30MW Blackburn Meadows biomass plant near Sheffield. (https://www.eonenergy.com/about-eon/media-centre/eon-completes-uk-first-battery-installation-at-blackburn-meadows-biomass-power-plant/).

The unit has been hailed as a breakthrough in the switch towards greener energy and the development of energy storage solutions capable of holding energy generated by wind farms and gas power stations, for release in times of excess demand.

The Issue of Energy Storage:

The National Grid is tasked with producing enough energy to meet supply. Excess energy from one source, such as solar, will prompt the grid’s operators to switch off another.

Currently, renewable energy can only make intermittent contributions to the grid’s output. As the sun does not shine 24/7 and some days are windier than others, the renewables sector eagerly awaits technology capable of storing energy.

There have been numerous suggestions as to how the energy storage conundrum may be solved.

Spinning Flywheels:

Through storage of kinetic energy, a flywheel operates like a mechanical battery, with some designs now able to spin at rates of up to 60,000 revolutions per minute. Although early models were generally very heavy, modern carbon fibre flywheels have the ability to contain twenty times more energy then a steel wheel (http://www.economist.com/node/21540386).

A spinning flywheel will speed up when it receives electrical energy, and slow when there is a need to release the energy that it stores, at which point the kinetic energy will be transferred back into electrical energy.

Flywheels are an efficient method of storing energy. Round Trip Efficiency is generally 85% – 90%, meaning a spinning flywheel only wastes a seventh of the energy it absorbs. In comparison, coal and gas generators are half as efficient.

Compressed Air:

Compressed Air Energy Storage is currently the second biggest method of energy storage, and works by transferring electrical energy into high pressure compressed air that is stored underground

In times of short supply, the compressed air will be heated and expanded to drive a turbine generator.

Currently there are two CAES plants in operation; one in Huntorf, Germany, and another in McIntosh, Alabama (http://www.powersouth.com/mcintosh_power_plant/compressed_air_energy).

Aquifers and porous rock are generally the ideal sites for CAES systems. Underground salt domes, which have long since been used to store natural gas, have also been used in the past, and are generally found at coastal sites where the potential to generate a lot of wind energy is high.

Geographically, there is thought to be good potential for CAES systems across Europe, including in Great Britain.

Pumped Hydro:

Pumped Hydroelectric Storage requires an upper and lower reservoir, and works by using excess energy to pump water to the higher reservoir, for storage as gravitational potential energy.

In times of short supply the water will be allowed to flow down to the lower point through a turbine and generator, transferring back to kinetic and then electrical energy in the process.

Whilst PHS schemes have been considered the best mass energy storage solution, they can only be installed at very specific terrains. The largest PHS scheme is currently near Dinorwig in Snowdonia National Park, one of four across the UK, and has become something of a tourist attraction (http://www.electricmountain.co.uk/Dinorwig-Power-Station).

It is thought that the hydroelectric facilities across Europe are now able to hold roughly 5% of the continent’s electrical generating capacity.

Conclusion:

Renewables provided nearly 30% of UK Energy Generation between April and June 2017, and it is thought that the UK will need to be able to store around 200GWh of electricity by 2020.

E-ON’s unit at Blackburn Meadows, designed to offer the grid energy in less then a second, comes as National Grid recently released a tender with a view to helping it manage supply and demand.

There is clearly as yet no clear answer to the energy storage question, but battery storage appears to have become very topical.

Other energy firms are developing similar projects to the one at Blackburn Meadows. EDF Energy is developing a 49MW plant at West Burton Power Station, Nottinghamshire, whilst Centrica are developing a project of the same size at a site in Barrow-on-Furness, Cumbria (https://www.centrica.com/news/centrica-start-construction-new-battery-storage-facility-roosecote).

About the Author

Prospect Law is a multi-disciplinary practice with specialist expertise in the energy and environmental sectors with particular experience in the low carbon energy sector. The firm is made up of lawyers, engineers, surveyors and finance experts.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

For more information please contact Adam Mikula on 020 7947 5354 or by email on: adm@prospectlaw.co.uk.

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A NEW NUCLEAR SAFEGUARDS REGIME: A NEW CHALLENGE FOR THE UK

Keen “Brexatom” watchers will recently have picked up on remarks made by the Secretary of State for Business, Energy and Industrial Strategy, Greg Clark, on the setting up of a domestic “nuclear safeguards regime”.

As a result of our withdrawal from Euratom we will no longer fall within Euratom’s safeguards regime, and with nothing else in place the UK’s relationship with its nuclear trading partners could be seriously affected. It could, for example, have an impact on the ability of potential nuclear new build organisations in France, Japan, the US, China and Korea being able to export reactor designs and physical nuclear power plant components to the UK.

What is a nuclear safeguards regime?

The safeguards regime is administered by the International Atomic Energy Agency (IAEA) and ensures through physical inspection that:

  • those countries which are signed up to the 1970 Treaty on the Non-Proliferation of Nuclear Weapons (NPT) do not manufacture or acquire nuclear weapons, and;
  • the five defined nuclear weapons states (China, Russia, UK, France and the US) do not assist other countries to acquire nuclear weapons. The regime is not mandatory for the nuclear weapons states, but each has entered into equivalent voluntary arrangements.

The application of safeguards in the UK is more than a little complicated because of the UK’s status as both a nuclear weapons state and a Member State of the EU, and the fact it did enter into a voluntary arrangement with both organisations in 1978.

Euratom, which is administered by the European Commission, has established its own similar system of safeguards additional to the NPT requirements which require Member States to have high standards of materials accountancy and to make their nuclear facilities available for inspection as part of ensuring nuclear material is not diverted. Such inspections are usually done through both installed cameras and visits to facilities. Sellafield, with its large quantities of separated plutonium, is inspected about three times a month. Annually over 200 inspections are carried out in more than 100 UK facilities.

Why is the announcement important?

When the UK leaves Euratom, unless alternative arrangements are in place, only the voluntary arrangement with the IAEA will apply; the stricter Euratom requirements will not. This will be a cause for upset amongst our trading partners, with whom we will have to enter into bilateral Nuclear Co-operation Agreements instead.

Mr Clark’s announcement included the vital importance that the new domestic nuclear safeguards regime, to be run by the Office for Nuclear Regulation (ONR), is as comprehensive and robust as that currently provided by Euratom, and that it should exceed the standard that the international community would require from the UK as a member of the IAEA.

International oversight will be a key part of the future regime. The UK is currently seeking to conclude new agreements with the IAEA that follow the same principles as the current ones. These will ensure that the IAEA retains its right to inspect all civil nuclear facilities, and receive all current safeguards reporting, ensuring that international verification of our safeguards activity continues to be robust.

The ONR is currently assessing what this might mean for them and it is highly likely they will need to recruit additional resources to build the necessary in-house capability. They will need not only additional people but also equipment, infrastructure and processes. In evidence to the BEIS Parliamentary Committee, ONR said this will be “very challenging” and that only a basic system could be in place within the two years. The immediate question therefore is whether having only a basic system in place will be enough to satisfy our trading partners. If not it is highly possible that the UK’s ability to build new nuclear power stations will fall further behind schedule, and that the UK’s world leading civil nuclear sector will no longer be able to operate and generate income in the way it currently does.

About The Author

Edward de la Billiere is a Solicitor and co-founder of Prospect Law. He trained at the leading Middle East firm Trowers and Hamlins, working in both their London and Dubai offices, predominantly in the oil sector. On qualification, Edward moved to Magnox Electric, which was taken over by the nuclear operator BNFL. He has retained a strong interest in infrastructure and, in particular, energy related projects and has advised recently in respect of energy projects for corporate, local authority and private clients across the UK and internationally.

Prospect Law is a multi-disciplinary practice with specialist expertise in the energy and environmental sectors with particular experience in the low carbon energy sector. The firm is made up of lawyers, engineers, surveyors and finance experts who provide a complete service for clients.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

For more information please contact us on 020 7947 5354 or by email on: info@prospectlaw.co.uk.

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CONSULTING INTERNATIONALLY: 10 TIPS FOR SUCCESS

East Isn’t East Anymore

Just like their engineering counterparts in the aerospace, automotive and advanced manufacturing sectors, innovative British nuclear companies are increasingly looking towards new overseas markets in order to sell their hard-earned consulting expertise. Look closely at the financial accounts of Britain’s biggest FTSE professional service firms and you will see that most large consulting practices quietly earn over half of their revenues abroad. Indeed the UK market is generally too small to support multinational firms alone. Even smaller domestic nuclear SMEs are eyeing foreign markets, as much for post BREXIT survival as for growth. Sooner rather than later nuclear professionals tend to find themselves working in foreign lands. This modern-day nuclear Gold Rush lies in Eastern Europe, the Middle East and South East Asia, where civil nuclear electricity programmes are needed to power their rapidly growing industrial economies.

How to Compete and Win

British firms have a reputation for high quality. But also high cost. The simple fact is that local professional labour is often much cheaper in Eastern and Asian countries with their budget priced nuclear power programmes. How can British firms compete? The answer lies in offering a mix of technical expertise, outstanding customer service and – most importantly – a finely tuned sense of cultural awareness upon which to build effective business relationships. In short, knowing your customer is key. And this means stepping outside of your cultural comfort zone, by looking at things from a different viewpoint. Travel does indeed broaden the mind.

My experience of working overseas as a nuclear consultant has been overwhelmingly positive. Here are 10 quick tips for fame and hopefully fortune for those nuclear experts brave enough to venture abroad with their laptops.

Rules of Thumb for Working Internationally 

Tip # 1.  Walk in their shoes. The major difference between doing business in the East and the West is that personal relationships matter much more in the East than tender submissions. All other things being equal, clients would sooner do business with a trusted friend. In fact even if things are not quite equal, clients will still prefer to work with a friend rather than gamble on a cheaper but unknown alternative. Always try to see problems from the other person’s point of view – not your own. Put yourself in the client’s shoes. Understand the wider foreign context and the internal pressures that they may be facing. What motivates them? What does success look like for them? What outcomes really matter and what are less important? How can you genuinely help improve your client’s situation? Take the time to get to know your client deeply. The answers may surprise you.

Tip # 2.  Deals are based on trust, not contract documents. Contracts tend to be regarded as the minimum level of performance. Foreign clients will usually expect you to deliver more than what the contract says. Going above and beyond without complaint is the norm for expat Brits. Besides, it is very difficult to legally enforce contracts in foreign jurisdictions. Nuclear energy projects are invariably closely linked to State governments, who can tie you up in red tape delaying payments indefinitely when displeased by under-performance. Getting paid mostly depends on whether the client thinks you have done a good job. Don’t get hung up on legal details in contracts. Arguing over small points sends the customer the wrong signal, that you don’t trust them. And trust is essential for doing business overseas.

Tip # 3.  Be polite and courteous in all circumstances. The British have a reputation for politeness, courtesy, integrity and honesty. Live up to it. Overseas clients will respect and admire your Britishness, even in difficult situations. Your softer people handling skills will ultimately determine how successful you become overseas. A willingness to help is always a big plus.

Tip # 4.  Avoid the hard sell. Hard sell is really a form of grovelling. Brashness hints at desperation which is never attractive for buyers of professional consulting services. They will wonder why you are quite so desperate. Professionals never grovel. So don’t hard sell under any circumstances, even if you lose to competitors sometimes. The customer may eventually come back to you when they realise why that cut-price deal they bought was so cheap or the consulting solutions didn’t work. Also, confrontational management styles rarely work in consultancy business situations. Collaborative diplomacy and people skills are the way to get things done abroad.

Tip # 5.  Ask questions rather than give opinions. Gently asking your future client questions will give you much deeper insight into the underlying problems and issues that your client is really trying to solve. These may not be immediately apparent from a translated contract scope or tender document. For example, technical consultancy on the chemical composition of steel in nuclear transport flasks might reflect wider systemic difficulties with the regulatory safety case for spent fuel dry cask storage. The client’s real problem might be running out of spent fuel storage capacity, not chemical analysis of steels. But if you don’t ask “why?” you may never know. Avoid silo mentality. Try to experience a wide range of different technical and situational challenges. Develop crossover skills. Nuclear power projects are never undertaken in isolation. Many different people and skills must be brought together as a team. Understanding your client’s project in this way will lead to new business opportunities.

Tip # 6.  Negotiate with patience. Foreign business deals usually require several rounds of downward negotiation to agree a final “best price”. But beware the technical scope will always remain fixed and in any case the consultant will be expected to exceed the contracted delivery terms. I have watched senior Arab officials quite literally throw a consulting proposal out of the room in feigned anger, but then minutes later be utterly charming when the price was halved for the same scope. Keep calm and carry on. Negotiate with patience.

Tip # 7.  Don’t worry about IP. The British are above all else good innovators. Conventional wisdom has it that Eastern countries will steal your nuclear intellectual property in a heartbeat. British companies focus far too much corporate effort on vain attempts to protect their IP through complex commercial and legal contracts. For most practical purposes enforcing these in a foreign jurisdiction is impossible. You might win in Court but the process will take years and bankrupt you. Instead nuclear consulting companies should not worry too much about IP. Firstly because this misunderstands Eastern buyers. They want the very latest nuclear technology for their money, not older recycled background IP. In any case the raison d’être for using a high value British consultant is precisely to generate valuable foreground IP for the client. This should be part of the consultant’s value proposition and helps justify high consulting fees. Secondly, IP should be less of a worry because the added value that nuclear consultants bring to nuclear projects is largely in their heads – it is the expert ability of British consultants to solve complex nuclear problems facing a client here and now – and this can’t be copied. That is why British consultants are highly valued problem solvers. Although they do talk about the weather too much, which always puzzles foreigners.

Tip # 8.  Be sensitive to wage disparities. Large disparities between expat and local wages can cause tensions on projects. Even quite senior nuclear officials can earn relatively low incomes by Western standards. While running a nuclear training course for some energy executives in South East Asia, I once complained about the high cost of my household gas bill. “Ian, that is more than my monthly income” my client gently chided me. I was mortified. Developing countries build civil nuclear energy programmes because they need them to boost their economy. By the same token these countries are not always rich. Beware of the social effects of wage disparities and always treat your clients with dignity and respect. They will do the same for you.

Tip # 9.  Reach out to Commonwealth Countries. It is generally easier working in foreign countries that have a strong cultural association with Britain or were once part of the British Commonwealth. For example, Australia, Hong Kong, India, Malaysia, Singapore, New Zealand and some Middle Eastern States are all undeniably foreign but have inherited some aspects of Britishness. Vietnam was once closely linked to France and retains its Western European cultural and architectural feel. Doing business in these countries is much easier than places with zero British heritage.

Tip # 10.  Remember how lucky you are. Working abroad is a privilege. Think about your colleagues stuck in a City office, as you watch the sun slowly rise over the Arabian Desert at Barakah or fly low over the green jungle of Vietnam into DaLat. I’ve done both and they definitely beat life sat in an open plan corporate office near the M6.

About The Author

Prospect Law and Prospect Advisory provide legal and business consultancy services for clients involved in the infrastructure, energy and financial sectors.

Ian Jackson is a nuclear energy consultant at Prospect Advisory with 30 years’ experience working in both the public and private nuclear sectors. He has worked from Manchester to Vietnam, and everywhere in between. Ian joined Prospect Advisory from the UK National Nuclear Laboratory where he led international business development. Prior to that, Ian was an Associate Fellow at the Royal Institute of International Affairs, Chatham House, London.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

For more information please contact us on 020 7947 5354 or by email on: info@prospectlaw.co.uk.

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WHOLESALE ENERGY PRICES: JULY – AUGUST 2017:

In this article, Dominic Whittome covers recent changes to wholesale energy prices.

Crude Oil

Forward and spot markets across energy commodities increased over the summer. This was led by crude, which rose over 7% with the futures market buoyed by reports of progress in quota compliance amongst OPEC and OPEC-Alliance producing countries. The geo-political concerns highlighted in July’s issue are also taking hold. Although Latin American tensions have eased, those in the Korean Peninsula remain foremost in peoples’ minds. Indeed, the oil market may be driven higher if more investors view hard commodities as a safe haven.

The refined products markets rose ahead of crude prices amid reports of increased military stocking (chiefly jet-kerosene). Meanwhile, US storms and emergency draws on the Strategic Petroleum Reserve, and also served to drive crude and petroleum products prices up.

Long term hopes for shale took a knock in confidence with an announcement from BHP Billiton that it was selling investments in the US to stem losses on its fracking venture. This news was compounded by comments by the CEO of Total, perhaps the one energy major with the most significant shale involvement, asserting that oil prices will need to stabilise well over $80/bl before any significant new investments can be justified.

Natural Gas

Gas finished the period up more than 3p per therm.

The spectre of North American refiners converging on the Rotterdam spot market drove up European prices for all petroleum products, notably middle distillates. This had a knock-on effect on gas, which is often contractually-indexed to heating oil. It is also a naturally interchangeable refinery product which is frequently blended with kerosene at refineries, hence the strong price correlation notwithstanding the supply basis. This factor and the rise in energy prices across the board perhaps best explains the recent run in gas prices, a market which is otherwise very well supplied, with talk of some LNG cargoes hitherto destined for South Asia now being diverted to European terminals.

Petroleum markets aside, the effects of the weakness of Sterling vs. the Euro, with the determining €/MWh price converting into p/therm, needs to be considered too. The North European gas market is essentially a single, inter-connected supply pool, with the UK price at the National Balancing Point (NBP) essentially ‘set’ by trans-European deliveries cleared in and out of the Title Transfer Facility (TTF) in Holland. A sustained or further weakening in Sterling could put upwards pressure on prices in the UK therefore, especially if regional European spot markets start to tighten once winter takes a hold or we see outages at key power stations requiring an uptake in gas or coal.

Electricity

Wholesale power prices saw the strongest gains of all, with the annual 2017 base-load contract and the spark spread rising 6% and 11% respectively.

Nuclear power stations in France and Benelux, which represent the backbone of the Continent’s supply, had come under increasing safety/decommissioning authority scrutiny, with considerable uncertainty and lack of information on the long-term future of key generators unnerving the forward market.

Industrial electricity prices in the United Kingdom, meanwhile, increased further, partly in unison with steep rises in domestic tariffs and rising input wholesale costs. The impending Energy Intensive Industry (EII) exemption surcharge will soon be affecting end-users on both new and existing long-term contracts from next April. There is some consternation amongst buyers, not just in relation to the justice of the tax itself (which exists chiefly to pay for a tax exemption for larger energy-intensive buyers) but to the uncertainty it is causing as well. Whilst the surcharge will apply from April 2018, buyers still remain in the dark as to what the actual tax rate will be – a case of Whitehall ‘delaying’ bad news, perhaps. Some suppliers have been offering premium-rated ‘insured tariffs’ in response to these end-user concerns.

But perhaps the real ‘elephant in the room’ is inflation. Not so much headline RPI or CPI, but leading-indictor of Producer/Factory Gate prices, with some industry trade associations telling us that such indices are already heading into double figures. Were this to be the case, there are contractual clauses and statutory measures in place to trigger automatic rises across wholesale, industrial and commercial prices. The same inflation-related factors affect the gas market, and in both cases, EUA carbon prices (up by more than 15% over the two month period according to Gazprom Research) could also chase industrial energy costs higher, unless such inflation can be kept in check.

Prospect Law and Prospect Advisory provide legal and business consultancy services for clients involved in the infrastructure, energy and financial sectors.

Prices quoted are indicative and may be based on approximate or readjusted prices, indices or mean levels discussed in the market. No warranty is given to the accuracy of any view, statement or price information made here which readers must verify.

Dominic Whittome is an economist with 25 years of commercial experience in oil & gas exploration, power generation, business development and supply & trading. Dominic has served as an analyst, contract negotiator and Head of Trading with four energy majors (Statoil, Mobil, ENI and EDF). As a consultant, Dominic has also advised government clients (including the UK Treasury, Met Office and Consumer Focus) and private entities on a range of energy origination, strategy and trading issues. 

For more information please contact us on 020 7947 5354 or by email on: info@prospectlaw.co.uk.

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DECOMMISSIONING LARGE SCALE ENERGY PLANTS: DISCHARGING LIABILITIES SAFELY AND COST EFFECTIVELY

PART II: THE DECOMMISSIONING PLAN

In the first article of this series we pointed out the desirability of having a robust and appropriately underpinned plan to discharge any liabilities arising from the operation of a facility, whether it be nuclear, conventionally hazardous, or physically complex, and the importance of a rigorous risk and uncertainty analysis, and the advisability of having independent verification of the plan. This article looks at the other key elements contributing to a robust plan.

Any plan has to be technically sound and should be developed against appropriate base case assumptions. The assumptions should be clearly stated and justified. Current good or accepted and internationally benchmarked practice need applying to the proposed decommissioning technologies and techniques. Quantities and metrics must be stated and justified, eg with regard to waste arisings.

Scope must be adequately defined with bounding assumptions and exclusions clearly stated. All work necessary to successfully deliver the proposed end state needs explaining and justifying. In particular the scope of work must be fully understood, with plan describing ‘how’ it will be carried out and not ‘what’ is required – its surprising how often this aspect is overlooked. A programmatic approach should normally be adopted pulling together inter-related elements of scope and allowing work packages or projects to be expressed in the context of an overall end state objective.

Schedules must be logically linked and reflect all the scope and assumptions needed to successfully deliver the plan: durations are reasonable, and there is a clearly described critical path through to the proposed end state. Interdependencies and milestones should be clear and realistic and schedules need to tie in with risk mitigation measures (see part 1 of this article).

Cost estimates must be as robust as possible at that stage of the plans maturity and must reflect the totality of the scope required, being phased according to scope and schedule. The techniques used to estimate cost and uncertainty should be appropriate and reflect good international practice. Cost and quantity data sets must be appropriately robust and wherever possible benchmarked. Where uncertainty exists, eg with regard to waste disposal, this should be made clear and appropriate contingency values applied.

It is important to fully consult regulators with consent milestones clearly articulated and demonstrably deliverable. In the latter regard adequate allowance in terms of time and effort should be made for developing appropriate cases and the iteration of these with the regulator before consent is granted. Stakeholders are also an important part of this process and should be engaged during the development of the decommissioning plan, and where appropriate their responses captured in the plan.

The above is of course predicated on the operator having a mature quality management system in place to provide oversight and governance during development of the plan and this should also be documented in the plan. Many operators back this up with independent verification of the plan’s quality during and after its drafting, with the operator documenting how the verifier’s findings have been incorporated into the finished product. Such verification is particularly valued if the operator is dealing with highly politicised or heavily regulated decommissioning programmes, providing authorities and the public with assurance that the programme is being or will be delivered safely, cost effectively and in an environmentally responsible manner.

Funding the plan is a separate but very important matter and clearly the two are closely inter-related, for which several models exist. These will be discussed in a future article.

Prospect Law and Prospect Advisory provide a unique combination of legal and technical advisory services for clients involved in energy, infrastructure and natural resource projects in the UK and internationally.       

Chris Kaye is a nuclear specialist and senior commercial executive with over 40 years experience in negotiating, managing, and assuring the performance of multi-billion pound strategically and technically complex contracts, to Board and Ministerial level, within Government and private sectors. From 2006 and prior to joining Prospect Group in 2017 Chris was a function head of a major UK Non-Departmental Public Body. There he was responsible for assurance and oversight of all the UK private sector nuclear operators’ decommissioning strategies, plans and costings on behalf of the UK Government where a third party or the taxpayer has an interest in funding and risk.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

For more information please contact us on 020 7947 5354 or by email on: info@prospectlaw.co.uk.

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FACTORS TO CONSIDER BEFORE INVESTING IN BATTERY STORAGE: PART II

This new series of blogs highlights the factors which a prospective end-user should weigh up before deciding whether and how to invest in electric storage.

In terms of optimisation, such energy management can be done in-house or outsourced. Although there is no hard and fast rule, outsourcing can bring efficiency and expertise that can far out-weight its cost in commissioning. Fortunately, there are various ways of going about this task and the use of third party agents or an Agency Trader is fairy well established and several firms can offer Agency Trading services.

Although much of the financial model can be prepared by the user’s agent, supplier or prospective manufacturer, the question of intangibles comes up again. Only the user can really determine what the value of continuity and ‘security of supply’ to the business will be: the resilience value overall. It is important, therefore, for the user to be involved in the modelling process.

The cost of modelling varies, as does the quality of much of the work; not always in tandem. In some cases, the cost of modelling should be deducted from the cost of any purchase, if charged. Reputable manufacturers will also inform the prospective buyer of cheaper leasing options which they may have on offer, as well as other alternatives which the user may wish to explore if the financials begin to look marginal.

To clarify, the visible savings of a financial model should include:

  1. Reductions in annual electricity bills: potentially over 50% through Power Purchase Agreement (PPA) tariff reductions or under a bespoke Storage PPA agreed with the supplier.
  1. Future income from Frequency Response services to local distribution networks under private-wire agreements or, in the majority of cases, services to National Grid under reverse auctions.
  1. Optimisation using the battery: This task could be outsourced to an Agency Trader, e.g. a Big Six, independent generator or other energy merchant, who will optimise the battery through their own supply pool and access to the Elexon, OTC, Nord Pool, APX and other markets. This task is less complex than it may sound. Like the battery itself, once in place the process requires little resource from the user, and there are various energy merchants who already offer Agency Trading services, some paid on performance only.
  1. Peak Shifting: the ability of the user or embedded generator to ‘time’ their exports of the electricity they sell into the system and so attract higher ‘peak’ prices in trading markets. Again, an Agency Trader could facilitate if the end user does not wish to becoming involved in trading directly, as many may not.
  1. Enhanced Plant Efficiency: alleviating excess loads, avoiding ‘cold starts’ and mitigating other impacts to prolong the life and reliability of turbines, minimise wear on machinery and preclude erroneous reset of control systems which some ‘black box’ DSR systems might place at risk.

It is worth adding here that larger businesses have the option of a Guest Battery. The business will not buy the battery nor pay for anything related to it, but will simply make land available and allow the Provider to install and operate the Guest Battery. The user receives pretty much the same electricity bill savings outlined in paragraph 1 above and the Guest Battery also adds a valuable degree of ‘free resilience’ as well. To compensate the Provider for such benefits, which entail practically zero cost and zero risk, the user must agree to share any resultant cost savings with the Provider.

In evaluating the resilience benefit for the company, it is important to consider:

  • The cost to the business of any ‘worst case scenario’ occurring within five, ten or fifteen years without any emergency cover or 100% dependable back-up. These will include direct contractual losses and/or consequential damages relating to any power outage, whether it was caused internally or by an outside issue with the local distribution, high-voltage transmission grid or generator: be it human error, one of the cyber attacks targeting grids of late, a force majeure or any other unforeseen event, which may or may not lie within the user’s control but remain his financial responsibility.
  • The alternative cost of buying ‘critical loss’ cover or very high premium catastrophe insurance (if it is available) that may be sure to protect the business from damages resulting from short-term or prolonged outages.

Whether or not a battery is finally purchased or leased, the process of exploring this investment can be useful as it will focus attention on optimisation options for the plant itself. The exercise can serve as a ‘de facto’ energy heath check and is offered free by some providers. This exercise must also establish what battery chemistry is best suited for the user, the size and performance specification of any battery, as well as the exact type of long-term warranty on offer, with questions pertaining to its operational life, the number of complete and partial cycles; its flexibility, its depth of discharge, specified breeches and allowed tolerances that may void a guarantee.

The forward service provision is just as important as the battery itself. It is another key question which the agent, supplier or manufacturer will need to be asked.

This article has analysed the visible savings a financial model should include, and has also introduced factors to take into account when evaluating the resilience benefit for a company. Click here to read Part I, which discussed the importance of valuing benefits, visible and intangible, and including them in a financial mode.

By Dominic Whittome 

Prospect Law and Prospect Advisory provide legal and business consultancy services for clients involved in the infrastructure, energy and financial sectors.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

Dominic Whittome is an economist with 25 years of commercial experience in oil & gas exploration, power generation, business development and supply & trading. Dominic has served as an analyst, contract negotiator and Head of Trading with four energy majors (Statoil, Mobil, ENI and EDF). As a consultant, Dominic has also advised government clients (including the UK Treasury, Met Office and Consumer Focus) and various private entities on a range of energy origination, strategy and trading issues.

For more information please contact us on 020 7947 5354 or by email on: info@prospectlaw.co.uk.

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US AND KOREAN NUCLEAR PLANT CANCELLATIONS: IMPLICATIONS FOR UK NEW NUCLEAR BUILD

The US currently has 100 nuclear power plants in operation supplying about 20% of its power needs. A further four were under construction, two each in Georgia and South Carolina, until the owners of the South Carolina plants recently announced the cancellation of construction of its two Westinghouse AP1000 units, Summer 2 and 3.

Summer 2 and 3 had been under construction since 2013, with original operational dates of late 2019 and late 2020.  However, due to construction delays and cost overruns, these were later revised to December 2022 for Summer 2 and March 2024 for Summer 3.  The finances were a key factor in the decision to cancel construction, with the original estimate of $11.5 bn having more than doubling to $25 bn. The reasons behind this are no doubt complex, but as the US has not constructed a new reactor since the 1970s, the loss of nuclear expertise must be a factor.

Summer 2 and 3 were intended to showcase advanced nuclear technology and pave the way, along with the Georgia plants – also Westinghouse AP1000s, for a nuclear renaissance in the US.  A further four AP1000s and 12 SMRs (Small Modular Reactors) are currently proposed and several more are in the early stages of planning. The fate of these and the two Georgia plants remains to be seen.

The economics of nuclear have always been the subject of much debate, but what seems to have swayed the South Carolina decision to cut losses is the availability cheap natural gas, enabled by the more liberal attitude to fracking in the US, and a flat energy demand due to improved energy efficiency. Ironically, the cancellation of Summer 2 and 3 will mean South Carolina’s coal plants will need to run for longer, whereas they were originally intended to be shutdowns upon the nuclear units coming online. A decision to proceed or not with the Georgia plants is expected soon.

The Westinghouse bankruptcy has also complicated the picture in the US, with its AP1000 design being used for the South Carolina and Georgia projects and its role being reduced to a vendor supporting the EPC. Their situation has also had an effect in the UK, with Toshiba’s stake in Nu-Gen now being considered by KEPCO. Rather than utilise the Westinghouse design, which was approved by the UK nuclear regulator, ONR, in March this year, KEPCO wants to use its own technology, which will cause a delay in construction of the Moorside plant while the necessary regulatory design assessment is undertaken.

The South Korean nuclear industry is also in difficulty, with the new anti-nuclear government suspending construction of the Shin Kori 5 and 6 nuclear plants for several months while it undertakes a public consultation on their future. This decision has generated much debate in the country and is seen as a threat to its nuclear exports, and KEPCO’s future Nu-Gen.

Decisions to be taken in the next few months will be crucial for the future of nuclear in the US and Korea. The Korean decision in particular will have an impact on the Moorside project in the UK, and may put the government’s climate change targets in jeopardy. Unlike the US, it is doubtful that the supply of natural gas from fracking will be a welcome alternative.

Prospect Law and Prospect Advisory provide a unique combination of legal and technical advisory services for clients involved in energy, infrastructure and natural resource projects in the UK and internationally.       

Edward de la Billiere is a Solicitor and co-founder of Prospect Law. He was educated at Newcastle University and trained at the leading Middle East firm Trowers and Hamlins, working in both their London and Dubai offices, predominantly in the oil sector. On qualification, Edward moved to Magnox Electric, which was taken over by the nuclear operator BNFL. He has retained a strong interest in infrastructure and, in particular, energy related projects and has advised recently in respect of energy and waste projects for corporate, local authority and private clients across the UK and internationally.

This article remains the copyright property of Prospect Law Ltd and Prospect Advisory Ltd and neither the article nor any part of it may be published or copied without the prior written permission of the directors of Prospect Law and Prospect Advisory.

For more information please contact us on 020 7947 5354 or by email on: info@prospectlaw.co.uk.

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