Nuclear Regulatory Review 2025: Major Gaps in Understanding of Environmental Law and Ecology

The Government-commissioned Nuclear Regulatory Review 2025, led by economist John Fingleton and published in November 2025, raises serious concerns for nature and environmental protections. Whilst recognising the potential importance of the nuclear industry for the UK’s energy and defence needs, CIEEM warns that the Review fundamentally misunderstands ecology, environmental processes, and the purpose and application of environmental regulation.

Lack of environmental expertise at the heart of the review

The Review was conducted without consulting CIEEM, RTPI or any other relevant professional bodies involved in environmental regulation or decision-making. No environmental scientists or natural environment experts were appointed to the Taskforce, despite environmental regulation being one of its stated targets.

The Taskforce members, while respected in their fields, do not collectively bring the expertise required to evaluate the ecological or nature conservation implications of regulatory reform. The membership comprised:

• John Fingleton, economist and former CEO of the Office of Fair Trading

• Professor Andrew Sherry, materials and structures specialist at the University of Manchester

• Mark Bassett, member of the International Nuclear Safety Advisory Group (INSAG) and recently retired from the International Atomic Energy Agency (IAEA)

• Dame Sue Ion, engineer and nuclear industry adviser

• Mustafa Latif-Aramesh, infrastructure planning lawyer and parliamentary advisor on Nationally Significant Infrastructure Projects (NSIPs)

You have to ask yourself if Government would trust a taskforce comprised entirely of environmental assessment experts to review the operation of the nuclear industry…

A one-sided and negative portrayal of environmental regulation

Initial analysis by a CIEEM Fellow finds that the Review adopts an overwhelmingly negative stance toward regulation of all kinds, particularly environmental safeguards.

Rather than an impartial or evidence-based assessment, the report frequently ridicules environmental assessment processes and draws on selective or extreme examples, many unrelated to the nuclear sector.

Significantly, the Review fails to acknowledge any of the positive outcomes achieved by the Habitats Regulations or Environmental Impact Assessment (EIA) Regulations, outcomes that even the most critical ministerial statements have previously recognised.

The result is a document that appears partial, unbalanced and overly aligned with existing political narratives. Its tone and structure suggest a report intended to justify pre-determined conclusions rather than genuinely assess the evidence.

Misunderstanding the purpose of environmental law

The Review demonstrates a poor grasp of the objectives and context of the Nature Directives and EIA Directive. Instead of engaging with the established purpose of these frameworks (i.e. ensuring that development does not irreversibly damage biodiversity and natural systems) it recycles long-standing criticisms of environmental regulation and echoes approaches already progressing through the Planning and Infrastructure Bill. It does so without addressing the numerous concerns raised about that legislation or the concessions already made by Government.

Recommendation 12

These issues culminate in Recommendation 12, which proposes allowing the nuclear industry to bypass environmental assessment duties altogether.

Under this approach, developers could proceed without examining or avoiding harm to the natural environment, instead simply contributing financially to a centralised environmental fund.

CIEEM is clear that such a proposal would dismantle essential safeguards and permit development without understanding, managing or mitigating ecological impacts. This is an approach entirely at odds with environmental law, professional practice and effective nature recovery.

Regulatory challenges stem from poor resourcing and lack of adequate guidance, not the Regulations themselves

The Review’s own evidence points not to flaws in the Regulations but to long-standing and well-documented problems, namely under-resourced regulators, insufficient skills, inadequate guidance, and a lack of ministerial leadership in improving the operation of the regulatory framework.

CIEEM has consistently advocated for clear, authoritative guidance and modest amendments, which is possible within existing ministerial powers, that would streamline processes without weakening environmental protection. These constructive options appear to have been largely ignored.

Wider Habitats Regulations engagement

CIEEM continues to engage with Government and other stakeholders over ongoing concerns of Government’s possible intentions to weaken the Habitats Regulations.