In November 2025, EDF confirmed it would spend £700 million installing major fish protection systems at Hinkley Point C. This decisive shift did not appear overnight. It followed years of technical challenge, public scrutiny, expert testimony, and coordinated strategic influence.

Underpin Consultants played a central role throughout this period: shaping the strategy, managing the narrative, supporting Fish Guidance Systems and the Acoustic Fish Deterrent (AFD) Delivery Group, and ensuring the regulatory and public conversation remained rooted in evidence, proportionality, and environmental responsibility.

Before EDF’s commitment was secured, Underpin helped create a climate in which not installing the protections was no longer politically, technically, or publicly defensible.

The Context Before the Decision

In 2022, the position was fragile.

EDF continued to argue that the AFD was unsafe, untested, noisy, and infeasible offshore. They attempted to substitute the legally mandated AFD with a vast salt-marsh compensation proposal, despite:

• A Secretary of State decision,
• A Welsh Government requirement,
• Environment Agency assessments,
• And a full public inquiry mandating the AFD as an essential protection measure.

At this stage, we worked with a wide range of experts to address this on public record included pieces such as:

• Prof Mark Everard on BBC Radio 4, stating the AFD was “mature technology that works” and “not optional: it’s legally required.”
• Technical blog posts from experts explaining the science behind deterrent systems, how a Fish Disco combines multiple technologies, and why salt marshes could not address fish mortality.
• Clear, evidence-based rebuttals to EDF’s safety, noise, and technical claims.

This information now existed and created strategic cohesion, national visibility, and coordinated pressure.

This is what Underpin provided.

1. Strategy and Campaign Architecture

Underpin designed and ran the overarching strategy that connected technical evidence, expert testimony, regulatory requirements, and public legitimacy.

This included:

• Developing a long-term influence plan targeting regulators, ministers, MPs, civil servants, and environmental stakeholders.
• Positioning the AFD Delivery Group as technically credible, united, and solution-focused.
• Ensuring all emerging evidence (e.g., Everard’s BBC interview, updated delivery reports, feasibility demonstrations) reinforced a single, coherent public case.

This work matched Underpin’s recognised strengths in multi-stakeholder influence design and campaign structuring.

2. National Media and Public Narrative Management

Underpin acted as the lead public communicator, ensuring the case for the AFD remained visible, accurate, and unambiguous.

We:

• Coordinated media opportunities for technical experts, including amplification of the BBC Radio 4 Farming Today interview where Everard dismantled EDF’s claims point by point.
• Produced explainers, articles, videos, and animations translating complex engineering into clear public stories.
• Corrected misinformation, clarified risks, and explained regulatory requirements.

Before the decision was reached, we ensured the EDF narrative, that the AFD was unsafe, untested, or infeasible, was publicly and repeatedly shown to be inaccurate.

This built trust with journalists, regulators, and policymakers, who increasingly relied on our briefings.

3. Coalition Building Before the Decision

We helped coordinate a diverse ecosystem of actors:

• Local communities
• Marine and fisheries interests
• Environmental groups
• Academic experts
• Technical specialists
• NGOs and advocacy bodies

The coalition approach did three things crucial before the final decision:

1. Prevented EDF from isolating individual voices.
2. Created a unified message across technical, environmental, and civic organisations.
3. Maintained sustained pressure, ensuring the issue did not fade between regulatory milestones.

4. Technical Communication and the AFD Delivery Report

Underpin supported the AFD Delivery Group in presenting a clear, evidence-driven answer to EDF’s feasibility objections.

This earlier work included:

• Summaries showing offshore installation was safe using established vessels and ROVs.
• Evidence that AFD systems are globally recognised, mature, and not experimental.
• Clear explanations of species behaviour, relevant frequencies, and operational safeguards.
• Reports highlighting that salt-marsh habitat creation could not, and scientifically could never, compensate for cooling-water mortality.

This gave regulators and ministers a well-structured basis for accountability.

5. Spokespersonship and High-Pressure Communications

Underpin provided live, written and broadcast spokesperson work throughout the pre-decision period, including:

• Responding rapidly to EDF statements
• Clarifying legal obligations under the DCO
• Articulating the scale of potential ecological harm
• Presenting FGS and AFD Delivery Group evidence with clarity and authority

This reduced the communication risk for technical experts and kept the messaging consistent.

The Turning Point

• By mid-2025, the combined impact of the technical case, public campaign, political scrutiny, and expert media appearances, including Prof. Everard’s Radio 4 intervention, shifted the regulatory landscape.
• The Government established the Nuclear Regulatory Taskforce.
• EDF’s attempt to dilute obligations attracted significant public and scientific challenge.
• Credible evidence demonstrating feasibility undermined EDF’s narrative.

The eventual November 2025 announcement, committing £700 million to Fish Protection Measures became the only defensible course of action.

Impact

The impact is not yet known, but the commitment is there. Underpin will continue to support experts to hold EDF to account on its legally obligated duties.

Environmental

• Major reduction in fish mortality
• Protection for multiple species and life stages
• Establishing rigorous national precedent for marine infrastructure

Regulatory

• Reinforced the authority of DCO conditions
• Demonstrated that environmental obligations cannot be bypassed
• Strengthened evidence-led decision-making for future nuclear projects

Public and Stakeholder Trust

• Transparent evidence
• Credible expert input
• Clear, consistent narrative
• Strong coalition support

Acoustic Fish Deterrents and the Sector

• Increased public understanding of fish deterrent systems
• Reinforced confidence in British environmental-technology leadership
• Positioned the UK as the global leader in AFD deployment and delivery

Conclusion

Before EDF committed £700 million, the ground needed to be prepared. Underpin helped prepare it. Our role was to ensure the technical evidence was visible, the public narrative stable, the coalition aligned, and the political pressure clear.

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