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GBE-N is the UK Government’s body responsible for building the UK’s first government-supported SMRs. Rolls-Royce SMR has been selected by GBE-N to built three of its SMRs at the Wylfa nuclear site in North Wales.

In May, GBE-N announced it had awarded Rolls-Royce SMR stage 1 of the SMR TP Contract. It said: “The forecast Stage 1 price of the TP Contract is £359,000,000. This forecast price may change.

“The forecast Stage 2 price of the TP Contract is approximately £8,168,000,000. This forecast price is indicative only as the pricing mechanism for Stage 2 remains subject to negotiation during Stage 1.”

Taken together, that placed the forecast cost of the total TP Contract at £8,527,000,000. It is worth noting that the TP Contract does not capture the full cost of GBE-N’s Wylfa SMR project.

The contract award announcement also said: “The estimated total value within the tender notice for the two-stage TP Contract was £20,000,000,000 excluding VAT. This value was indicative only and based upon GBE-N’s initial understanding of the potential costs of developing a first of a kind technology.

“This estimated total value was based on the fact that in the tender notice GBE-N reserved the right to make up to four awards, although GBE-N also reserved the right to award three, two or only one contract(s). GBE-N has ultimately decided to award only one TP Contract and the contract award notice value reflects this.”

Given that the notes say GBE-N had an initial estimated £20bn for the TP Contract, and that it reserved the right to make up to four awards, it could reasonably be assumed that it had estimated each contract would have a value of £5bn. However, this was unclear.

Via the Freedom of Information (FOI) Act, GBE-N was asked to provide a breakdown of the £20bn figure.

In response, New Civil Engineer revealed that GBE-N said: “Following reasonable and proportionate searches of our records, we confirm that Great British Energy – Nuclear (GBE-N) does not hold the information you have requested.”

20 Working Days challenged this response via a request for an internal review and GBE-N chief financial officer Neil Cooper responded to say that upon further inspection, the organisation did have a breakdown of the figure.

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“In our original decision, we concluded that GBE-N does not hold the information requested,” Cooper said.

He went on to say that, following the internal review, GBE-N concluded that it “does hold information within the scope of your request.

“Our review has found that our original decision did not identify this information because it sits within a document whose predominant purpose is not to explain the calculation of the £20bn figure and which was therefore not considered to fall within the scope of your request.

“We consider it was reasonable to have concluded initially that the document did not contain information within the scope of your request. On further review, however, we are satisfied that it does, and we have therefore continued to assess whether the information we hold is disclosable under the EIR (Environmental Information Regulations).”

However, he added: “Our review has concluded that the information held by GBE-N should be withheld from disclosure under the exceptions in Regulation 12(5)(e) (Confidentiality of commercial or industrial information) and Regulation 12(5)(b) (The course of justice and inquiries) of the EIR.”

He went on to explain this further, saying: “We are withholding the requested information in reliance on Regulation 12(5)(e) of the EIR, which permits a public authority to refuse to disclose information to the extent that disclosure would adversely affect the confidentiality of commercial or industrial information where such confidentiality is provided by law to protect a legitimate economic interest.

“The information you have requested includes inter alia vendor cost estimates, government funding assumptions, the approach to negotiation strategies, and assessments of vendor capability relating to the Small Modular Reactor Technology Selection Process.

“Much of this information was obtained through confidential market engagement, and the information is identified as being market-sensitive.”

Cooper did find that he was able to provide an explanation for the £20bn figure without releasing internal documents.

“Although we have concluded that the information that you have requested is exempt from disclosure, we have set out below an explanation of how the £20bn figure was derived,” he said.

“The £20bn estimated total value in the Contract Notice of 2023 was an indicative, best-estimate at the time figure, published to meet the legal requirement to state the total potential value of the contract award including all options on the number of sites and technology providers.

“It was arrived at on an objective basis reflecting GBE-N’s understanding at the time, and anticipating a procurement capable of supporting up to two small modular reactor projects (broadly £10bn per project), across the whole life of a project, from early development through to commercial operation.”

It is unclear whether a single SMR ‘project’ would cover the three Rolls-Royce SMRs which are proposed for the Wylfa site, or whether that would mean a single reactor.

Cooper continued: “Because the technology is first-of-a-kind and yet to be developed, the estimate necessarily carried significant uncertainty, as the Contract Notice made clear.

“The detailed assumptions underpinning the figure comprise commercially sensitive vendor cost information and funding and negotiating assumptions obtained through confidential market engagement, and to the extent that they fall within the scope of your request these are withheld under regulation 12(5)(e) of the EIR for the reasons set out in this response.”

GBE-N was approached for comment.

You can find 20 Working Days on LinkedIn and Instagram.

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It is widely understood that one of the first tasks a Prime Minister has on walking through the door to Number 10 Downing Street is writing the letters to the captains of Trident submarines - the UK’s continuous-at-sea-deterrent.

The letters are written so that, if communications are not possible between the submarine and the wider military and political command and control structure, the submarine captains are able to find out what they should do by reading the pre-written letters which are believed to be sealed until they are needed.

The existence of the letters was confirmed by the MOD in an internal review of a FOI request in 2015. The results of the internal review were addressed to a Mr D Black.

In 2016, just before Theresa May took over the role from David Cameron, the Guardian reported: “The options are said to include the orders “Put yourself under the command of the US, if it is still there”; “Go to Australia”; “Retaliate”; or “Use your own judgment”.”

On 4 July 2026, using the FOI Act, 20 Working Days asked the MOD to share “any documents which show whether the options include the orders ‘Put yourself under the command of the US, if it is still there’; ‘Go to Australia’; ‘Retaliate’; or ‘Use your own judgment’,” as per the reporting in the Guardian.

In response, on 16 July, the MOD said: “As the letters are administered by the Cabinet Office, you may wish to approach them regarding [...] what options the letters might contain.”

On the same day, 20 Working Days put that question to the Cabinet Office.

On 17 August, the Cabinet Office responded and said: “We are writing to advise you that following a search of our paper and electronic records, we have established that the information you requested is held by the Cabinet Office.

“Information you have requested is exempt under section 24(1) of the Freedom of Information Act. Section 24 exempts information from disclosure if its exemption is required for the purpose of safeguarding national security.”

It added that “Section 24 is a qualified exemption and we have considered whether the balance of the public interest favours releasing or withholding this information”, and confirmed “we have determined that the balance of the public interest favours withholding this Information”.

The Cabinet Office was approached for comment.

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The FOI request is now the subject of an Information Commissioner’s Office (ICO) decision notice - a type of enforcement action - over its failure to respond to a FOI request sent by 20 Working Days on 6 May, via WhatDoTheyKnow.

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WhatDoTheyKnow describes itself as “a site to help anyone submit a Freedom of Information request. WhatDoTheyKnow also publishes and archives requests and responses, building a massive archive of information.” It is built by a pro-democracy and transparency non-governmental organisation called MySociety.

The decision notice has since been published on the ICO’s website. The ICO explains what decision notices are. It says: “When we do take formal enforcement action, this will likely be in the form of a decision notice.

“A decision notice is a formal document that explains whether the Information Commissioner thinks a public authority has complied with the law when dealing with a specific request.”

The decision notice it issued to AWE about the 6 May FOI request said: “A public authority will breach section 10 of FOIA if it fails to respond to a request within 20 working days.

“Based on evidence available to the Commissioner, by the date of this notice the public authority has not issued a substantive response to this request. Therefore the Commissioner finds a breach of section 10.”

Setting out the next steps required by the ICO, it said: “The public authority must provide a substantive response to the request in accordance with its obligations under FOIA.

“The public authority must take this step within 30 calendar days of the date of this decision notice. Failure to comply may result in the Commissioner making written certification of this fact to the High Court pursuant to section 54 of FOIA and may be dealt with as a contempt of court.”

20 Working Days offered AWE the opportunity to comment on the decision notice ahead of publication of its 12 August article covering the enforcement action.

The day after the article was published, on 13 August, an AWE spokesperson said: “AWE has received, and processed, previous requests from the requestor (FOI2026-020, FOI2026-042 and FOI2026-044) and has also received and acknowledged FOI2026-047) via the WhatDoTheyKnow platform. A response to that request is currently being considered.

“However a further request, understood to have been submitted on 6th May, was not received by AWE. AWE was therefore unaware of its existence until contacted by the Information Commissioner’s Office (ICO) in July.

“Following correspondence with the ICO, the ICO issued a Decision Notice on 10 August 2026, requiring AWE to provide a substantive response within 20 working days.

“AWE is processing this and has formally acknowledged this (reference FOI2026-049). A response will be provided within the applicable time limit.”

20 Working Days then shared AWE’s comments with WhatDoTheyKnow to verify whether the FOI request had been sent properly.

A WhatDoTheyKnow spokesperson told 20 Working Days: “In terms of the 6th May message, you can use our delivery verification system to prove the email was delivered to their address.”

They also provided a digital receipt that it was sent by WhatDoTheyKnow and received by AWE’s email system, and said the receipt can be used to “prove that [AWE’s] mail server accepted the email.”

The spokesperson added: “This is equivalent to a signed-for physical letter delivery where the receptionist signs for the letter. Whether that letter got routed to the desk of the responsible person is the authority’s responsibility and out of our control.”

WhatDoTheyKnow later provided additional technical information to show it had evidence that the message was sent properly and received by AWE’s systems.

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All the evidence shared by WhatDoTheyKnow was forwarded by 20 Working Days to AWE.

In response to the digital evidence, an AWE spokesperson said: “We have carried out enquiries using the additional log information supplied by [20 Working Days], but have not been able to locate any reference to the message that you are referring to.

“Our position therefore remains that the message in question was not responded to because it was not received by the team dealing with such requests. As stated previously, the team now has the request and will respond within the relevant timescales.”

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AWE, formally called AWE Plc and recently rebranded to ‘AWE- Nuclear security technologies’, is responsible for designing and manufacturing the UK’s nuclear warheads.

The warheads get attached to US-supplied rockets that together become the submarine launched ballistic missiles (SLBMs), which are then loaded onto Trident submarines.

AWE also has responsibilities covering nuclear-related counter-terrorism, nuclear emergency and nuclear threat reduction, and for monitoring related to the Comprehensive Nuclear Test Ban Treaty.

As part of an ongoing investigation, using the FOI Act, 20 Working Days asked AWE on 6 May to “share any documents you have which show any new assessments AWE has made of AWE’s capacity for storing highly enriched uranium (HEU) or documents showing any plans AWE has made to change AWE’s capacity to store HEU?

“This only covers the period between 27 February 2026 and the present day.”

The US and Israeli attacks against Iran started on 28 February 2026. One of US President Donald Trump’s main war aims has been to prevent Iran from being able to build nuclear weapons by destroying or removing its HEU.

Iran would have to further process its HEU to turn it into nuclear weapons-grade material. The US has proposed various ways of eliminating Iran’s access to HEU.

The UK has substantial nuclear materials expertise and well established facilities for processing and storing nuclear materials, and a ‘special relationship’ with the US.

Given those characteristics of the UK, 20 Working Days has been looking into whether the UK Government has considered helping, or chosen to help, the US or Israeli governments or the International Atomic Energy Agency (IAEA) with securing, transporting or storing Iran’s HEU.

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AWE did not respond to the 6 May request within 20 working days, as per the rules set out in the FOI Act. On 5 June, 20 Working Days told AWE that if a response was not received by the close of business on 19 June, a complaint would be made to the Information Commissioner.

AWE further failed to respond and on 1 July, 20 Working Days submitted a complaint to the ICO.

The government says the ICO “upholds information rights in the public interest, promoting openness by public bodies and data privacy for individuals”.

On 24 July, the ICO wrote a letter to AWE, saying it had received a complaint which said it had “not sent a response to an information request they submitted to your organisation on 6 May 2026”.

It asked AWE to either “provide a substantive response to this request within 10 working days and provide a copy of that response to this office”, or to “confirm that a response to this request has already been sent and provide a copy of that response to this office”.

It added: “Please respond within 10 working days of the date of this email and remember to quote our reference number above.

“If we do not receive a response from you within 10 working days of the date of this email, a decision notice finding a breach of FOIA and compelling you to respond to the request will be issued. It is your responsibility to inform us if a response has been provided.”

The ICO explains what decision notices are on its website. It says: “When we do take formal enforcement action, this will likely be in the form of a decision notice.

“A decision notice is a formal document that explains whether the Information Commissioner thinks a public authority has complied with the law when dealing with a specific request.”

On 30 July, AWE responded to 20 Working Days and said: “We will aim to provide you with a response by 24 August 2026, which is twenty working days from the date we received your request.”

This failure to provide a substantive response resulted in the ICO issuing a decision notice dated 10 August.

“A public authority will breach section 10 of FOIA if it fails to respond to a request within 20 working days,” it said.

“Based on evidence available to the Commissioner, by the date of this notice the public authority has not issued a substantive response to this request. Therefore the Commissioner finds a breach of section 10.”

Setting out the next steps required by the ICO, it said: “The public authority must provide a substantive response to the request in accordance with its obligations under FOIA.

“The public authority must take this step within 30 calendar days of the date of this decision notice. Failure to comply may result in the Commissioner making written certification of this fact to the High Court pursuant to section 54 of FOIA and may be dealt with as a contempt of court.”

An AWE spokesperson told 20 Working Days: “AWE has received, and processed, previous requests from the requestor (FOI2026-020, FOI2026-042 and FOI2026-044) and has also received and acknowledged FOI2026-047) via the WhatDoTheyKnow platform. A response to that request is currently being considered.

“However a further request, understood to have been submitted on 6th May, was not received by AWE. AWE was therefore unaware of its existence until contacted by the Information Commissioner’s Office (ICO) in July.

“Following correspondence with the ICO, the ICO issued a Decision Notice on 10 August 2026, requiring AWE to provide a substantive response within 20 working days.

“AWE is processing this and has formally acknowledged this (reference FOI2026-049). A response will be provided within the applicable time limit.”

The response from AWE was added to this article on 13 August.

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On 26 March 2026, the then Department for Business and Trade (DBT) announced that agreed a deal with Ensus which owns a bioethanol plant at Wilton, Teesside to safeguard domestic CO2 supplies due to disruptions to imports caused by the Iran conflict. The plant had been mothballed in September 2025.

The DBT is in the process of absorbing the Department for Science, Innovation and Technology (DSIT) following the appointment of Andy Burnham as Prime Minister, and will soon become the Department for Business, Innovation, Science and Trade (BIST).

The 26 March announcement described CO2 as “vital” for Britain’s “nuclear, packaged meats, fresh food and healthcare”.

The DBT said: “Disruptions to European fertiliser production — combined with difficult market conditions — have significantly reduced the reliability of CO2 imports, and rising gas prices driven by the Iran conflict, plus unplanned maintenance at several European CO2 producing sites, mean that the UK’s market for CO2 risks being undersupplied.

“Given the potential impact of a shortage on essential UK sectors, including healthcare, nuclear and food and drink production, the Government has taken the decision to back the restart of activity at Ensus to safeguard critical national infrastructure and maintain a resilient supply of CO2.”

It was widely reported at the time that the government was spending £100M to restart the factory, however, the government didn’t make public any documents confirming that figure.

The support from the government was intended to cover an initial three month restart, which is now understood to have been extended by a further three months to October 2026.

The International Atomic Energy Agency says the UK is the only operator of advanced gas-cooled reactors (AGRs) and that the gas is CO2.

According to the World Nuclear Association (WNA), the UK has eight operable AGRs at four nuclear power plants (NPPs) - named by the UK Office for Nuclear Regulation (ONR) as Hartlepool, Heysham 1, Heysham 1 and Torness. The WNA and ONR appear to have slightly different naming conventions for the NPPs.

20 Working Days submitted a request under the Freedom of Information (FOI) Act on 28 April asking the government to share “any documents showing the formal agreement which was agreed between Ensus and HMG (His Majesty’s Government) regarding the restart of Ensus’s CO2 facility.”

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The request also asked the government to “disclose how much money has been committed by HMG for the plant’s three month restart.”

The DBT replied on 28 April saying it would “at the latest by 28 May 2026”, but on 28 May, said: “we need more time to consider your request.

It added: “The Freedom of Information Act 2000 (’the Act’) obliges us to respond to requests promptly and in any case not later than 20 working days after receiving your request.

“However, when a ‘qualified’ exemption applies to the information and an accompanying public interest test is engaged, section 10(3) of the Act allows the time for response to be extended, in which case a full response must be provided within such time as is reasonable in all circumstances.

“In the case of this FOI request, we are considering section 43 (Commercial interests). However, this is not yet finalised and will be subject to changes.”

The DBT said it hoped to respond by 26 June.

On 18 June, it said: “The Department for Business and Trade (the Department/DBT) can confirm information is held in scope of your request, however this is withheld in full under section 22 (Information intended for future publication), section 40(2)(Personal Information) Section 41(Information provided in confidence) and section 43(2)(commercial interests) under the Act.”

In the DBT’s explanation of its application of “Section 22 – Information intended for future publication”, it said: “The Department acknowledges the public interest in favour of transparency and early sight of the formal agreement which was agreed between Ensus and HMG regarding the restart of the facility.

“It is our view that although there may be an interest in early sight of this information,
there is also a strong public interest to ensure that publication of information is in accordance with certain procedures to ensure accuracy and consistency.

“Under Section 16 (duty to provide help and assistance) the expenditure costs will be published in the Department’s Annual Report and Accounts found on gov.uk.”

A written ministerial statement by the UK Government published on 13 April 2026, about the Ensus restart, said: “We will protect taxpayers’ money by operating the plant only for as long as necessary. This is why we have agreed that the plant will operate for an initial period of 3 months but will be subject to regular review.

“The Department for Business and Trade (DBT) will closely monitor the associated spend, which will be reported in DBT’s accounts for 2026-27, with 2025-26 spend also disclosed in the annual report and accounts.

“If conditions require it, Government will not hesitate to extend this period and will retain the ability to restart the plant for a longer period as a precautionary measure.”

The DBT’s Annual Report and Accounts 2025-2026 for the period 1 April 2025 to 31 March 2026 was published on 15 July.

It said: “Ensus UK Limited was indicatively classified by HM Treasury to the Departmental Group after the designation process for 2025-26 had concluded. Accordingly, it will be consolidated in the 2026-27 Group accounts.”

On 18 June, 20 Working Days submitted a request for an internal review of DBT’s decision to withhold the information, and on 17 July, the DBT said it had conducted an internal review and that it stood by its decision to withhold the information.

The DBT, the Department for Energy Security and Net Zero (DESNZ) and Ensus were approached for comment.

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The MOD’s lack of information on the letters was revealed in response to a request made under the Freedom of Information (FOI) Act by 20 Working Days.

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Attention was drawn back to the existence of the so-called ‘letters of last resort’ because of the UK getting its sixth Prime Minister in 10 years, as Andy Burnham replaced Keir Starmer as leader of the Labour Party.

It is widely understood that one of the first tasks a Prime Minister has on walking through the door to Number 10 Downing Street is writing the letters to the submarine captains.

The letters are written so that, if communications are not possible between the submarine and the wider military and political command and control structure, the submarine captains are able to find out what they should do by reading the pre-written letters which are believed to be sealed until they are needed.

The classic hypothetical scenario involves nuclear war breaking out, London and other military and political headquarters being destroyed or otherwise compromised, and nuclear submarines remaining operational but without a command structure telling their captains what to do.

The existence of the letters was confirmed by the MOD in an internal review of a FOI request in 2015. The results of the internal review were addressed to a Mr D Black.

The internal review found that the MOD's decision to neither confirm nor deny whether the information Black had requested relating to the letters of last resort was an "overly-cautious" approach to take, and instead should release certain information about the letters.

It said: “Under section 1 of the Act I can confirm that obsolete letters are not held. I have been advised that this is because the letters are only retained until replaced by a later version.”

One department no longer holding the letters does not necessarily mean that the government as a whole has no record of the contents of the letters.

In 2016, just before Theresa May took over the role from David Cameron, the Guardian reported: “The options are said to include the orders “Put yourself under the command of the US, if it is still there”; “Go to Australia”; “Retaliate”; or “Use your own judgment”.”

On 4 July 2026, using the FOI Act, 20 Working Days asked the MOD to share “any documents you have which show whether the MOD plan to release historic Letters of last resort, possibly to the National Archives or whether they might be made available under the FOI Act in future?” This was with reference to the 2015 FOI.

The request also asked for “any documents which show whether the options include the orders ‘Put yourself under the command of the US, if it is still there’; ‘Go to Australia’; ‘Retaliate’; or ‘Use your own judgment’,” as per the reporting in the Guardian.

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In response, on 16 July, the MOD said: “We have treated your correspondence as a request for information under the Freedom of Information Act 2000 (the Act). A search has been completed within the Ministry of Defence (MOD) and we can confirm that the MOD holds no information in scope of your request.

“Under section 16, whereby the public authority should provide advice and assistance, so far as it is reasonable to do so, you may find it helpful to note that the response to FOI2015/086381, which you referred to in your email, confirmed that the MOD did not hold versions of the so called ‘letters of last resort’ issued by previous Prime Ministers and that letters currently onboard the submarines are not retained once they are superseded by new versions.”

FOI2015/086381 is the 2015 request made by Mr D Black.

The MOD continued: “Further, as the letters are written by the Prime Minister of the day, they are administered by the Cabinet Office. In response to a 2015 request for letters written by previous Prime Ministers, the Cabinet Office stated that the information is not held.

“These previous responses, taken together, suggest that historic letters are not retained and therefore cannot be released in future to either The National Archives or to individuals in response to requests under the Act.

“As the letters are administered by the Cabinet Office, you may wish to approach them regarding the second part of your request relating to what options the letters might contain.”

20 Working Days has submitted the same two requests to the Cabinet Office under the FOI Act following the recommendation by the MOD.

The MOD was approached for comment.

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The news is not surprising, but it is an additional piece of information about the highly secretive NATO NPG, which 20 Working Days garnered via a response to a request under the Freedom of Information (FOI) Act.

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The NATO NPG was scheduled as part of the Meeting of NATO Ministers of Defence which took place across 17 and 18 June 2026 in Brussels, Belgium.

The NPG was listed on the agenda of the ministers’ meeting on 18 June at 08:00.

NATO’s website explains what the NPG is. It says: “The Nuclear Planning Group (NPG) is the senior body responsible for NATO’s nuclear deterrence.

“Established in 1966, it provides a forum for consultation and decision-making on all issues that relate to nuclear deterrence, including nuclear policy, doctrine, planning, force posture, capabilities and exercises.

“It also addresses the overall effectiveness, safety and security of NATO’s nuclear weapons, and the corresponding consultation, command and control systems.”

It adds: “While the North Atlantic Council (NAC) is the principal political decision-making body within NATO, the NAC defers consultation and decision-making on nuclear issues to the NPG, which is also chaired by the Secretary General.”

The secretary general of NATO is former Dutch prime minister Mark Rutte.

All NATO allies, with the exception of France, participate in the NPG and usually at the level of defence ministers.

It also claims to be in favour of nuclear disarmament, saying: “NATO is committed to arms control, disarmament and non-proliferation, but as long as nuclear weapons exist, it will remain a nuclear alliance.”

On 18 June 2026, NATO published the 2026 Nuclear Planning Group Statement. It was the first statement published by the group since 2007 and comes at a time of nuclear escalation between the nuclear weapons states (NWS). NWS are those which are known, or thought, to possess nuclear weapons.

The statement said: “The Nuclear Planning Group (NPG), NATO’s senior body for nuclear deterrence matters, met in a regular Ministerial Session on 18 June 2026.

“NPG Ministers recalled that the strategic nuclear forces of the Alliance remain the supreme guarantee of Allied security and underpin NATO’s extended deterrence architecture.

“NPG Ministers agreed to continue enhancing NATO’s nuclear deterrence mission by modernising NATO’s nuclear capabilities, strengthening its nuclear planning capacity, and adapting to achieve its security interests.

“The Alliance maintains a safe, secure, effective, and credible nuclear posture to preserve peace, prevent coercion and deter aggression.

“The NPG Allies reaffirmed their enduring commitment to sharing the responsibilities, risks, and burdens of collective defence by investing in the resources, capabilities, and forces required to deliver NATO’s nuclear mission and demonstrate Alliance unity and resolve.”

The 35th Meeting of the Ukraine Defense Contact Group also took place during the Meeting of NATO Ministers of Defence and attracted substantial media attention.

Also on 18 June, 20 Working Days submitted two FOI requests about the NATO Nuclear Planning Group - one to the MOD and one to the Foreign, Commonwealth and Development Office (FCDO).

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The request asked for “any documents showing any or (preferably) all of:

• “Which UK officials attended the meeting

• “What agenda items the UK Government added

• “What updates were provided by UK Government officials

• “Any outcome documents from the meeting”

FCDO is yet to send a substantive response.

However, on 17 July, the MOD sent a two page PDF, which is available in full below.

20260717 FOI2026 12613 Pashby NATO NPG.pdf

129KB ∙ PDF file

Download

Download

The response said: “A search has been completed within the Ministry of Defence (MOD) and we can confirm that information in scope of those parts of your request which relate to attendance, UK updates and outcome documents is held.

“However some of it falls within the scope of the absolute exemption provided for under section 21 (Information accessible by other means) and the qualified exemptions provided for under sections 24 (National Security), 26 (Defence) and 27 (International Relations) of the Act and has been withheld.

“The information which is releasable follows: The UK Secretary of State for Defence attended the NATO Nuclear Planning Group (NPG) meeting on 18 June.”

Dan Jarvis had been appointed as defence secretary on 11 June 2026, meaning he had only been in the role for a week when he attended the NPG.

The previous defence secretary, John Healey, had been in the post from 5 July 2024 until 11 June 2026, when he resigned because he had wanted more money to be committed to the Defence Investment Plan (DIP).

Jarvis had been seen in photographs shared about the Meeting of NATO Ministers of Defence, but there had been no official confirmation that the UK had sent any officials, nor the names of those officials, to the NPG.

The MOD’s response to the FOI request declined to share some information because it was “accessible by other means.” That meant the statement published by NATO.

The information withheld due to “national security”, “defence” and “international relations” referred to the UK Government’s commitment to strategic ambiguity over its nuclear deterrence policy, to avoid prejudicing “the defence of the British Isles or any colony”, and to protecting its relationships with the US, NATO allies and NATO itself, respectively.

Part of the MOD’s response said: “Section 24(1) provides that information is exempt if exemption is required for the purpose of safeguarding national security.

“The Act contains a presumption in favour of release. There is a recognised public interest in nuclear deterrence due to its high-profile role in deterring the most extreme threats to our national security and way of life.

“Communicating publicly on nuclear deterrence plays a part in achieving effective deterrence by reassuring our allies and messaging our potential adversaries.

“However, effective deterrence relies on the UK and NATO maintaining a policy of deliberate ambiguity on details of our nuclear deterrence policies, postures and capabilities.

“This deliberate ambiguity complicates the calculations of potential adversaries, reducing the risk that nuclear weapons are used, and so contributing to strategic stability.

“The balance of public interest was found to be in favour of withholding the information from release for the purpose of safeguarding national security.”

Elements of the UK’s nuclear deterrence policy are sometimes revealed.

A House of Commons Library research briefing titled Strategic Defence Review 2025: NATO published on 18 June 2025, said the review recommended “that the government begin discussions with the US and NATO on greater UK participation in NATO’s nuclear deterrence mission.”

The briefing added that the recommendation “raised questions about whether the government is considering buying nuclear-capable F-35A aircraft and allowing US nuclear weapons to return to the UK.”

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The liability had previously been announced in a statement by a minister which had left open the possibility that taxpayers were only on the hook for part of a total £10bn liability, but a response to a Freedom of Information (FOI) Act request by 20 Working Days has confirmed that they were exposed to the full figure.

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I initially wrote in the ‘About’ section when I launched this Substack at the end of June 2026 that this is an experiment. Well, this is an iteration of the experiment.

I might change the URL in future to reflect the name change, so don’t be alarmed if you see that happen down the line.

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I’m trying to teach myself quickly about how to use the platform and see what other similar journalists, writers and creators are doing.

Having written a few newsy articles now, I can see that it will be a lot more elegant to write in the third person with the publication being called something other than my name.

There’s an established practise in journalism where journalists refer to themselves as the publication. I.e. ‘The Times approached the government’ means that the journalist working for the Times who is writing that sentence approached the government.

It felt a bit clunky for me to be saying ‘this Substack approached the government’ or ‘the author of this Substack approached the government’.

Rebranding from my name to 20 Working Days also means I can add some healthy journalistic distance between the subjects of the stories I write about and I.

And in case you aren’t a big fan of the Freedom of Information (FOI) Act like me - 20 Working Days is a reference to the statutory time limit that the Act gives organisations to respond to requests.

The Act says organisations subject to the Act must respond “not later than the twentieth working day following the date of receipt” of a request.

Having completed dozens of FOI requests, I know that it often takes far longer than 20 working days to get a response.

This can be because of public bodies either ignoring requests until the Information Commissioner’s Office (ICO) intervenes, because they manage to find an exemption to apply which allows the to extend their own deadlines, or because they wait until days or weeks after the initial request to ask for clarification, which means they can add an extension.

The change of the name of this Substack doesn’t signal that the focus has changed. It’s to signal that it will hopefully grow its own identity which is separate to my personal identity.

And I hope you keep reading and finding interest in the articles I write into the future.

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The Cabinet Office Freedom of Information (FOI) Clearing House, and any similar equivalent entities, are no longer in operation, according to a response to a FOI request by this Substack.

It is understood that when someone submits a FOI request, the type of sender is sometimes recorded - such as a member of the public, a campaigner, a company engaging in market research, or a journalist - and the inferred identity then informs the treatment of the request.

For the most politically sensitive FOI requests made to government organisations before December 2022, they would be sent to the Cabinet Office Freedom of Information Clearing House so that civil servants and ministers could review requests.

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On 27 April 2022, the House of Commons Public Administration and Constitutional Affairs Committee (PACAC) published its Ninth Report of Session 2021–22 titled The Cabinet Office Freedom of Information Clearing House.

Providing context for the public discovery of the existence of the Clearing House, the report said: “In April 2021, a judgment by a First Tier Tribunal required the Government to release information on a body known as the ‘Clearing House’—a body within the Cabinet Office which assists with the processing of Freedom of Information (“FOI”) requests—citing a “profound lack of transparency about the operation” of that body (“the First Tier Tribunal Case”).”

FOI cases are heard by the First Tier Tribunal if a public body subject to a FOI request appeals a decision by the Information Commissioner’s Office.

The report went on: “The Tribunal heard the case following a FOI request on 20 August 2018 by the journalist Jenna Corderoy. The FOI request was rejected by the Cabinet Office under Section 35(1)(a) and (b) of the FOIA, stating it would impact on the formulation of policy and communication between Ministers.

“After appeal and following delays, Ms Corderoy raised a complaint with the Information Commissioner’s Office, which upheld the complaint on 13 July 2020. The Cabinet Office appealed to the Tribunal.

“By the time the Tribunal concluded, the nature of the case had changed as the Cabinet Office released 145 out of the 159 rows of information that were being sought under the original FOI request.

“However, the Cabinet Office sought to withhold fourteen pieces of advice it judged to be sensitive on the grounds of national security and personal information. In its final decision, the Tribunal granted release of a further six rows of data. Following the Tribunal decision, the Cabinet Office did not appeal the judgement and released the relevant information.”

Corderoy is a journalist currently working for the online publication Democracy for Sale, which describes her as “an award-winning investigator and FOI ninja who was formerly an investigative reporter at openDemocracy.”

The committee raised concerns about a lack of transparency about the function of the clearing house. The report said: “Information on the Clearing House and its structures within the Cabinet Office and within Government itself is limited—though some details on its structure can be gathered from job adverts from April 2020.

“These suggest the Clearing House is administered by the FOI & Transparency Team in the Cabinet Office, which is a body within the Private Office Group and ultimately overseen by the Director General for Propriety and Ethics.

“On 9 March 2021, the then Chancellor of the Duchy of Lancaster, Mr Gove, wrote to the Committee explaining the Clearing House is a three-person team.

“Further details on its operations and how effectively it operates cannot be seen based on existing disclosures. Appearing before the Committee, the then Information Commissioner, Elizabeth Denham, was unable to answer questions such as whether the existence and operation of the Clearing House made a necessary or helpful contribution to cross-Government FOI processing.”

It quoted Denham as saying: “I wish I could answer that question, but we simply do not know, because the actual operations of the Clearing House are opaque to our office.”

In its conclusions, the select committee’s report said: “A greater level of transparency is required about the Clearing House. To further allay concerns about the Clearing House, a greater volume of data on its performance should be published.”

On 25 August 2022, the Guardian newspaper published an article titled “‘Orwellian’ government unit accused of blocking FoI requests to be replaced”.

The article said: “The Cabinet Office clearing house, which circulates details of certain FoI requests by journalists, campaigners and others around Whitehall and also advises on how to respond to them, is to be replaced by a freedom of information ‘centre of excellence’.”

In an effort to uncover whether FOI requests from journalists and campaigners, which are often politically sensitive, are still being filtered through the Cabinet Office, this Substack submitted a FOI request to the Cabinet Office on 1 July 2026, which asked: “Please will you send me any documents which show whether the Cabinet Office Freedom of Information Clearing House, or a similar equivalent, is still in operation?

The Cabinet Office was also asked to supply the entity’s current terms of reference or equivalent, on the assumption that FOI requests are still being filtered by the Clearing House or a similar equivalent.

In response, on 7 July, the Cabinet Office said: “We are writing to advise you that following a search of our paper and electronic records, we have established that the information you requested is not held by the Cabinet Office.

“The FOI Clearing House was closed in December 2022, and we therefore hold no
information in relation to your request.”

It is reasonable to expect that the use of the phrase “or a similar equivalent” should have captured the “centre of excellence” mentioned in the Guardian article from 2022. However, it is unclear whether the Cabinet Office’s 7 July 2026 response accepted that the centre of excellence was described by that phrase.

This Substack has submitted a follow up FOI request on 8 July asking whether the centre of excellence still exists and for its terms of reference or equivalent.

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The mystery of whether the government was thinking about ending the consent-based policy for siting the proposed geological disposal facility for nuclear waste continues, following mixed responses to Freedom of Information (FOI) Act requests.

Nuclear power and defence nuclear activities produce waste, some of which is classified as high level waste (HLW) - meaning highly radioactive, and that needs a long term disposal solution which is not simply sitting at a licensed nuclear site.

The longer that nuclear waste remains sitting at the surface of the Earth, the greater the risks it poses to the environment and people.

Risks include degradation due to exposure to the elements if it has not been immobilised and increased potential for improper access, which could lead to proliferation risks. Proliferation risks means the creation of illicit or licit nuclear weapons.

The UK Government’s sole policy answer to the long term disposal of high level waste is called the geological disposal facility (GDF). The author of this Substack has written extensively about the plans for a GDF for New Civil Engineer.

Work to select a GDF site should take 20 years, according to the government body responsible for the project – Nuclear Waste Services (NWS) – and a further 150 years to build, fill and close the facility. NWS is part of the Nuclear Decommissioning Authority (NDA), which is sponsored and funded by DESNZ.

The HLW then needs to sit and remain undisturbed for 100,000 years before its radioactivity has reduced sufficiently for people to be able to be near it. The GDF has been estimated to cost up to £53.3bn and was rated by the government’s own National Infrastructure and Service Transformation Authority (NISTA) as ‘Red’, meaning the project appears “unachievable” in its 2025 annual report.

On 25 September 2025, the Telegraph published a story where an anonymously quoted government source said that the Department for Energy Security and Net Zero (DESNZ) had decided to review the consent-based approach to siting the GDF.

The consent-based process for deciding where to site the GDF has been government policy since 2014, when it published the Implementing Geological Disposal white paper. The paper outlined “an approach based on working with interested communities, beginning with 2 years of actions overseen by government and intended to address issues that the public and stakeholders have told us are important to them.”

The Telegraph reported that its anonymous source said that conversations were taking place within government to consider prioritising areas with the best geology, rather than areas with the most welcoming communities. A DESNZ spokesperson denied that the policy was under review.

Ending the consent-based process could result in ministers having the power to impose a GDF on a community, although they would still face the standard planning and consenting obstacles, including potential judicial reviews from campaigners.

In response to the story in the Telegraph, a former DESNZ minister told the author of this Substack, for New Civil Engineer, that he thought it was inevitable that the consent-based policy would have to end, otherwise the government wouldn’t be able to deliver a GDF.

The report in the Telegraph could be viewed as an example of the established political communications practice of ‘kite-flying’. This is when a minister or someone working on their instruction speaks to the media on the condition of anonymity about a policy decision the government is considering, with the intention of going forward with implementing the decision on the basis of the reaction to the story the journalist writes.

The author of this Substack submitted three separate FOI requests to DESNZ to try to discern whether DESNZ employees, including ministers, in September 2025, were thinking about ending the consent-based process.

The purpose of the FOIs was not to identify the source and it’s entirely possible that the person speaking to the Telegraph did not have the political connections it was implied that they had.

FOI requests are only able to recover written or image-based media that public authorities choose to record and share, so they can’t capture phone calls or in-person meetings. The conversation with the Telegraph may have taken place over the phone or in-person.

It is also possible that the Telegraph’s source is an employee of a government organisation other than DESNZ, or even someone familiar with government thinking, but not themselves employed in the government, or was potentially a very junior DESNZ employee whose correspondence would be more difficult to recover using the FOI Act.

FOIs are often rejected if they include a request for correspondence without naming the people that the correspondence was sent between, so the FOIs about the government’s thinking in September 2025 were aimed at specific named government employees at the top of government.

There are far fewer individuals in the most senior roles in departments. DESNZ employed 4935 people directly within the department according to transparency data released in summer 2025. It is harder to identify more junior employees who are likely to have been involved in subject-specific conversations because there are more of them and many have the same job title.

On 13 April, using the FOI Act, this Substack asked DESNZ: “Please will you send me any records showing mentions by DESNZ ministers and DESNZ special advisors of the consent-based process for a geological disposal facility between 1 August 2025 and 1 October 2025?

“Please include complete conversation chains where the consent-based process for a geological disposal facility is discussed in any correspondence within those parameters.”

In response, on 11 May, DESNZ said: “We have considered your request in accordance with the Environmental Information Regulations 2004 (‘the EIRs’) as the information you request falls within the definition of ‘environmental information’ in the EIRs.

“We do not hold any information within the scope of your request. Specifically, we do not hold any records of mentions by DESNZ ministers or DESNZ special advisers of the consent-based process for a geological disposal facility during the period 1 August 2025 to 1 October 2025. As a result, we do not hold any correspondence or complete conversation chains falling within the parameters you have requested.”

On the same day, this Substack sent a follow up to DESNZ, asking: “Please will you keep the request the same except for a different list of people. I am basing this on this organogram.

“The DESNZ people should this time be (with Job ID in brackets):

• Permanent Secretary (250)

• Second permanent secretary (1)

• Director General Net Zero, Nuclear and International (NZNI) (5)

• Director Nuclear Projects Delivery (13)

DESNZ responded on 28 May, where it said: “We have considered your request in accordance with the Environmental Information Regulations 2004 (‘the EIRs’) as the information you request falls within the definition of ‘environmental information’ in the EIRs.

“We do not hold any information within the scope of your request. Specifically, we do not hold any records of mentions by Permanent Secretary, Second Permanent Secretary, Director General of Net Zero, Nuclear and International, and Director of Nuclear Projects Delivery of the consent-based process for a geological disposal facility during the period 1 August 2025 to 1 October 2025.

“As a result, we do not hold any correspondence or complete conversation chains falling within the parameters you have requested.”

The third a final FOI was submitted on 28 May, which changed the list of job roles to:

• Deputy Director Nuclear Projects Delivery (109)

• Deputy Director Nuclear Projects Delivery (104)

• Director Nuclear Power, Infrastructure & Decommissioning (16)

• Deputy Director Nuclear Power, Infrastructure and Decommissioning (157)

• Deputy Director Nuclear Power, Infrastructure and Decommissioning (194)

• Deputy Director Nuclear Power, Infrastructure and Decommissioning (217)

DESNZ responded on 23 June, saying: “Under the Freedom of Information Act 2000 (“the Act”), you have the right to:

1. know whether we hold the information you require; and
   

2. be provided with that information, subject to any exemptions under the Act which may apply.
   

“The Department can neither confirm nor deny whether it holds information within the scope of your request.

“Section 35(3) of the Act provides that the duty in section 1(1)(a) to confirm or deny whether information is held does not arise where compliance would involve the disclosure of information which would be exempt under section 35(1)(a), which relates to the formulation or development of government policy.

“In this case, confirming or denying whether information is held would itself disclose information falling within the scope of section 35(1)(a).

“The Department therefore considers that section 35(3) is engaged.
Section 35 is a qualified exemption and we have therefore considered the balance of the public interest in deciding whether to maintain the exclusion from the duty to confirm or deny.

“There is a public interest in openness and transparency about the work of government.

“However, there is also a public interest in ensuring that the effective conduct of public affairs is not undermined. Confirming or denying whether information is held could disclose information about the consideration of matters within government, which would be likely to affect the ability of ministers and officials to engage in full and frank discussions and could lead to unwarranted inference or speculation.

“Having considered these factors, we have concluded that the public interest in maintaining the exclusion from the duty to confirm or deny outweighs the public interest in confirming or denying whether the requested information is held.

“This should not be taken as an indication that the information you requested is or is not held by the Department.”

It is unclear why DESNZ used EIR for the first two FOI request, but FOI for the third one. It is also unclear why DESNZ was able to confirm if such documents existed in the first two, but not for the third.

This Substack has submitted a challenge to the third FOI response via a request for an internal review on the basis that DESNZ inconsistently applied EIR versus FOI, and had previously deemed it appropriate to confirm or deny whether it held the documents requested.

Note: This article was written and published when this publication was called ‘Tom Pashby’. It is now called ‘20 Working Days’.

The UK Ministry of Defence (MOD) has declined to reveal whether it has assessed the threat posed by Iran’s ballistic missile to London, after two intermediate-range ballistic missiles (IRBMs) were fired at the UK territory of Diego Garcia in March.

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This is my first post on my shiny new personal Substack. I’m using this to introduce myself and to explain what I expect to write about.

Journalist

I’m a Gold Standard NCTJ-qualified journalist employed in a staff role as a senior reporter at New Civil Engineer (NCE). I write about infrastructure and civil engineering, with focuses on nuclear, the electricity grid, critical national infrastructure, the environment, resilience and risk.

In addition, I have written extensively about nuclear disarmament, the environment and activism as a freelance news reporter at the Canary, and about defence issues including nuclear warfare, ballistic missile defence, drone and counter-drone technology and the Iran conflict as a freelance contributor at Resilience Media.

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Using the Freedom of Information Act

As someone who isn’t a political editor of a mainstream news media organisation (yet), I don’t have privileged relationships and access within Westminster and Whitehall, which has led me to become somewhat effective at using the Freedom of Information (FOI) Act to find news stories.

At the time of writing, I have 117 FOI requests to my name on my WhatDoTheyKnow profile, many of which are public, but some will remain hidden for up to 12 months while I either work on writing stories about them, or accidentally forget I created them at all.

Some of my FOIs will take months, potentially more than a year, to reach their conclusion - often a rejection.

This can be due to delays in normal response times, public bodies giving themselves extensions, substantive responses being inadequate, internal reviews taking up to 40 working days, and slowly working with the Information Commissioner’s Office (ICO) to get proper responses.

On the rare occasion when a FOI response is of interest, I will try to get it covered in NCE if it’s relevant to the magazine’s readers, or elsewhere if it’s not relevant to NCE. Sometimes, FOI-based stories which I believe have good news value fall through the cracks of editors desks, and on those occasions, I will try to bring them here.

I will also, however, be using this space to write about my process for submitting FOIs as well as less successful FOI requests, to act as a record of my work, which will become public anyway due to WhatDoTheyKnow’s forced publication system and partly to hopefully assist other FOI users with their own work.

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Areas of interest

My main areas of interest in journalism are those which intersect between my actual interests and what’s relevant to the readers of the publications I write for, so that I can get paid for this work.

You can expect to see lots of niche information about nuclear power, defence nuclear - which covers nuclear weapons and nuclear propulsion for submarines, nuclear waste and decommissioning, other critical national infrastructure, the environment and environmental politics, UK politics more generally, wider defence and international relations.

Before my NCTJ, I achieved BSc (Hons) Environmental Science and MA Global Political Economy degrees, to give you more of a sense of what I’m looking for in stories.

Ex-future-politician

Before making a career change to journalism, I was an activist in the Green Party of England and Wales for 10 years, between 2012 and 2022. I ran for parliament in Braintree, Essex in 2017 and in South West Hertfordshire in 2019.

I also ran for local council three times and for deputy leader of the party once. I was a member of the Green Party Executive between 2017 and 2019. I left the party in 2022 and haven’t been a member of any party since then.

Please do subscribe if my work sounds like it could be of interest to you.

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