The key conclusions of the NFLA model response to the MRWS consultation include:
1. The Government’s proposals represent a highly counter-productive move back to centralised control, whilst continuing to pay lip service to voluntarism. This consultation document should be withdrawn and the Government should go back to the drawing board.
2. The previous process failed partly because of the intractability of the nuclear waste problem, but also because of the Government’s refusal to accept most of the recommendations of its own advisory committee – the Committee on Radioactive Waste Management (CoRWM).
3. CoRWM recommended a high level of public engagement in any future process. This has been ignored.
4. The scope of this consultation is focussed solely on finding a site for a geological repository when the priority should clearly be the development of robust interim storage.
5. There should be a national debate about whether the process should be looking for the best geology for the job or whether to use mediocre geology and rely more heavily on very expensive engineered barriers.
6. The Nuclear Decommissioning Authority’s (NDA) Radioactive Waste Management Directorate (RWMD) has listed 900 outstanding scientific and technical issues with a deep underground repository which still need to be resolved. The process of resolving these issues needs to be much more open and transparent.
7. Any assessment of community support for a radioactive waste proposal needs to be on the basis of informed consent. The idea that because District Councils have full-time staff they can somehow become better qualified to make a judgement on a highly complicated area of scientific controversy is absurd. Funding needs to be provided so that Councils can commission independent advice and so that nongovernmental organisations (NGOs) can provide a critical voice.
8. Any public awareness campaign needs to be organised by an independent body, not the developer, and should be carried out on the basis that all sides of the debate are represented fairly with equal resources.
9. The Government must drop the idea of using the nationally significant infrastructure planning regime for a deep underground radioactive waste repository.
The Government should produce a baseline inventory which does not include new build reactors, and a Maximum Inventory which shows the impact of a 16GW new build programme. It should enshrine in any future process the principle that any community willing to host nuclear waste facilities should get a say in the inventory of waste committed to those facilities.
10. The Government must re-visit CoRWM’s idea of a separate process which can examine the ethics of producing more waste in the face of the uncertainties involved with nuclear waste management.
11. Communities faced with proposals for nuclear waste facilities in their vicinity should be funded to produce alternative economic strategies so that no-one has to decide to accept such a facility because they feel there is no alternative.