To say that CoRWM’s recent public meeting in Workington was dissappointing would be a truly masterful piece of understatement!

Having now considered the “answers” the public were given by CoRWM (Committee on Radioactive Waste Management) during the meeting in Workington on 30th April, Cumbria Trust Director John Wilson has sent the following letter to the members of the committee:

TO ALL CoRWM MEMBERS

5th May 2014

Dear Members

I wish to place on record my genuine concerns about the whole so called Managing Radioactive Waste Safely process and CoRWM’s role therein; with particular regard to the GDF process and issues.

I and many others now have no trust in any of DECC, CoRWM, the Government, the major political parties or the NDA over this issue.

Why?

  1. A complete lack of strong and logical political leadership resulting in proposed solutions being based upon political and socio-economic convenience.

  2. A failure to place safety first.

  3. An underlying pre- determination to site a GDF in West Cumbria and

  4. A determination to do so at almost any cost including usurping democracy and tearing up legally binding agreements.

Let’s recap.

In the 1980s Nirex (and others) looked at the country’s geology, identified over 500 potential GDF sites but ended up choosing a site at near Sellafield (not in the original list!). After spending £400m the whole process fails (1997) essentially due to irrational site selection and inappropriate geology.

Times passes, people “forget” or are supposed to, politicians move on, the Nirex case is air-brushed away, West Cumbria becomes more malleable and generally nicely groomed….meantime circa 2000 some bright spark at Nirex or CoRWM comes up with the politically convenient “voluntarism” concept.

We end up with the 2008 MRWS White Paper.

[By the way this ignores recommendations from objective individuals and bodies such as The Royal Society and the House of Lords Science and Technology Committee Third Report of 1999 which recommended that:

the first phase of site selection … would consist of establishing qualitative criteria and using them with desk studies to identify a “long list” of, say, 15-20 potentially suitablesites. The criteria at this stage would be primarily, but not exclusively, geological and hydrogeological … The final list of sites for field investigation would be derived by consultation or by using a volunteering approach”.]

By this time (2008) Copeland BC (which had objected to the proposed Nirex site due to safety concerns and irrational site selection) is “onside”.

Result for DECC. The 11 years had not been wasted!

And lo and behold within weeks of the 2008 White Paper being published Copeland “expresses an interest” in a GDF. It seems inconceivable that proper consultation could have taken place within this period. Also inconceivable that this (Copeland intention to express an interest) was not known by Central Government ie that this was going to happen before the WP was published.

So the only area of the UK which had been considered in detail before and found “faulty” (pun intended!) is the only volunteer.

The neighbouring Allerdale then does the same as does Cumbria County Council – the latter no doubt so as to ensure it was involved with the process and the former probably simply driven by a desire to share in the financial benefits of the “deal” which seemed “done”.

After the expressions of interest DECC then specifically, unequivocally and unconditionally agrees that MRWS cannot proceed in West Cumbria (namely Copeland and Allerdale) without the Three Green Lights at Central Government, County Council and District Council level. Great play is made of this during MRWS consultation.

The County Council eventually says no.

DECC then makes a Call For Evidence regarding the “failure” and the majority of respondents call for a new approach putting geology first and a national geological assessment before any volunteers are sought. Only a very few (4 – one of which is Copeland) call for County Council exclusion from key decision making.

DECC ignores the call for national geological assessment and then proposes to exclude County Councils from the process going forward and place the decision making emphasis on District Councils (where they exist) and unitary authorities where they exist.

The latter is “justified” by an illogical, irrational and entirely disingenuous and fatuous argument based on “localism” and “subsidiarity”.

Subsidiarity is a fine principle intended to place decision making at the lowest practical level but DECC twists this and simply says that Districts are best as they are local but have more resources than Parishes – who are more local. Also argues this follows European best practice.

DECC is obviously wrong.

Districts simply do not have the expertise or the resources to deal properly with the issue of a GDF which is an enormous infrastructure project of great national importance and one of huge complexity. Most struggle to run public toilets.

Even County councils will struggle but are undoubtedly much better placed than districts and of course are charged with responsibility for waste and minerals. In any event a project like a GDF clearly affects more than the immediate area of GDF location.

France, Sweden, Finland and Switzerland have all placed decision making with their equivalent of County Councils although right of withdrawal may vest at a more local level ie the equivalent of our parish.

DECC’s proposal irrationally treats a District like Copeland in the same category as a large unitary such as Northumberland or Cornwall.

It is obvious what DECC is up to and this will not withstand judicial scrutiny or indeed any objective scrutiny.

CoRWM describes itself as in “broad agreement” with DECC’s proposal and that is “understandable” to vest powers in Districts as Representative Authority to the exclusion of County Councils.

At the public meeting in Workington CoRWM members seemed to be offended and a little surprised that such comments had been interpreted by many as supportive of the DECC proposition to vest powers at District level.

It seems that CoRWM thought, by virtue of the attempted quasi-legal caveats in paragraph 45, it had done enough to counter such “interpretation”.

The reality is that CoRWM could and should have said YES or NO to the question and avoided this ambiguous situation.

At Workington some members certainly gave me the impression that they disagreed with the DECC proposition to vest decision making with Districts.

In these circumstances of mistrust and gerrymandering it is imperative that CoRWM is honest and robust in its dealings with DECC.

I don’t believe CoRWM’s approach to this key issue is either to date.

So, to clarify CoRWM’s paragraph 45 response, I would like a yes or no written answer from each CoRWM member on this point (vesting decision making at district level) by return please.

I think the CoRWM position should also be clarified to DECC now and certainly before the next White Paper is published.

CoRWM’s integrity, and that of its members, is at stake.

I also am dismayed and very concerned at the general theme and tenor emanating from many members at the Workington meeting with regard to geology and a GDF. Specifically, the apparent “downplaying” by members of the importance of a geological barrier.

[Of course this is essential to proceed in West Cumbria given the unsuitable geology…!]

Can I remind you all that this is a national process and it must be in the national interest (from a safety and cost perspective) to site a GDF in something like our best/most suitable geology. According to Nirex 30% of the UK is suitable.

A GDF relying on an engineered solution and not a geological barrier is arguably not a GDF. However, if such approach is ever to be taken by a country then surely that should only be a very last resort for any nation and only when no suitable geology can be found in the country concerned.

No community (maybe with the exception of Copeland) will volunteer without knowing its geology is potentially safe and suitable as determined by an independent assessment.

Clay or salt geology seems to be internationally regarded as the most appropriate. We have both in the UK. France is siting in “Oxford clay” which gives a little clue as the availability of similar geology in the UK. I refer you to the comment of Professor Bruce Yardley explaining why Sweden and Finland had GDF sites in hard rock – in short as they have no clay [or salt].

http://www.geos.ed.ac.uk/homes/rsh/Cumbrian_MP_Fact_finding_session_with_experts__note_of_session_verbal_discussion,_10_January_2013__PUBLISHED.pdf

See paras 168-199

Finally it is again not in the national interest that there appears to be no cognizance at all of the issues and the problems relating to MRWS and siting of a GDF in a National Park or AONB or affecting a European Site eg Special Area of Conservation (SAC).

In short one could only carry out major development like a GDF in or affecting a National Park or SAC site if all other options had been exhausted.

So simply put, by way of example, if the West Cumbrian process had not ended and the chosen site had been in Ennerdale granite (as was mooted and still mooted by some!) then under our planning laws relating to National Parks and European legislation (Ennerdale has a SAC) the process could not proceed unless it could be shown there were no other suitable sites elsewhere in the country.

Given 30% of the UK has suitable geology, in this scenario, the so called “voluntarism” would fail in the end leaving the country no further forward in its search for a GDF.

Even Nirex in its search excluded what it called environmentally sensitive sites at an early stage. This is sensible on many levels and the siting process should reflect this for pragmatic and legal reasons let alone the other obvious reasons. It is in the national interest to do so. In fact only a fool would not.

I look forward to your reply by return

Yours

JOHN WILSON

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