You can respond online here and you may wish to include some of the following points in your response to the consultation:
CONSULTATION QUESTION 1: Do you agree with this approach of identifying communities? Do you have any other suggestions that we should consider?
The geological screening report appears to be little more than a broad overview, which is a missed opportunity. A lesson from the previous MRWS process was that early information on geology would help communities to make a decision on volunteering.
There needs to be a test of public support before a community joins the process. It is a long term commitment which could cause significant blight.
Neighbouring local authorities should also have a say in the process. 4.21 suggests that they will be excluded from any test of public support even if a GDF could be close to their boundary.
CONSULTATION QUESTION 2: Do you agree with the approach of formative engagement? Do you support the use of a formative engagement team to carry out information gathering activities? Are there any other approaches we should consider?
This appears to be a process which is very easy to join, but difficult to leave.
There is a need for a test of public support before a community enters the process.
CONSULTATION QUESTION 3: Do you agree with this approach to forming a Community Partnership? Are there other approaches we should consider?
Radioactive Waste Management (RWM) should not be part of the Community Partnership, but should be available to answer its questions.
Frequent tests of public support are required to ensure that the Community Partnership continues to reflect the view of the community throughout this 20 year process.
CONSULTATION QUESTION 4: Do you agree with the approach to engaging people more widely in the community through a Community Stakeholder Forum? Are there other approaches we should consider?
A Community Stakeholder Forum could be appropriate if their views are taken seriously. Previous experience of forums in this area suggests that this may not happen.
The Chair of the Stakeholder Forum must not be part of the Community Partnership – there is a need for independence.
CONSULTATION QUESTION 5: Do you agree with the proposal for a Community Agreement and what it could potentially include? Are there other approaches we should consider?
The suggestion that a local authority may be able to overrule the remaining members of the Community Partnership is unworkable. Partnerships cannot function in that way.
The Community Agreement should be put to a public vote before it is accepted, since it may have a significant impact on the community. The public (rather than just the Community Partnership) must be confident that they have an acceptable right of withdrawal before entering the process. The failure to draw up an adequate right of withdrawal during MRWS was one of the causes of the process being halted before stage 4.
CONSULTATION QUESTION 6: Do you agree with the proposed approach to the way community investment funding would be provided? Are there alternatives that we should consider?
There is a risk that this method of funding will act to ensure that deprived areas, rather than geologically suitable areas, are more likely to volunteer.
CONSULTATION QUESTION 7: Do you agree with the proposed process for the right of withdrawal? Do you have views on how else this could be decided? Are there alternatives that we should consider?
The ongoing right of withdrawal must rest with the community, not the Community Partnership. In order to ensure that there is alignment between the community and Community Partnership, frequent tests of public support are required.
The withdrawal process is unnecessarily complex. There should be no requirement to go through a pre-defined process. If the public vote to withdraw, that should happen with immediate effect.
CONSULTATION QUESTION 8: Do you agree with the approach to the test of public support? Do you agree that the Community Partnership should decide how and when the test of public support should be carried out? Do you have views on how else this could be decided? Are there alternatives that we should consider?
It cannot be right that there is a single test of public support after 20 years. What possible reason could there be for suggesting this, other than to trap a community within the process? If this is a genuine voluntary process then there must be frequent tests of public support.
CONSULTATION QUESTION 9: Do you feel this process provides suitably defined roles for local authorities in the siting process? Are there alternatives that we should consider?
The local authority must not be able to overrule the remainder of the Community Partnership. The scale of this project also requires approval at county level.
CONSULTATION QUESTION 10: Do you have any other views on the matters presented in this consultation?
Communities should have access to a truly independent scientific body such as MKG in Sweden
The current consultation is likely to lead to an early breakdown of trust, since the public are kept at a distance from decision making by the Community Partnership, and appear to have almost no control of it.
It appears that lessons have not been learnt from the MRWS process, and what is described as an open and transparent process, could be a long way from that.
The investigation process, which includes a borehole drilling programme may cause significant blight to an area, particularly if an area’s economy depends on tourism. In addition to setting out the benefits of hosting a GDF, or entering the siting process, there needs to me more honesty and openness about the negative aspects.