22nd August 2018
CONSERVATION OF THE NATIONAL PARKS
As the former Leader of Cumbria County Council, it was my Cabinet and I who rejected the last search process for a radioactive waste, Geological Disposal Facility in West Cumbria, orchestrated by the MRWS process, for a substantial number of reasons. including:
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No statutory, enshrined Right of Withdrawal from the process.
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No Sovereign Wealth Fund for Cumbria – in perpetuity.
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Plethora of expert opinion against the geology – NOT rebutted by the NDA
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No proposals for a Strategic Environmental Assessment
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Allerdale ruled out nem con. by all Cabinet Members.
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Copeland too small without infringing designated and protected areas.
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Significant democratic deficit. No credible local or Cumbria-wide support.
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Huge potential for planning blight/property devaluation
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Received no commitment to invest in international standards of safe surface or sub surface storage (e.g. Sweden); the ‘twin-track’ approach, in effect.
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The adverse findings of the NAO and the highly critical comments by the Public Accounts Committee (Margaret Hodge et al)
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But, nonetheless, emphasising the County Council’s total commitment to urgent alternative investment in Sellafield and West Cumbria – not least, the infrastructure, but with no forthcoming guarantees from the government.
Nothing has changed, except for yet another rebranding exercise and a White Paper which seeks to sideline county councils.
I am now writing to you – ahead of the House of Lords debate on 6th September on the “Draft NPS for Geological Disposal Infrastructure” – as a Director of Cumbria Trust (cumbriatrust.org)
The conclusions reached by the House of Commons BEIS Committee on the Draft NPS for Geological Disposal Infrastructure should be a matter of great concern for those who value and respect the National Parks, and for Cumbrians in particular. The failure to exclude designated areas, including AONBs and National Parks, from the search process for geological disposal is both alarming and irrational, in that it demonstrates a clear lack of understanding of the protection in law given to these areas.
Major developments can only be permitted in exceptional circumstances where it can be demonstrated that there are no alternative sites available outside the National Park (LDNPA Core Strategy CS12). The fact that other UK sites outside a National Park may not have volunteered is of no relevance. Voluntarism is not a concept recognised by planning law, and as such, should a site within a designated area be selected, there would be a requirement to survey the entire non-designated land area (around 91% of the UK) to demonstrate that no alternative exists. This highlights the absurdity of the failure to exclude designated areas, something which even Nirex understood three decades ago. This is not simply a matter of failing to learn from past mistakes, but of introducing new and significant mistakes as they go along, and Cumbria Trust believes it simply must not go unchallenged.
I would also refer you to the Sandford Principle – Section 62 of the Environment Act 1995 – enjoyment of the National Parks ‘shall be in a manner and by such means as will leave their natural beauty unimpaired for the enjoyment of this and future generations’. You will also be aware that as a World Heritage Site, the Lake District has adopted a Statement of Outstanding Universal Value, and that its inclusion in a search area will undoubtedly threaten that status, requiring notification to the World Heritage Centre and ICOMOS.
We would encourage you to speak up strongly for the protection of our designated areas and for Cumbria in particular.
We know from the last process that Ennerdale (specifically the Ennerdale granite intrusion which runs from the shore of Buttermere in the north to Nether Wasdale in the south) was identified by the MRWS geologist, Dr Dearlove, as a potential site for geological disposal, as was a second site (in the Mercia Mudstone Group rocks) near Silloth. If we allow this Draft NPS to proceed unchallenged these areas are likely to find themselves back in the spotlight. If an area such as Copeland volunteers, no test of public support is required until around 20 years into the process, during which time 20-30 deep boreholes will be drilled over the course of a decade. LDNPA planning permission would not be required since they now come under NSIP (Planning Act 2008) legislation.
For all of these reasons, designated areas must be protected and any new search process should exclude them from the beginning. My colleagues and I would urge you to use the debate on 6th September to push for that exclusion. Thank you.
Yours sincerely
Eddie Martin
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Eddie Martin speaking to Adam Powell on BBC Radio Cumbria:
Cumbria Trust 