Q1. How to define a community.
The answer to this question has been bedevilled and confused by the past attachment to the word ‘community’ of various adjectives at the whim and fancy of those organisations driving the Managing Radioactive Waste Safely (MRWS) agenda, and in particular the GDF siting process; eg. Host Community, Wider Community, Interested Community, Local Community, Affected Community etc. etc.
The 2008 White Paper (and there is no indication in the 2014 White Paper that the definition has changed) gave a reasonably understandable definition of the Host Community as that community within which a GDF could be sited. In terms of its scale it was small, and to this extent a Parish Council was generally accepted as the most identifiable unit which could represent that community.
The 2008 White Paper also defined a Decision Making Body (DMB) and this clearly gave an indication that the smallest identifiable unit for such a body was a District/Borough Council, though it did not exclude a County Council being a DMB. Neither of these bodies could possibly be construed as a Host Community although that did not stop two District Councils in Cumbria trying to assume that mantle during the previous MRWS process. As was stated by Parish Council representatives many times during that process, a District or County Council does not represent a community, and neither do individual District or County councillors; they represent wards or divisions within which reside a number of different and separate communities.
In summary, Gosforth Parish Council believes that the general description of a Host Community in the 2008 White Paper was essentially correct, and that the body which most accurately and democratically represents that Host Community is its Parish Council.
Q2. Effective Representation.
This Parish Council has had a long association in dealings with the Nuclear Industry and currently formally participates as a member of the West Cumbria Site Stakeholders Group. This group not only engages in dialogue with (among others) local communities (ie. Parishes which are adjacent to the Sellafield site) but accepts that they participate in some of the decision making. There are also formally arranged meetings between the Sellafield Site operator and those parish councils local to the site to discuss current issues and allow a 2-way line of communication.
This Parish Council has also had a particular interest and involvement in the waste disposal issue dating back to the days of NIREX and the subsequent Public Inquiry. Prior to that Inquiry, NIREX dealt with the Parish Council as representatives of the local Gosforth community and, on occasion, meetings were jointly arranged to provide information to the Gosforth parishioners. Due to the way the process unfolded, and evidence, particularly on the surrounding Geology and Hydrogeology became available, the Parish Council eventually found itself opposed to the NIREX proposals and represented itself independently at the Inquiry. (Ref. 1 – NIREX Public Inquiry proceedings)
When the MRWS issue was resurrected by HMG in 2006, the newly-formed HMG advisory body (CORWM) held meetings with local groups, which included specific invitations to Parish Councils surrounding the Sellafield site, to seek their views on why NIREX had failed to convince the local communities of the acceptability of their proposals. This Parish Council fully participated in those
discussions and also attended the series of workshops organised later by CORWM to gain a better understanding of the waste disposal issues. It was generally encouraged by the subsequent advice provided to HMG by CORWM on how to move forward.
When the 2008 White Paper was published the Parish Council not only responded to the associated consultation (Ref. 2 – Part of DECC public record) but raised specific issues of concern at meetings with the then Head of the Radioactive Waste Policy Team (DEFRA) – Dr Robert Jackson (Ref. 3 – Note for the record Oct. 2008) and later, when responsibility for MRWS was passed to DECC, with the then Head of Nuclear Materials and Waste Strategy – Bruce Cairns (Ref. 4 – Note for the record July 2009). There was no suggestion that the Parish Council was acting in any way other than in the interests of and on behalf of the Gosforth community.
The precipitate action of Copeland Borough Council in registering an Expression of Interest and its formation of a Shadow MRWS Partnership, effectively de-railed the whole process as laid out in the 2008 White Paper. The constitution of the initial Shadow Partnership included no representation from local communities, specifically Parish Councils, who had to rely on officers from the Cumbria Association of Local Councils (CALC) to act as observers. It was some time before CALC was invited to join the partnership.
The CALC officers found it necessary to form a working group with representatives from the Parish Councils of Copeland and Allerdale, which included Gosforth and the neighbouring parish of Ponsonby (which hosts a substantial part of the Sellafield site), to exchange information and monitor progress on the MRWS process as it developed. This led directly to CALC generating a Position Statement on behalf of the Parish Councils (Ref 5 – CALC publication) as it became obvious that the Partnership had no intention of recognising the rights of Parish Councils to represent Host Communities or have any influence in deciding on matters such as the disbursement of Community Benefits. It seemed to Parish Councils that the concept of ‘Localism’ stopped at the District Council level and there appeared to be no acceptance or recognition that there were (and have been for >100 years) three tiers of democratically elected local government.
The recent statement by the Secretary of State for Communities and Local Government (June 2015) on how planning authorities should consult and take into account the views of local communities when considering the siting of wind turbines is clearly phrased to envisage that ‘Localism’ means what it says and reinforces the points made above.
In summary, the Parish Council has a history of representing its parishioners and will continue to do so. In relation to MRWS it firmly believes that a Parish Council is the only true representative of a Host Community. Any future process must recognise the principle of Localism, the existence of Parish Councils, and their rights to represent their communities in any discussions and decisions concerning the siting of a GDF within their parish. The previous MRWS process was perceived and progressed as a top-down process, contrary to the way in which the White Paper was laid out, and ignored the principle of Localism; Above all it generated a sense of deep mistrust, as much informed scientific evidence and argument was cast aside or overridden in the interests of political expediency.
Q3. Management and Disbursement of Community Investment.
The Parish Council wishes to make clear that when referring to Community Investments or ‘Benefits’ as they were previously labelled, these are over and above that investment in area infrastructure such as road, rail, training, health, education etc. which will be necessary to enable a GDF to be constructed and operated, and that this area investment must be provided before there is any attempt to construct a GDF. Construction of a GDF should be viewed as an integral part of a wider economic/social development programme that is designed around the specific aspirations of a potentially interested area and not as an individual project. This area has past experience of infrastructure promises being made in relation to the construction of THORP (a bypass for Egremont) which did not materialise until long after THORP was in operation. The inadequacy of many local rural transport links and the sheer scale of a GDF mean that any local community will have to live under intolerable conditions for an extended period of time unless advance steps are taken to upgrade those links and mitigate the effects.
The Parish Council feels that introduction of Community Investment at this stage, and in particular the proposed amounts, may well be perceived as a bribe. It also has concerns as to which ‘Community’ or level of community the investment is aimed. Previous attempts to gain insight into what could be considered for inclusion were unproductive, HMG preferring ‘not to be specific’. Suggestions such as support for property prices, compensation for planning blight and the mal-effect on tourism, reductions in Council Tax etc. were not received enthusiastically.
If potential Host Communities (2008 White Paper definition), represented by their respective Parish Councils, are to be encouraged to participate in the future process it is essential that they should have access to some funding to enable them to participate. Examples would be travel and accommodation expenses for attendance where meetings are not held locally, and also to enable them to access independent advice should they deem this necessary. The decision on the amount of funding and for what purpose should be made by a body which is independent of RWM and the other two tiers of local government.
Those communities which will eventually be host to a GDF (it is recognised that it is likely that a GDF may well cover an area which spans more than one community) should receive a benefit in terms of compensation at a level which reflects the degree of upheaval and intrusion into their lives which the construction and the ongoing operation of the facility will cause. This will have to be a long-term commitment due to the nature of the project. That package should be ring-fenced for the benefit of, and administered by, each community. The amount of, the conditions under which it can be used, and how this benefit could be administered, would need to be subject to discussion (which includes the Host Community), but there already exists a local precedent whereby the nearby parish of Drigg & Carleton which hosts the Low Level Waste Repository (LLWR), receives a guaranteed annual amount from within a larger fund which is provided for the Copeland District but independently administered. All other parishes have access to this larger fund by application. Drigg & Carleton Parish Council administer their specific fund via a local trust.
In summary, the Parish Council believes that the arrangement proposed will be perceived as bribery. There must be an appropriate level of infrastructure investment in an area within which a GDF is hosted, prior to any decision made to actively proceed with a GDF being built and operated. It also believes that this investment must be kept totally separate from any other investment packages. The example of LLWR should serve as an example of how further local investment could be achieved.
Q4. Delivering a test of public support.
The Parish Council believes that before any attempt is made to test public support an effective educative programme should be implemented to ensure that any community which chooses to show an interest and to find out more of what a GDF is, and what it would mean for it to be sited within that community, can do so without prejudice. It became very clear during the previous process that many people (~ 80% of those polled in Cumbria who declared support for a GDF) knew little or nothing of what was involved in creating a GDF. The recent General Election experience casts further doubt on the wisdom of using conventional polling as a means of measurement of public opinion.
There should not necessarily just be one test of public support but that as the process develops there may be a need to ensure that initial support still holds good. The Parish Council disagrees with HMG that the whole process, once started should be continuous, which in any case flies in the face of its own advice (Ref PRINCE 2 (PRojects IN Controlled Environments) is a process-based method for effective project management. PRINCE 2 is a de facto standard used extensively by the UK Government and is widely recognised and used in the private sector, both in the UK and internationally.
The pauses for decisions to be made, as part of the previous staged MRWS process, were perceived by HMG as a stumbling block to progress. In reality they were a blessing as the process was unlikely to deliver an outcome and was likely to end up in the Courts.
When the 2008 MRWS process got underway the Parish Council produced a newsletter (Feb 2009) for its parishioners setting out the situation and including its own Position Statement, one point of which stated:
“That any decision, should one be necessary, relating to the hosting of a GDF within the parish of Gosforth, will be taken by the people of Gosforth via a local (parish) referendum held under the normal electoral rules/procedures”.
It has seen nothing in the 2014 White Paper which would cause it to change its position and still believes that a referendum as described is the only way of capturing the principle of Voluntarism.
Due to the immense scale of a GDF, undoubtedly its construction and operation will have influence and an effect on other communities well beyond the boundaries of the Host Community. Accordingly it may be necessary to conduct District and County–wide referenda to include those communities.
In summary, the Parish Council believes that a local referendum is the best way of assessing public support at the Host Community level. Without that assessment Voluntarism is meaningless. For the same reason, although referenda at District and County level may be necessary to gauge public support, those referenda should not be used as a means of coercion of the Host Community.