Review of the Siting Process for a Geological Disposal Facility.
N.B. Cumbria Trust is happy for you to use this text to assist you to formulate your own response. However, in order to ensure that your response is counted by DECC please do not just copy and paste, but tailor your response to suit your own views.
The following are the questions as they are asked in the Department of Energy and Climate Change (DECC) consultation document followed by the main points from the detailed Cumbria Trust response.
1.Do you agree that a test of public support should be taken before the representative authority loses the Right of Withdrawal?
Everyone must have complete confidence in the process. There must be a high level of engagement, openness and complete transparency.
Decision making within the process should involve as broad a group as is democratically practical.
There must be enshrined the legitimate and democratic Right of Withdrawal by potential host communities, parish councils, district councils and the county council (or unitary authority).
2.Do you agree with the proposed amendments to decision-making within the MRWS siting process? If not how would you modify the proposed phased approach or alternatively, what different approach would you propose?
The proposed new arrangements outlined in the consultation paper show a complete lack of independent advice and no genuinely impartial supervision of any of the processes.
We strongly disagree with the changes in arrangements that allow District Councils to act as the Representative Authority. We also disagree with the suggestion that the Leader of the Representative Authority should chair the Steering Group.
3.Do you agree with this approach to revising roles in the siting process set out in the White Paper? If not, what alternative approach would you propose and why?
The proposals will allow for a body, most likely to be a Borough or District Council, to express an interest. This body will then be responsible for steering the project and finally, as Representative Authority (RA), it will decide upon a right of withdrawal. These powers should not be held by one body.
A GDF project will cross many service boundaries, highways, minerals, planning, safety and waste disposal. By limiting the County Council to a consultant role it seems that DECC wishes to remove obstacles to the outcome that they want. DECC are not creating a process properly based on voluntarism.
It is vital that any further siting process must include a clear and unambiguous definition of a Host Community.
4.Do you agree with this proposed approach to assessing geological suitability as part of the MRWS siting process? If not, what alternative approach would you propose and why?
Selection of the suitable geology for geological disposal of nuclear waste must be the number one priority. DECC has chosen in this review to mislead, misrepresent and distort the facts in order to engineer the outcome it wants.
A national screening process for sites with suitable geology is possible. The data already exists that could be examined and compiled into a national report within a matter of months.
It must be emphasised repeatedly that the long term safety of a GDF depends almost entirely on the geology in which it is placed.
5.Do you agree with this proposed approach to planning for the geological disposal facility?
The ‘representative authority’ role should not be delegated to a district council. A County Council must have a participative role rather than merely a consultative one.
There will be conflict of interest if the final decision about a GDF application is adjudicated by the Secretary of State for ENERGY. This is not acceptable.
6.Do you agree with this clarification of the inventory for geological disposal – and how this will be communicated with the volunteer host community? If not, what alternative approach would you propose and why?
DECC appears to be ignoring the government’s Committee on Radioactive Waste Management (CoRWM) recommendations by including waste from a new build programme in the revised Baseline Inventory.
Why set up an advisory committee if you choose to ignore inconvenient conclusions?
7.Do you endorse the proposed approach to community benefits associated with a GDF. If not what alternative approach would you propose and why?
It would be totally wrong to suggest to a community that its economic future and well-being depended on an agreement to host a GDF.
Community benefits could be paid from the ‘focusing phase’. A volunteer community could come forward at that stage and benefits could be paid to that community. If the geology were then found to be unsuitable government retrieval of these benefits would be hugely disadvantageous to both the community and the representative authority.
8.Do you agree with the proposed approach to addressing potential socio-economic and environmental effects that might come from hosting a GDF? If not, what alternative approach would you propose and why?
It is important to prevent a community feeling that it is under pressure to accept a GDF to bring it out of economic hardship. Any socio-economic information presented to a community should be factual, unbiased and delivered by an independent body.
There should be clear separation of the environmental issues from the economic issues. With regard to environmental issues, it would appear to be illogical and entirely counter-productive to attempt to put a GDF where it could adversely affect any nationally and internationally protected areas (National Parks, Areas of Outstanding Natural Beauty, World Heritage Sites, Special Areas of Conservation, Ramsar Sites, Special Protection Areas).