The Partnership considered a range of issues that would be involved in West Cumbria taking part in the Government’s search for somewhere to locate a repository.
It looked at reports and literature, heard from experts in the field, commissioned independent research and invited reviews by independent experts over a period of about three years. It also placed a high priority on public and stakeholder engagement (PSE), carrying out three rounds of engagement in order to inform people, seek their input, and give feedback on how this had changed its work.
An overview of the Partnership's key opinions and advice is outlined below, and is abbreviated in some places. It is important to read the full Final Report to see all of the opinions and advice that the Partnership agreed, and to get a clear picture of the work that lies behind them.
The Councils were originally due to make their decisions about whether or not to participate in the next stage of the process in October 2012. They decided to take extra time to seek clarification from the Department of Energy and Climate Change (DECC) on a number of issues, including the right of withdrawal, community benefits and geology. They also used this extra time to clarify other issues such as ensuring that there would be adequate funding from the Government for community representatives to independently scrutinise the studies and investigations that would be carried out, and to ensure that the Cumbria brand would be protected.
The Councils considered the responses from the Government alongside the Partnership's Final Report, the results of the consultation carried out by the Partnership and the opinion survey conducted by Ipsos MORI, and on 30th January 2013 they made their formal decisions on whether the Allerdale and/or Copeland areas should take part in the search for somewhere to put a repository.
The decisions that were taken are as follows:
For further information on the specific decisions please see the following links:
The types and amounts of radioactive wastes for disposal – the inventory – could affect a GDF in a number of ways including the design, the size of the underground footprint, the period of operation, the developing safety case and, potentially, the number of required repositories.
Overall, the Partnership is unable to say at this stage that it is satisfied with the proposed inventory because it does not yet have definite information on what actually would go into a GDF (GDF operation is over 25 years away).
However, it has developed a set of Inventory Principles in order to ask for commitments from the Government about how inventory issues will be handled if a decision to enter the siting process is taken. Progress has been made towards agreeing the principles that define an acceptable process for how the inventory could be changed, including how the community can influence this.
If there is a decision to take part in the first stage of the search for a suitable location for a GDF (Stage 4), the Partnership advises that a community siting partnership enters into negotiation with the Government to develop a mutually acceptable process for how the inventory would be changed, including the circumstances under which the decision-making bodies should have a veto on changes to the inventory even after the right of withdrawal has ceased.
(See Chapter 7 of the Partnership's Final Report for more detail.)
Finding a suitable rock formation that can act as an effective barrier is essential for the construction of a safe disposal facility.
As a first step, the Government said that any area expressing an interest in this process should have a test carried out by the British Geological Survey (BGS). This was designed to rule out certain areas as being clearly unsuitable, and thereby enable a judgement about whether the remaining area is enough to continue investigations for a potential site. This test was done in West Cumbria and ruled out about 25% of the land area, leaving 1890km2 for possible investigation. The Partnership commissioned two peer reviews of this study, which both said it could rely on the results.
The Partnership believes that the 1,890km² of land not ruled out as clearly unsuitable by the BGS provides a sufficient amount of land, in terms of area, available for investigation.
The Partnership also looked at the suitability of the geology of the remaining area. It has received expert geological submissions arguing that West Cumbria’s geology is unsuitable and further progress is not worthwhile, but it has also received contrary expert advice stating that further progress is worthwhile because not enough is yet known to be able to say that all of West Cumbria should be ruled out.
The Partnership agrees that it is inherently uncertain at this stage whether a suitable site can be found, that more geological work is therefore required, and that it should be done as soon as possible. However, there is a difference of view in the Partnership about whether this further geological work should be done before or after a decision about participation in Stage 4.
The Partnership agrees that, if there is a decision to proceed to Stage 4, a community siting partnership should independently review the NDA’s work, in particular the geological assessments.
(See Chapter 8 of the Final Report for more detail.)
Knowing how a GDF might be designed and engineered is important because: it helps people to visualise what it might look like and appreciate the scale of the project; it can affect, or be affected by, what goes into it and where it is located; and the design affects the safety of the facility.
The Partnership's opinion is that, overall, it is content that detailed design issues are largely site-specific and, as such, cannot and should not be resolved at this time. Specifically, it understands the generic design concepts being worked on, and they fit with its expectations.
The Partnership looked at ‘retrievability’, which means the possibility of withdrawing the waste after it has been put into a GDF. It has confirmed that retrievability of waste is an option, to be decided on in the future.
(See Chapter 9 of the Final Report for more detail.)
Making sure that any GDF would be as safe, secure and environmentally sound as possible is of the highest importance.
Regulatory and planning processes
The Partnership is as confident as is possible at this stage that the necessary regulatory bodies exist and have, or are developing/modifying, processes by which they will consider proposals for a GDF.
If there is a decision to move to the next stage, it advises that areas within the National Park are not considered for surface facilities because of the likely impact this would have on the special qualities of the Park, which would not be consistent with current planning policies.
The Partnership believes that the NDA will have suitable capability and an acceptable process in place to develop site-specific safety cases. Of course, any site-specific safety cases would need further monitoring and independent reviews.
The Partnership's opinion is that, overall, the NDA’s research & development programme is acceptable. However, it notes that there remain some concerns about the lack of progress with the programme, as well as the lack of clarity over the timescales for completing individual research topics.
Our additional advice includes a suggestion that a community siting partnership secures an ‘Engagement Package’ (funding) from the Government that allows it to commission independent reviews of any work conducted by the NDA, including safety-related work, potentially via setting up a panel of independent experts.
(See Chapter 10 of the Final Report for more detail.)
If a GDF was to be sited in West Cumbria it could lead to a number of different negative and positive impacts for the community, the economy and the environment. These might include:
• The immediate effects of construction such as noise and dust.
• Whether there would be any impact on health.
• Changes in investment in the area.
• Traffic impacts.
• Possible effects on the visual or physical environment and on tourism.
• Changes in employment.
These impacts, both positive and negative, would ultimately need weighing up against the impacts of the waste remaining in its current form, and of the above-ground storage arrangements at Sellafield and elsewhere in the country.
The Partnership's overall opinion is that, at this stage, it is fairly confident that an acceptable process can be put in place to assess and mitigate negative impacts, and maximise positive impacts.
There are potential risks to some parts of the economy if the process moves forward, particularly the visitor, land-based, and food and drink sectors. The Partnership advises that a coordinated strategy and action plan is prepared to support those aspects of Cumbria's economic activity if the process enters the search for a site.
Its opinion is that the development of a GDF appears broadly compatible with the economic aspirations of West Cumbria. It advises that a full economic impact assessment is conducted if the process proceeds any further, as potential site areas are identified.
(See Chapter 11 of the Final Report for more detail.)
The Government has said that any area in which a GDF is sited would receive some kind of community benefits package. The Partnership would expect it to be a substantial long-term investment provided by the Government in things like infrastructure, services and/or skills that benefit the whole community.
The Government has agreed that this means that benefits would be beyond those that derive directly from the construction and operation of the facility, and would be in addition to those that the community would normally expect.
The Partnership has developed a set of Community Benefits Principles that set out how it would expect community benefits to be discussed, agreed and potentially administered. The Government has agreed to the Partnership's principles as the basis for negotiation in the next stage of the process.
This gives the Partnership a certain amount of confidence that an acceptable community benefits package could be negotiated. It advises that a community siting partnership uses these principles as the basis for negotiations with the Government, if Stage 4 starts.
However, it cannot be certain what specific package the Government might agree to this far in advance and, therefore, whether the amount and type of these benefits would match the expectations of local people.
We believe a final decision to accept a GDF should only be made if the community is convinced that the Government – and future governments that follow – will honour commitments on community benefits.
(See Chapter 12 of the Final Report for more detail.)
The Partnership wanted to be confident that a good process can be put in place if the next steps are taken.
In Chapter 13 of its Final Report the Partnership set out its views on the way in which voluntarism should work during a siting process.
The Partnership believes the emphasis on a strong commitment to voluntarism and community ‘willingness to participate’ is one that parties should keep at the forefront of their minds if this process continues. At each stage, any future community siting partnership should seek to maximise consensus amongst the decision-making bodies, potential host communities and wider local interests.
The Partnership's opinion is that its work in Chapter 13 provides some confidence that the siting process can be sufficiently robust and flexible, at least during Stage 4. It is reassured by the Councils’ ability to withdraw West Cumbria from discussions with the Government. However, it recognises that the very first challenge in a possible Stage 4 will be to agree how a community siting partnership should operate and what partnership agreement should exist between members.
The Partnership advises that any community siting partnership should be established and operated in line with all of the guidance set out in Chapter 13.
(See Chapter 13 of the Final Report for more detail.)
There are a number of issues that have either run across all of the Partnership's work, or provide an important context for the decision about whether or not to participate in the first stage of the search for a suitable location for a GDF. These include:
A great many uncertainties remain, primarily because they relate to issues that can only be considered in detail at a later date. Should a decision to participate be taken, the Partnership would advise that a community siting partnership uses the indicative schedule provided in the ‘Stage 4 and 5’ chapter (Chapter 13 in our Final Report) to build its work programme and, in doing so, help reduce the range of uncertainties that exist.
A lack of trust appears to the Partnership to be at the root of many of the key concerns raised by the public and stakeholders. It has provided advice on this throughout the Final Report.
In particular, it advises that prior to a decision about participation, the decision-making bodies secure a commitment that, by the end of Stage 4, the Government will have decided what mechanisms it will use to make key parts of the MRWS process (including the right of withdrawal) legally binding. The Partnership has received this commitment from the Minister of Energy, and advises that any community siting partnership should tackle this early in its work programme.
It also advises that a community siting partnership should continue the Partnership’s approach to transparency and extensive public and stakeholder engagement, operating by consensus where practical, and seeking agreements from others where useful e.g. regarding legislation.
Strategic Environmental Assessments
The Partnership considered whether the Government’s MRWS policy is consistent with European legislation on Strategic Environmental Assessments (SEAs). This legislation includes looking at 'reasonable alternatives' such as alternative sites, alternative disposal methods and alternatives to the current process of voluntarism.
Some members believe that the aspect of a SEAs that assesses reasonable alternatives should take place before a decision about participation. Other members believe that the NDA’s plans for carrying out an SEA after a potential decision to participate are appropriate.
(See Chapter 6 of the Final Report for more detail.)
Engaging the public and stakeholders has been a priority for the Partnership (see Chapters 5 and 14 of the Final Report for more detail). The Partnership wanted to understand how partner organisations, stakeholders, and interested members of the public, as well as the silent majority of the general public, felt about this issue.
As well as three extensive rounds of engagement, it conducted a statistically significant opinion survey to gauge people’s views. The results show that across Cumbria more people are in favour of taking part in the search for a suitable site than those that oppose taking part. However, this must be considered alongside other parts of the Partnership's engagement.
Other aspects of its engagement aimed to understand concerns so they could be addressed, to ensure its opinions and advice are credible. The Partnership has done a considerable amount of work to respond directly to consultation submissions. Overall, most Partnership members are satisfied that the opinions and advice given in the Final Report reflect the public and stakeholder views it has received. However, some members feel this is not the case on some topics and this has been noted in the relevant Chapters 8 and 13 in the Final Report. Specific significant changes have been made as a result of public input, for example requiring a firm legal footing to the process, and advising that an outline community benefits package should be developed and agreed with the Government before any site investigations start.
The Partnership thanks everybody for their time in submitting their views and contributing to its work.'
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