Consent & planning | Save Our Lake District

A new approach to planning….

“If a problem is too difficult to solve, one cannot claim that it is solved by pointing to all the efforts made to solve it”

Hannes Alfven, Energy and Environment, Bulletin of the Atomic Scientists May 1972

opening quote to the Royal Commission on Environmental Pollution, Sixth Report, Nuclear Power and the Environment (September 1976)

The government has dreamed up a new approach to dealing with nuclear waste that turns planning on its head

It ought to:

1. do the necessary research on geology, engineering, safety, etc.

2. use the results to find a suitable region place for a dump

3. explore fully and openly, with independent expert review from the technical and social sciences, the implications for the local communities of the immediate and long term future of such a proposal

Instead, it has:

1. slowed down research after the Nirex proposals were rejected in 1997

see ‘history’ on this site

2. decided that nuclear power would be an easy way to cut down on carbon emissions – but realised this would require addressing the waste problem, the long-neglected aspect of nuclear power.

3. issued the Managing Radioactive Waste Safely (MRWS) White Paper in June 2008. This plan has been confused with being a solution that is technically and socially acceptable. It is why the current consultation, with its potential to progress waste disposals plans, is so important right now.

4. asked for Councils to ‘express an interest’ in ‘hosting’ a dump, holding out a ‘community benefits package’ as a bribe

5. got 3 hands up from Copeland, Allerdale and Cumbria (the over-arching County Council)

6. funded the West Cumbria MRWS Partnership with around £1million a year to take the process forward

7. given the Nuclear Decommissioning Authority – whose job it is to deal with nuclear waste! – a leading role in the process

8. approved the use of Pubic Relations experts from the very beginning

9. put off consideration of site selection, engineering and technical issues until AFTER a fuller expression of interest – the ‘decision to participate’ in siting is made!

The Government is not looking for the best and most geologically safe site for radioactive waste.

Instead it is looking for a site which a local community can be persuaded to accept and hopes that it can find an area of rock formation within a willing community/region where the waste can be dumped.

For a summary of the international guidelines on technical and scientific aspects of siting, go to the International page on this site.

Here is a statement from Swarthmoor South-west Cumbria Quaker Meeting

The disposal of High Level Nuclear Waste: Cumbrian Firsts Swarthmoor SW Cumbria Area Quaker Meeting

Who will make decisions ?

It is up to each of the 3 Councils, to decide whether or not to volunteer their local area (called ‘a decision to participate’) – and so to take things forward to find a site.

Initially, the MRWS Partnership’s role was put forward as one which, collectively, would make recommendations to the 3 Local Authorities. But it has not been able to agree and finalise the Terms of Reference, primarily because the concept of ‘voluntarism’ has not been allowed to apply to local Parish and Town Councils.

It has been agreed that the role of the Partnership will now be just to offer its ‘views’ to the Local Authorities, through a report on a Consultation – held between November 2011 and March 2012 – which will be presented to the Councils.

The Partnership will have to take its members’ views into account, including the Lake District National Park Authority (LDNPA) and the Cumbria Association of Local Councils (CALC) which represents the Parish and Town Councils.

Regardless of the official and complicated consultation, there is no reason why individuals or organisations cannot contact any of the 3 Councils and the LDNPA (or any other of the Partnership members) to make their views known, or to offer advice.

This applies to anyone in Copeland, Allerdale, across Cumbria and beyond. In fact, because it is acknowledged that the Lake District is a National Park, its constituency lies across the whole country. And as a Park applying for World Heritage status we would say that this broadens the responsibility of those who look after it to listen to the views of anyone who loves to visit the Lakes – whether they are from Gosforth or Berlin!

The Right of Withdrawal

One major area of ambiguity concerns the right of a community to decide not to accept a dump. This ‘Right of Withdrawal’ (RoW) for ‘communities’ has been loudly trumpeted but it is a deception.

“Community” doesn’t mean the village or parish that would be involved. It means the local authorities, called the ‘Decision Making Bodies’ (DMBs) –Cumbria, Copeland, Allerdale.

All these Councils are made up of representatives from across very wide areas, many of whom might feel they would not be significantly affected by a dump. There is a particular concern that some might approve going forward with the plans because of the massive taxpayer funded “community benefits package” the Government is offering. This may only begin to be delivered when full agreement is reached.

The decision to make further progress could be made before the negative impacts are fully understood. The MRWS Partnership are doing some work on this (focused on the ‘Cumbria brand’), but it is not completed, and is very limited in scope.

Important questions are being pushed aside and the public is being sucked into giving the nod to a continuing bureaucratic process that is well-understood only by bureaucrats.

And if plans get advanced enough to start drilling boreholes, the White Paper says

‘All parties in a Community Siting Partnership should work positively to seek to avoid the need to exercise the RoW. This will be particularly important following a surface-based investigation programme, when considerable investment will already have been made’ (para 6.39 page 56)

So, the further its gets into the process and the more money has been spent on it, the greater the pressure will be to continue.

If a community within a specific area wished to opt out, it could still be included in the dump proposals - if the decison makers gave ‘justification’ for doing so. This is stated in the second paragraph of (e), page 93 of the consultation document.

This means there are significant risks of communities being steamrollered, by financial concerns, or forced, through the ‘justification’ of others, to be involved in the dump.

How will the MRWS Partnership interpret the results from its Consultation?

The Partnership is not going to require the approval of a majority to move forward to the next stage.

An idea called ‘net support’ from a wider community will do (apparently), meaning that the number of people bothering to say ‘yes!’ only needs to outweigh the number who say ‘no!’ – discounting the number who either say nothing, or say ‘I don’t know!’ – which probably for most people is the only reasonable response, considering the number of documents you’d have to read to feel remotely well-informed, and the general interest-sapping nature of them all….

So the breadth and depth of public opinion is not important just now. Along with other important matters this will ‘come later’. A bureaucratic process is invoked in order to justify ignoring any misgivings people may have about the notion of the dump.

Here is what the Partnership says it wants to get, in order to conclude it’s worth moving to the stage of ‘a decision to participate’ – i.e. volunteering to go to the siting process

‘Broad support: A range of organisations and people interested or involved in the Partnership’s work consider the initial opinions in this document to be reasonable in the light of the available evidence.

Understanding and addressing concerns: The Partnership can demonstrate that it has understood and taken into account concerns and reasons for opposition, and does not consider any arguments or evidence put forward in PSE3 to be ‘showstoppers’. (PSE means the 3^rd round of the ‘Public and Stakeholder Engagement’ programme).

Net support: Of the people surveyed in Copeland and/or Allerdale, more are in favour of entering the siting process than are against.

There is no indicator more important than the others, and they will not be weighted against each other; they are all equally important.’ (P 108 Consultation Document)

This is designed to sideline valid concerns from people who don’t say ‘no’ outright.

It will also rely on the Partnership’s understanding of which arguments are ‘showstoppers’. But despite many such arguments having been put to them already, they are dismissed as cases of:

‘leave it until later’ – in the case of the 100+ issues raised by the Nuclear Waste Advisory Associates - see www.nuclearwasteadvisory.co.uk

‘that’s just one view among many’ – in the case of the argument that no suitable geographical, geological and hydrogeological attributes of West Cumbria meet internationally recognised criteria

It also leaves the process open to a decision being made primarily on the views of those within Copeland and Allerdale, even though this is a matter which will affect people across the whole county and beyond.

The decision to progress a national nuclear dump needs to be based on more than this!

Responses to the MRWS consultation 2011 – 2012

Prof David Smythe’s response – expert geology

www.davidsmythe.org/nuclear/Smythe%20consultation%20response%20march%202012.pdf.

Nuclear Free Local Authorities response – argues against the necessity for deep disposal

NFLA RWB_32_West_Cumbria_MRWS_consultation

Prof Stuart Haszeldine’s response – expert geology

Response to westCumbria MRWS Consultation Haszeldine small

W Cumbria & N Lakes FoE response – critique of the process

WC & NL FoE response to MRWS cons Mar 2012

WC & NL FoE MRWS resp Appendix note

Jean McSorley’s reponse – critique of the process