There was a lot to unpack from the Government’s surprise announcement on the eve of Christmas, and try to understand what that might mean for the GDF siting process in 2019, and beyond.
Announced by way of a Written Ministerial Statement, the Government published:
RWM’s supplementary announcements
In addition to the Government’s announcement, RWM also published a suite of information as the first steps in the re-opening of the siting process:
Working With Communities policy
Following public consultation, there have been subtle changes to the policy which clarify the role of local authorities, and also ease entry into or withdrawal from the siting process. The Government appears to have listened to consultation comments, which were more focused on improving practical implementation of the policy.
Local authorities now have more formal roles in the Community Partnership. For example, they would lead the decision on community withdrawal from the siting process, or of moving to the Test of Public Support (ToPS) stage. These changes reflect the reality of local authorities having wider statutory obligations and functions, but remove the risk that one local authority could stop community interests even discussing participation in the siting process. Also, one local authority cannot now over-rule another (avoiding a “Cumbria 2” scenario).
The Government also seems to have understood that more flexibility in timing and availability of engagement funding is required to support community-level interests from the very earliest stages. The policy has done away with the “formative engagement” phase. The policy now envisages initial ‘Working Groups’, which do not require local authority participation or approval.
There is also now an explicit commitment to providing separate funding to local authorities, to cover any costs associated with participating in the GDF siting process — so that local taxpayers are not be required to bear any financial burden. With the parlous state of local government finances, and the politically contentious and speculative nature of entering the GDF process, this is an important concession by the Government, to reduce real or perceived barriers to participation.
The GDF siting policy, and RWM’s subsequent Community Guidance, sets out an ambitious list of activities for the Community Partnership around citizen engagement and participation, and promises to fund these and other relevant activities. Fulfilling these commitments will be vital if the siting process is to succeed. However, no mention is made of budgets. This is going to be an inevitable area of contention. Communities’ wishlists are likely to exceed HM Treasury’s willingness to pay. But in a consent-based process, the balance of negotiating power does shift away from those who are soliciting the goodwill and participation of a potential partner. Some interesting discussions ahead!
On balance, the new GDF siting policy has gone as far as might reasonably be expected in developing a flexible framework that might help start and sustain discussions. The difficulty lies in implementation.
The Year Ahead
So how will all of this roll-out in the coming year, and what can we expect during 2019?
In making the announcement before Christmas, the Government have gone some way to protecting the geological disposal programme from any political inertia or fall-out from Brexit.
The consent-based process is unique and untested, and critics are sceptical that Government will actually adhere to its principles. People are used to a “DAD” (Decide, Act, Defend) process for the siting of major infrastructure projects — a process which has tended to make local people feel marginalised and that key decisions affecting where they live are actually taken elsewhere. Significant effort and discussion will be required during 2019 to explain and explore with the wider community sector how the principles of the consent-based process can be implemented in a way that builds public confidence in the fairness of the GDF siting process and the effectiveness of community involvement in decision-making.
Nobody underestimates the challenge ahead. It should be an interesting 2019!
Communities or organisations seeking their own independent informed advice on the GDF siting process can contact GDFWatch for guidance on how and where to find it. Email us at firstname.lastname@example.org