Latest News

UPDATE: Analysis of Responses to RWM Consultation

i Apr 14th No Comments by

Weighting of evaluation criteria to allow more effective comparison between potential sites, and taking account of wider statutory obligations, are amongst the common key themes from a wide range of stakeholders’ responses to RWM’s Site Evaluation public consultation.

Now closed, it is thought that the two parallel public consultations in England and in Wales have attracted about 90-100 responses.  Some of those responses are published below, with permission of their authors.  If you would like to add your response submission to our list, please contact us at editorial@gdfwatch.org.uk

Context

It is important to place a ‘health warning’ on the following analysis of responses to the consultation, because:

  • the published responses are not necessarily representative of the total range of responses and opinion submitted to RWM;
  • there are a diversity of opinions and specific issues raised in the published responses — this analysis is not a summary of all opinion, but focuses on key common themes from across the stakeholder spectrum;
  • a final/definitive analysis is only possible once RWM publish all the responses received, when they formally respond to the consultation later in the summer.

Key issues raised

Although we have only read about 10-15% of responses submitted, there are certain key issues or themes which appear across the stakeholder spectrum, from industry and local authorities to environmentalists and local activist groups.  They also reflect issues raised at each of the regional stakeholder workshops which GDFWatch attended.   These include:

  • general awareness of the difficulty of using quantitative comparators, but a widespread sentiment that RWM need to find some way of ranking/weighting criteria so that a robust comparison can be made effectively between different sites under evaluation, especially when they might be at different stages of development;
  • the need for RWM to take account of wider statutory obligations, on themselves and other third parties, eg the legal obligations placed on all public bodies under the Environment Act 1995 and the Countryside and Rights of Way (CROW) Act 2000;
  • the omission of any reference to the Future Generations Act (FGA) in the Welsh consultation document and the consequent statutory obligations placed upon RWM when operating in Wales;
  • “community” site evaluation criteria should not just be ‘socioeconomic’, but look at wider social and environmental impacts, including governance of the siting process and how RWM will actually collaborate and work with communities;
  • geology should be a more prominent criteria, particularly hydrogeology, amid ongoing public concern about contamination of underground water sources;
  • the need to keep site evaluation criteria under review, for example by ensuring the criteria are aligned with the National Policy Statement (in England) and Technical Advisory Note (in Wales) when these are eventually published, and to consult again if necessary;
  • whether ethics and intergenerational equity/justice should be included amongst the site evaluation criteria;
  • “security”, on site and during transport of waste, is also frequently raised as a criteria which should be given more prominence.

General concerns

In addition to these specific key issues, the responses also express more general concerns, primarily about ‘public trust’ — in the GDF siting and evaluation processes, and in RWM itself.  These general expressions of concern include:

  • if communities are going to have any confidence, they must have trust in the siting process — establishing such trust cannot be reduced to or built upon a simplistic community role in ‘oversight and scrutiny’;
  • that geology will not be a key factor, and that a “less safe” GDF might be built in unsuitable geology (relying on engineered barriers) simply because the host community is willing;
  • the evaluation criteria are ‘mechanistic’, and do not reflect or adequately account for the overall acceptability of the project to a local community;
  • need for better guidance for communities on how the criteria will be assessed inter alia, and the provision of an ‘indicative’ or ‘example’ analysis that helps communities more easily understand how the comparative evaluations will be conducted and presented;
  • how overlaps between criteria will be accounted for when assessing sites.

From a narrow administrative perspective it is perhaps true that many of the comments made do not directly address the consultation questions.  However, the wider concerns expressed underline continuing anxiety about how the unique, new and untested complex siting process will be implemented.  Before asking the public about technical site evaluation criteria, there is a body of work to be conducted to explain and build confidence in the siting process.  There is widespread cynicism that communities will have the final say, or can walk away at any time without obligation.  Previous negative community experiences of the planning process for major infrastructure projects, and general exasperation with our political and democratic decision-making processes, mean that RWM will probably have to address these fundamental concerns before any community is ready to discuss technical details, like site evaluation criteria.

Responses published

Many organisations only responded to the England consultation, but those that have submitted a response to the Wales consultation have generally made both responses available on their website (and are easily visible when you click on the hyperlink below.

Allerdale Borough Council

Barlow Geosafety

Campaign for National Parks

Cumbria Trust

Dr David Lowry — member of Nuclear Waste Advisory Associates (NWAA) & Nuclear Transparency Watch

Friends of the Earth — West Cumbria & North Lakes branch

Friends of the Lake District

Nuclear Free Local Authorities (NFLA)

Nuclear Industry Association (NIA)

Nuclear Legacy Advisory Forum (NuLeAF) — special interest body of the Local Government Association (LGA)

Prospect — the Trades Union

To see GDFWatch’s responses to the two consultations, please scroll down.

___________

A Public consultation related to the search for a suitable site for a Geological Disposal Facility (GDF) in England

Response Form

Question 1:
Are there any other sources of high level Requirements other than Siting Process, National Policy Statement and Legal Requirements identified that you think should be reflected in the Site Evaluation and why? 
See Q4 below
Question 2:
Do you agree with the Siting Factors we have identified? Are there any other Siting Factors that should be included and why?
See Q4 below
Question 3:
Do you agree with the Evaluation Considerations we have identified? Are there any other Evaluation Considerations that should be included and why?
See Q4 below
Question 4:
Is there anything else that you think we should consider in our site evaluations and why?
We have never been entirely sure why this formal public consultation is being held.  Judging by discussions with other attendees at the regional workshops, this is a widely held view.  There is nothing ‘new’ in the consultation document.  It simply contextualises existing requirements, which cannot be changed.

 

 

However, if it’s an early indication of a more inclusive approach by RWM to taking wider civil society opinion with it, then it is to be welcomed.  And by bringing together all the existing legal, regulatory, environmental, planning and other requirements RWM is obliged to fulfil during the GDF siting process, the document also reads more like a ‘roadmap’ for communities.  It helps:

  • begin to explain broad timelines and how the different siting, planning and regulatory processes interweave with each other, and
  • provides the bare bones of a potential work programme for engaged communities, by focusing on six broad factors — Safety, Community, Environment, Engineering feasibility, Transport, and Cost.

At this stage, the six headline siting factors appear sufficiently broad and flexible to encompass a wide range of more detailed and location-specific issues. But in providing a basis which helps give shape and structure to community discussions, the evaluation consideration criteria will need to be continually updated.  The 31 March public consultation deadline therefore seems a little arbitrary, since these issues will continue to evolve, not least to include issues of particular relevance to a specific community.  We hope that, where possible, RWM will continue to keep these issues open as the siting process progresses, rather than a draw a line when this public consultation ends.

We do have some specific additional observations:

Meaningful consultation

Those attending the workshops appeared to represent stakeholder sector and organisations that are already well-versed and engaged in the GDF programme.  While their expertise and knowledge is undoubtedly of value to RWM in helping refine the site evaluation criteria, RWM cannot reasonably claim that they have satisfactorily reached out to and engaged with those whose consent is required to initiate and sustain a local discussion – ie, community and civil society organisations.

If the site evaluation criteria are to have any credibility or usefulness, they need to be understood and accepted at least by those representing the community and civil society sector.  To press ahead with only the input of ‘technical’ stakeholders creates risks for RWM in terms of securing broader public acceptance to the site evaluation criteria.

This concern was aired at the start of the consultation process, and has sadly been realised:

“A more basic concern is that civil society and community organisations will not have the capacity to make meaningful responses to the consultation by the end of March… experience from regional workshops for the National Geological Screening, National Policy Statement and Working With Communities consultations suggest that it is the same organisations which tend to attend these events.  While useful for those attending, the workshops are not always the most effective means of reaching out beyond historical core-engaged stakeholders.” [GDFWatch, 15/01/19]

The post-consultation revised site evaluation criteria should be subjected to further socialisation with and feedback from those representing the wider and community and civil society sectors.

Measurability/Objective Comparative Analysis

RWM state that a key purpose of the evaluation criteria is to support comparative assessment of different sites.  But there is little in the document to indicate how ‘objective’ comparative assessments are to be made.  There are clearly difficulties and constraints in relying purely on quantitative assessment methodologies, but there seems too little emphasis in the current proposals on how the different criteria might be objectively compared or weighted across different sites under investigation.  Nor does the consultation address the issue of comparing sites which are at different stages of investigation.

Being able to compare sites in a transparent and understandable way will be essential to the wider task of building communities’ confidence in the fairness and legitimacy of the siting process.  More importantly, RWM will need robust objective indicators in order to defend and justify their actions, to Parliament and the National Audit Office, to the Courts in the event of a Judicial Review, as well as to the affected communities.

There seems to be a widely-held view that RWM will almost certainly be challenged in Court at some point in the next 30 years, most likely by a community which RWM decides should no longer remain within the siting process.  The basis on which any such decision is made by RWM therefore needs to be built on a robust comparative evaluation.

The complexity of the project, the varied characteristics of each community, and availability of common data sources across all participating communities, make defining specific quantifiable comparative data a difficult task.  However, there are examples and precedents (eg environmental assessments) in which robust comparative analyses can be made and which can withstand public, regulatory and legal scrutiny.  While recognising the difficulty for RWM in defining and developing methodologies for objective comparative assessment, this is an issue on which further work is clearly required.

Local Authority/Statutory Obligations

Local Authorities have been allotted a specific role within the siting process and Community Partnership framework.  This reflects their responsibility to deliver statutory obligations, and the potential impact (positive or negative) of a GDF and related investments on their capacity and capability to meet those obligations.  The consultation document lists at length the legal and regulatory obligations RWM will need to meet, but is mute on how the siting process may need to be observant of the impact of RWM’s activities on the statutory obligations of affected local authorities (or any other third parties).

In different circumstances and scenarios, the effect of a GDF could drive efficiencies, or drive costs up, in the delivery of public and social services by the local authority.  This is both a ‘community’ and a ‘cost’ issue, of great significance to local taxpayers and public service users.

The key point here, is that the site evaluation criteria currently focus on RWM’s legal and regulatory obligations, and we believe further thought should be given to including an assessment of the impact of RWM’s activities on the statutory obligations of other parties within the affected communities.

National Policy Statement (NPS)

As we understand, the final NPS will, by necessity, be ‘generic’ – as there is no specific site to which a GDF NPS can currently be applied.  It will set out the key issues to be addressed and included within any site-specific planning application.  Such a flexible approach is required to be able to account for the potentially varied environmental impact and obligations in different parts of the country.  In our view, this underlines the need for the site evaluation criteria to be kept under review, and for the adoption by RWM in their site comparison analyses of similar measures to those used currently when assessing environmental impacts.

Language/Tone

RWM have clearly gone some way to making the text of the document much more accessible to lay and non-technical audiences.  But there are still improvements that can be made, and there is value in engaging the community/civil society sector to help continually improve the use of plain English (or Welsh).

The most obvious example of this is the ‘Cost’ evaluation criteria.  “Cost” is a laden term.  If the public believe that cost is a primary determinant, they will fear that the programme will be ‘cutting corners’ and not placing safety as a key determinant.

‘Value for money’ is a suggested alternative.  It is true that costs to the taxpayer will be one of the deciding issues.  However, it does not flow from that that the cheapest option will automatically be the preferred option.  There are other key influencing criteria to weigh alongside cost.  Given the scale of impact a GDF will have on a regional economy and infrastructure over a long period, it is not inconceivable that a Secretary of State in 30-50 years time evaluates two very similar potential sites, and chooses the site which maximises the impact of and return on the taxpayers investment. That may not be the lowest cost option, but one which realises optimal benefits for that region of the UK. 

Given that a key audience for these criteria are local communities, it is recommended that RWM conduct further analysis of the use of language with those who represent the community/civil society sector.  For example, would lay people refer to “Engineering Feasibility”, or would the more simple “Construction” be more meaningful and accessible to them?

Geology

During the workshops there were repeated comments that there was too little specific mention of ‘geology’.  We would agree with RWM that this issue should be woven through all the criteria, and not be a standalone criteria in its own right.  We welcome RWM’s commitment given at several workshops that they will be more explicit about the role of geology when revising the text of the document after the consultation.

A Public consultation related to the search for a suitable site for a Geological Disposal Facility (GDF) in Wales

Question 1:
Are there any other sources of high level Requirements other than Siting Process, National Policy Statement and Legal Requirements identified that you think should be reflected in the Site Evaluation and why?

The consultation document makes no mention of the Future Generations Act (FGA) despite this being a foundation piece of legislation which all public sector organisations must comply with when developing or implementing Welsh Government policy.

The FGA’s 7 well-being goals, and the Act’s requirements that public bodies in Wales think about the long-term impact of their decisions, to work better with people, communities and each other, all appear very relevant to site evaluation, and to wider geological disposal policy. Although RWM is not a ‘listed’ organisation under the Act, Welsh Ministers, local authorities and Natural Resources Wales are covered by legislation. Since, in Wales, RWM is in effect implementing Welsh (not UK) Government policy, we understand failure to incorporate the FGA goals could invalidate all or part of RWM’s approach to the siting process in Wales.

Not only is radioactive waste management policy a devolved issue, but land use planning, environmental permitting, and local authority, socioeconomic and communities policies are also devolved issues. The legal, regulatory, policy and institutional framework in Wales is no longer a replica of England. There is a distinctly different social, political and cultural environment in Wales. None of this is adequately reflected in the consultation document for Wales.

Although the FGA is not in operation in England, its sustainability principles, 7 well-being goals and approach to collaborative working provide a positive framework for the GDF siting process. Embracing the Act on a pan-UK basis might not only enhance implementation of the siting process, but would help provide a consistent basis for comparing Welsh and English communities.

Question 2:
Do you agree with the Siting Factors we have identified? Are there any other Siting Factors that should be included and why?

See Q4 below

Question 3:
Do you agree with the Evaluation Considerations we have identified? Are there any other Evaluation Considerations that should be included and why?

See Q4 below

Question 4:
Is there anything else that you think we should consider in our site evaluations and why?

We have never been entirely sure why this formal public consultation is being held. Judging by discussions with other attendees at the regional workshops, this is a widely held view. There is nothing ‘new’ in the consultation document. It simply contextualises existing requirements, which cannot be changed.

However, if it’s an early indication of a more inclusive approach by RWM to taking wider civil society opinion with it, then it is to be welcomed. And by bringing together all the existing legal, regulatory, environmental, planning and other requirements RWM is obliged to fulfil during the GDF siting process, the document also reads more like a ‘roadmap’ for communities. It helps:

• begin to explain broad timelines and how the different siting, planning and regulatory processes interweave with each other, and
• provides the bare bones of a potential work programme for engaged communities, by focusing on six broad factors — Safety, Community, Environment, Engineering feasibility, Transport, and Cost.

At this stage, the six headline siting factors appear sufficiently broad and flexible to encompass a wide range of more detailed and location-specific issues. But in providing a basis which helps give shape and structure to community discussions, the evaluation consideration criteria will need to be continually updated. The 31 March public consultation deadline therefore seems a little arbitrary, since these issues will continue to evolve, not least to include issues of particular relevance to a specific community. We hope that, where possible, RWM will continue to keep these issues open as the siting process progresses, rather than a draw a line when this public consultation ends.

We do have some specific additional observations:

Meaningful consultation

Those attending the workshops appeared to represent stakeholder sector and organisations that are already well-versed and engaged in the GDF programme. While their expertise and knowledge is undoubtedly of value to RWM in helping refine the site evaluation criteria, RWM cannot reasonably claim that they have satisfactorily reached out to and engaged with those whose consent is required to initiate and sustain a local discussion – ie, community and civil society organisations.

If the site evaluation criteria are to have any credibility or usefulness, they need to be understood and accepted at least by those representing the community and civil society sector. To press ahead with only the input of ‘technical’ stakeholders creates risks for RWM in terms of securing broader public acceptance to the site evaluation criteria.

This concern was aired at the start of the consultation process, and has sadly been realised:

“A more basic concern is that civil society and community organisations will not have the capacity to make meaningful responses to the consultation by the end of March… experience from regional workshops for the National Geological Screening, National Policy Statement and Working With Communities consultations suggest that it is the same organisations which tend to attend these events. While useful for those attending, the workshops are not always the most effective means of reaching out beyond historical core-engaged stakeholders.” [GDFWatch, 15/01/19]

The post-consultation revised site evaluation criteria should be subjected to further socialisation with and feedback from those representing the wider and community and civil society sectors.

Measurability/Objective Comparative Analysis

RWM state that a key purpose of the evaluation criteria is to support comparative assessment of different sites. But there is little in the document to indicate how ‘objective’ comparative assessments are to be made. There are clearly difficulties and constraints in relying purely on quantitative assessment methodologies, but there seems too little emphasis in the current proposals on how the different criteria might be objectively compared or weighted across different sites under investigation. Nor does the consultation address the issue of comparing sites which are at different stages of investigation.

Being able to compare sites in a transparent and understandable way will be essential to the wider task of building communities’ confidence in the fairness and legitimacy of the siting process. More importantly, RWM will need robust objective indicators in order to defend and justify their actions, to Parliament and the National Audit Office, to the Courts in the event of a Judicial Review, as well as to the affected communities.

There seems to be a widely-held view that RWM will almost certainly be challenged in Court at some point in the next 30 years, most likely by a community which RWM decides should no longer remain within the siting process. The basis on which any such decision is made by RWM therefore needs to be built on a robust comparative evaluation.

The complexity of the project, the varied characteristics of each community, and availability of common data sources across all participating communities, make defining specific quantifiable comparative data a difficult task. However, there are examples and precedents (eg environmental assessments) in which robust comparative analyses can be made and which can withstand public, regulatory and legal scrutiny. While recognising the difficulty for RWM in defining and developing methodologies for objective comparative assessment, this is an issue on which further work is clearly required.

Local Authority/Statutory Obligations

Local Authorities have been allotted a specific role within the siting process and Community Partnership framework. This reflects their responsibility to deliver statutory obligations, and the potential impact (positive or negative) of a GDF and related investments on their capacity and capability to meet those obligations. The consultation document lists at length the legal and regulatory obligations RWM will need to meet, but is mute on how the siting process may need to be observant of the impact of RWM’s activities on the statutory obligations of affected local authorities (or any other third parties).

In different circumstances and scenarios, the effect of a GDF could drive efficiencies, or drive costs up, in the delivery of public and social services by the local authority. This is both a ‘community’ and a ‘cost’ issue, of great significance to local taxpayers and public service users.

The key point here, is that the site evaluation criteria currently focus on RWM’s legal and regulatory obligations, and we believe further thought should be given to including an assessment of the impact of RWM’s activities on the statutory obligations of other parties within the affected communities.

National Policy Statement (NPS)

As we understand, the final NPS will, by necessity, be ‘generic’ – as there is no specific site to which a GDF NPS can currently be applied. It will set out the key issues to be addressed and included within any site-specific planning application. Such a flexible approach is required to be able to account for the potentially varied environmental impact and obligations in different parts of the country. In our view, this underlines the need for the site evaluation criteria to be kept under review, and for the adoption by RWM in their site comparison analyses of similar measures to those used currently when assessing environmental impacts.

Language/Tone

RWM have clearly gone some way to making the text of the document much more accessible to lay and non-technical audiences. But there are still improvements that can be made, and there is value in engaging the community/civil society sector to help continually improve the use of plain English (or Welsh).

The most obvious example of this is the ‘Cost’ evaluation criteria. “Cost” is a laden term. If the public believe that cost is a primary determinant, they will fear that the programme will be ‘cutting corners’ and not placing safety as a key determinant.

‘Value for money’ is a suggested alternative. It is true that costs to the taxpayer will be one of the deciding issues. However, it does not flow from that that the cheapest option will automatically be the preferred option. There are other key influencing criteria to weigh alongside cost. Given the scale of impact a GDF will have on a regional economy and infrastructure over a long period, it is not inconceivable that a Secretary of State in 30-50 years time evaluates two very similar potential sites, and chooses the site which maximises the impact of and return on the taxpayers investment. That may not be the lowest cost option, but one which realises optimal benefits for that region of the UK.

Given that a key audience for these criteria are local communities, it is recommended that RWM conduct further analysis of the use of language with those who represent the community/civil society sector. For example, would lay people refer to “Engineering Feasibility”, or would the more simple “Construction” be more meaningful and accessible to them?

Geology

During the workshops there were repeated comments that there was too little specific mention of ‘geology’. We would agree with RWM that this issue should be woven through all the criteria, and not be a standalone criteria in its own right. We welcome RWM’s commitment given at several workshops that they will be more explicit about the role of geology when revising the text of the document after the consultation.

CoRWM recruiting: community & communications expertise wanted

i Apr 8th No Comments by

Experts in local democracy, community development, engagement and communications – do you want to help shape how communities can actively participate in decision-making for a major infrastructure project?

Recruitment is underway for up to 8 new members for the Committee on Radioactive Waste Management (CoRWM), the Government’s expert advisory panel. This is the latest important step in CoRWM’s evolution from a purely scientific and technical group, to one which can also effectively monitor and advise on how RWM implements the Government’s Working With Communities policy.

GDFWatch has previously reported on the potential for developing a model local democratic framework of how communities can have more control over decisions affecting where they live and contribute to long-term socioeconomic planning and economic growth in their area.

The CoRWM recruitment advert specifically states the following as amongst the key areas of expertise being sought:

  • community engagement, stakeholder management, education, and participatory planning and delivery activities relevant to major infrastructure delivery.

The recent tailored review of CoRWM, following on from last summer’s appointment of prominent social scientist Sir Nigel Thrift as CoRWM’s new Chair, underlines the Government’s awareness of the need to shift priority as the GDF siting process relaunches.  There is a recognition that the issues related to finding a site based on a community’s consent are increasingly social rather than technical – civics not science.

With widespread discontent about the state of our democracy and how decisions are made, the unique and novel process for finding a GDF site requires active community participation in the planning and decision-making processes.  This new approach to engaging communities in important decisions which affect their lives provides an opportunity to develop a wider and longer-lasting socio-political legacy.

GDFWatch believes this is an important opportunity to shape the future by supporting and guiding how RWM develops and manages Community Partnerships, and ensures communities have the confidence and capability to participate actively in the decision-making process.

The deadline for applications is 12 May 2019. For more information about the posts, visit this Cabinet Office webpage.  Good luck with your application!

 

TO CONSULT OR TO COLLABORATE: that is the community question  

i Mar 17th 2 Comments by

The sociopolitical challenges RWM faces were starkly revealed by the community sector’s response to a recent major Government funding announcement.  Their reaction suggests that the package of GDF-related investment and other funding, while being ‘necessary’, is not necessarily ‘sufficient’ to secure a community’s consent to start initial discussions or formally enter the siting process.

At the forefront of the sectors’ concerns is ‘collaboration’, and more active involvement in shaping policy and how it is implemented.  This aspiration, particularly in the context of a ‘consent-based’ siting process, is likely to become a key area of discussion as RWM seeks to build awareness, trust and confidence with communities.

The evidence for this analysis can be found in the community/civil society sector reaction to the Government’s recent £1.6 billion ‘Stronger Towns Fund’ announcement.  Instead of welcoming the extra cash, across the board there was frustration and concern that once again there had been no consultation with those affected, that this was another top-down solution, and was throwing good money at bad means of delivering real benefits to communities.  Those expressing this opinion included:

Their reaction suggests that RWM cannot simply throw money at communities – instead communities and their representatives are more likely to seek much greater collaboration and involvement in creating and implementing the GDF siting process.

And acquiescing to these demands (which it will be difficult to resist in a consent-based process) might actually lead to more robust, sustainable and trusted community partnership frameworks.

There is a wealth of experience in the sector in managing citizen and community participation in decision-making and long-term planning, and much work has already been done by the sector in reforming the relationship between communities and local government.  This experience and expertise is core to the fundamentals of the community partnerships envisioned by the Working With Communities policy.

Communities may have no expertise in radioactive waste management, but RWM has zero experience of building local democratic institutions.  This sounds like an environment ripe for co-operation and collaboration.

GDFWatch has flagged this issue on previous occasions.  Whether that be the similarities between the GDF siting policy and Localism Commission recommendations, or the range of research and publications by the civil society sector around empowering communities and citizens.  There is also a wider public political debate about the state of our democracy and making decision-making more relevant to ordinary people.

Initial political, public and media reaction to RWM’s current Site Evaluation consultation underlines the difficulties faced in building trust with communities.  Aside from expected NIMBYism, there is also appears to be a widespread , underlying lack of belief that the GDF siting process is actually “community-centric”.

The whole ‘consent-based’ approach is novel and new to the United Kingdom.  But people have little trust in such government pledges.  A more collaborative approach to determining how a community partnership might operate, decisions are made, and the right of withdrawal is protected, is likely to be critical to building community trust and confidence in the siting process.  Radioactive waste is a difficult enough ‘sell’ but is complicated by an honestly-proposed but cynically-regarded community-based decision-making process.

Nobody would necessarily choose to host a GDF, but like every other country we need to find somewhere to safely and responsibly dispose of our radioactive waste.  Thus, the process by which we go about finding a willing community and suitable geological site becomes critical.  The siting process needs to be transparently fair, balancing the rights and needs of the community and the developer.  Involving the civil society sector and drawing on their experience and expertise in developing the consent-based community partnership approach, is likely to be a key and productive step towards building community trust in the GDF siting process.

All The Fun of The Consultation: deadline 31 March 2019

i Mar 15th 1 Comment by

This week RWM completed their regional Site Evaluation consultation workshops.  The deadline for submitting a response to the consultation is 31 March (in England), and 14 April (in Wales).

The consultation process has been quite an adventure for RWM.  A taste of the public reaction whenever the issue of radioactive waste is raised.

Public & Political Reaction

Ireland erupted, leading to inter-governmental discussions between Dublin and Westminster about a GDF during delicate Brexit ‘backstop’ negotiations.  In Wales there was a request to cancel a public information meeting in Swansea – blocking any meaningful conversation/debate about an issue of national and global significance.  And even in England, the merest mention of a workshop or of the generic geological screening maps, encouraged local media to misleadingly write that their area was under consideration for a “nuclear dump”.  You can read all the media coverage on our media coverage page.

The noise created by this fallout, while understandable and predictable, somewhat detracted from the purpose of the workshops, to discuss improving the Site Evaluation criteria.

Consultation Events: headline summary observations

GDFWatch attended several of the events, to find out what people were asking, what concerned them, and to gauge wider sentiment about the geological disposal programme.  Much of the questioning wasn’t about the site evaluation criteria, but more generally about the siting process, eg ‘how do you define a community’?

Answering such questions was part of the purpose of the workshops, but not their primary objective.  However, there seemed to be a general sense at each of the meetings attended by GDFWatch that structuring key issues in this way was a very helpful step to communities beginning to understand an otherwise complex siting process and how it interacts with Planning and other legislation.  There also seemed to be a view that this would be an on-going process, rather than something which should be determined within this consultation period.

One point which did come up at each meeting GDFWatch attended was the perceived need to quantify the evaluation criteria, or in some way structure them so they could be assessed more objectively.  This was suggested both in terms of offering greater transparency to the public, and in providing RWM with enhanced legal protection if a decision were ever challenged (which most people seemed to think would happen at some point in the future process – though strikingly, it was a community being removed from the siting process by RWM which most people seemed to think was the most likely legal challenge!)

However, this is a just a summary overview, and many other points were raised.  You are encouraged to submit your own response to the consultation.  If you are considering submitting a response to the consultation, but have remaining questions, you can contact siteevaluation@nda.gov.uk for further information to help inform your submission.  Remember to do so before 31 March in England, and 14 April in Wales.

If there was one critique of the consultation workshops, it would be the limited number of stakeholders who attended, and the range of interests they represented.  There was diversity of opinion, but attendees tended to be those who’ve been keeping up-to-speed with the GDF siting process, whether that be from industry or community.  There was no obvious involvement of the kinds of groups and organisations whose awareness and engagement needs to be enhanced in a consent-based process.

Remember, the deadline for submitting your responses in England is 31 March, and in Wales is 14 April.  You can access the consultation documents and find out how to submit a response by visiting RWM’s website.

 

 

 

Anti-GDF Outcry in Ireland, Wales & England

i Feb 8th 4 Comments by

With Britain in sensitive Brexit discussions about the Irish border ‘backstop’, the GDF may have inadvertently become a new diplomatic point of contention between the two countries.

This is one of several running stories in the UK media this week, that underline the complexities and sensitivities of finding a site for a geological disposal facility:

There is a common thread running through these stories, of people rushing to judgement and hyperbole before checking their facts. For example, the reaction in Northern Ireland was driven by an otherwise-innocuous RWM information video describing geological features of the County Armagh area. There are similar short videos for every region of England, Wales and N Ireland.

A local newspaper decided to fact-check the allegations that the British government was considering an area near Newry for nuclear waste disposal.  The newspaper concluded that while the claims have elements of truth, they also have elements of falsehood, saying: “Preliminary work has been carried out to see if the site in Northern Ireland could work, but we are far, far away from a GDF in the North being a reality given how much would have to happen before it could be built.”

This, more nuanced view, was also expressed by an Irish politician living just across the border.  Fine Gael councillor for Dundalk,  John McGahon, said the initial report was likely nothing more than a “fishing expedition”, that the probability of any plan being approved was “extremely remote”, that it was important politicians on both sides of the Border were not “asleep on the issue”, but equally that local representatives did not engage in “scaremongering”.

The reactions, particularly in Wales and in N Ireland, were predictable, and are wholly understandable, particularly in the context of nationalist politics. However, they also underline some other common themes underpinning media coverage and political reaction, eg:

  • providing technical information on its own is a necessary but is not a sufficient basis to enable mature public discussion
  • catching people ‘cold’ is not the best way to introduce the subject or build understanding – it is a recipe for immediate rejection
  • there is in-built underlying distrust of the UK Government and its agents, and of anything they say – it is going to take time to build trust and confidence

This week has seen the first salvos in what will become a prolonged period of media, public and political discussion. The initial media and political reaction was to be expected. It will now be interesting to see how RWM accommodates anticipatable reactions and moves forward to construct a more positive environment in which to nurture informed public debate.

A full list of UK media articles can be found in our international news pages.

GDF as Social Infrastructure & Local Democracy project

i Jan 28th No Comments by

A new opinion revealing the depth of public despair at how our current democracy operates is published on the same day as GDFWatch argues in a leading community sector magazine that the GDF siting process could also be a major social infrastructure change programme to help address the local democracy deficit.

The opinion poll was published in The Guardian, while the GDFWatch article (reprinted below) was published in New Start magazine.

Communities in Control: a local democracy laboratory

A Government policy announced without fanfare just before Christmas potentially has implications for everyone working to enhance local democracy and empower local decision-making, writes Roy Payne, executive director of GDFWatch.

The new policy, called Working With Communities, provides a framework — and more critically, the funding – to help communities exert more influence over, and be more involved in, long-term social, environmental and economic planning in their area.

Although created to support delivery of a major nationally-significant energy infrastructure programme, the new policy is effectively a huge social infrastructure change project.

It establishes a new and unique Community Partnership framework designed to proactively and pragmatic solutions to some fundamental issues of community representation and engagement. For example, how do we best:

  • plan for, and over, the long-term without the distractions of the electoral cycle and the short-term decision-making it drives?
  • give local people influence over the delivery of the UK’s national contribution to solving a global environmental issue?
  • create an effective working partnership, and rebalance power, between communities and their local government?
  • contact and involve those hard-to-reach groups within a community whose voice is not always heard?

The Government has also made significant commitments to fund a wide range of activities, including:

  • a central secretariat to professionally support the new Community Partnerships
  • the acquisition of independent expert skills and knowledge to advise and support the community, to more effectively challenge government assumptions
  • socioeconomic analysis, to create a ‘vision’ document that sets out the community’s long-term social, environmental and economic ambitions
  • outreach and engagement activity, to ensure even hard-to-reach groups are involved in deliberation and decision-making processes

The policy framework and funding might be in place, but the project currently lacks any flesh for these barebone principles. That’s where the localism, local wealth creation, local democracy and community development sectors might now have a role to play.

Cynics will observe this all seems too good to be true. To be sure, there are inevitable caveats. But what makes this policy different from anything that has gone before, and why it might pique the sector’s interest, is that the Government requires a community’s ‘consent’ throughout this process.

Let that sink in for a moment.  The Government requires your consent.  You can walk away, without obligation, at any time. That changes the whole negotiating and power-balance dynamic. It provides the community sector with new and unique leverage to secure an equitable and meaningful partnership with central and local governments.

So, what are the caveats and constraints? First of all, over the 10-30 year lifecycle of the project, it is likely that no more than 10-12 areas will be involved. Any area in the country could be involved, but only a handful are likely to be actually involved. This offers the opportunity to create ‘mega pilot projects’ in which new ideas and techniques around community participation and empowerment can be trialled and evaluated. The lessons learned applied to other areas of public policy. The evidence built to show central government that local people can be trusted with decision-making responsibilities.

But the biggest hurdle is the subject matter. Nuclear waste. The international scientific consensus, on a par with that behind climate change, is that every country needs to build a specialised facility deep underground. The international political consensus is that any site must have the approval of the local community. These are huge projects. The UK’s facility is likely to cost around £20 billion, with an operating life in excess of 150 years. Wherever it is sited it will have profound long-term implications for the surrounding communities and economy.

Finland, France, Sweden, Switzerland and Canada are all well ahead of us in securing community consent to build such a facility. The UK has learned from their experiences. The requirement to gain a community’s consent is the driving force behind the Working With Communities policy. It is a radical and new approach in the UK to how communities can shape and determine infrastructure projects. But the principles of ‘consent’, and experience learned from direct community involvement, could be applied across a wide range of public policy challenges.

We live in the most centralised ‘democracy’ in Europe. Despite paying lip-service to devolved decision-making, Westminster does not yield power easily. The Government have been required to introduce the ‘community consent’ principle because it is international best practice. The consent principle offers a foot in the door to wider local democracy reform, if we can show Government hard evidence that people can actually be trusted to evaluate complex issues and make pragmatic decisions.

Rebalancing power and bringing decision-making closer to those affected is one of the key challenges we face as we look to a society beyond Brexit. Nuclear waste may not be the issue you would choose to engage with. But if we are to develop new and more democratic ways to govern our affairs in the 21st Century, perhaps resolving one of our ‘dirtiest’ intergenerational problems is the best place to start.

GDF Siting Process Re-Opens: Overview & Analysis

i Jan 15th No Comments by

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.

BEIS announcement

Announced by way of a Written Ministerial Statement, the Government published:

  • its Working With Communities policy, setting out the consent-based framework for the site selection process
  • a summary of consultation responses, with an explanation of where and why the Government accepted or rejected opinions it had received
  • a Memorandum of Understanding, setting out more information on the Third-Party Expert View mechanism which is designed to provide independent scientific support to help provide clarity to communities in the event of any disputed science

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:

Click on the following links for our separate initial analysis and observations on the Site Evaluation public consultation, and on the National Geological Screening regional summaries.

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 brief:

  • reaction to the Government’s policy has largely been positive and constructive, though everyone is aware that now is when the hard work begins, implementing the policy
  • there seems to be a widespread view that any interested communities are unlikely to start coming forward until later in 2019 – but always be prepared to be surprised!
  • RWM are planning awareness-raising and relationship-building activity to start rolling out in the next few weeks
  • part of this work will be conducted via the regional workshops RWM are planning in support of the Site Evaluation public consultation – these events are expected to take place during February
  • there also seems to be a widespread view that there is no need to hurry communities at this stage, because there is still significant work to be done in building awareness and understanding, particularly within the community and civil society sectors
  • a growing awareness that discussion is probably less likely to solely focus on science and technology at this point, but will be a broader social/political debate about how to most effectively implement the consent-based and partnership approach, that balances the rights of the community with the requirement to progress the site selection process.

Conclusion

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 info@gdfwatch.org.uk

 

Site Evaluation: Public Consultation

i Jan 15th No Comments by

Not entirely sure why this public consultation is being held.  There is nothing new in it.  However, if it’s an indication of a cautious, inclusive approach by RWM to taking wider civil society opinion with it, then it is to be welcomed.

The consultation document brings together all the existing legal, regulatory, environmental, planning and other requirements RWM is obliged to fulfil during the GDF siting process.  In some ways it reads a bit like a ‘roadmap’ for communities.  It helps:

  • begin to explain broad timelines and how the different siting, planning and regulatory processes interweave with each other, and
  • provides the bare bones of a potential work programme for engaged communities, by focusing on six broad factors — Safety, Community, Environment, Engineering feasibility, Transport, and Cost.

At this stage, the six headline factors appear sufficiently broad to encompass a wide range of more detailed issues.  Understandably the selected criteria are presented from the perspective of delivering the GDF programme, and of creating the necessary transparent platform on which comparative analyses of potential sites and host communities can be made.  However, they also read like the basis of a framework for community discussions, which will need to be continually updated and amended.

The 31 March public consultation deadline therefore seems a little arbitrary and pointless, since these issues will evolve over time, not least to include issues of relevance to those communities eventually engaged in the siting process.

A more basic concern is that civil society and community organisations will not have the capacity to make meaningful responses to the consultation by the end of March.

RWM have indicated that there will be a series of regional workshops to help explain the consultation and support better-informed response submissions.  These workshops are expected to be held around the country during February.  We are awaiting event details from RWM.

However, experience from regional workshops for the National Geological Screening, National Policy Statement and Working With Communities consultations suggest that it is the same organisations which tend to attend these events.  While useful for those attending, the workshops are not always the most effective means of reaching out beyond historical core-engaged stakeholders.

RWM are to be applauded for taking an open and inclusive approach, especially when it’s not, procedurally, even technically necessary.  We hope that they will continue to keep these issues open as the siting process progresses, rather than a draw a line under them on 31 March 2019.

For a copy of the consultation document and to find out more about the consultation, visit the RWM siting website.

Because radioactive waste management is a devolved responsibility, RWM will be holding a separate but parallel public consultation in Wales.  They have produced specific Welsh consultation documents (in both English and Welsh languages).  The Welsh public consultation ends on 14 April 2019.

 

 

Bitesize Geology: Can a GDF be built in your region?

i Jan 15th No Comments by

Want to find out whether your region, geologically, could host a GDF?  Then check out this information from RWM, the public body responsible for overseeing the GDF process.

I’d suggest watching the video for your area before reading the pamphlet.  The videos, in a weather-forecast format, present the same information as the associated leaflet, but in a much more understandable way.  The more detailed text in the leaflets can be a little daunting (even off-putting) for the non-geologists amongst us (in whom I include myself).  But the videos will help you grasp the overall picture and key issues for your area.

Anyone expecting to determine whether a GDF could be built under their garden, village or town are going to be disappointed.  But that has been the case from the very start.  RWM and the wider expert geological community have been at pains over the past 4 years of consultation and data collection to make clear that there is insufficient geological information to provide detailed location-specific analyses at this time.

The videos provide simple summaries which indicate the likelihood and ease of finding a suitable GDF location in your area.  In some places, like South Wales, RWM make clear it is less likely that a suitable geology can be found — in part because previous coal mining allows groundwater to move more easily through the rock, in part because some areas in the region have mineral resources that might be commercially exploitable, and the presence of thermal springs indicates water flowing from depth.  Conversely, there is a broad band of rock running right across southern-central England, from the Severn Estuary to the coasts of Suffolk and Essex, which looks more promising in terms of being able to host a GDF.

Essentially, with the information currently available, most parts of England, Wales and Northern Ireland could host a GDF, geologically-speaking.  But as RWM make clear, a lot more detailed localised investigation will be required wherever a site is proposed.  What looks like good geology now may prove to be unsuitable.

From a community perspective, the information is most useful in starting a conversation with RWM about the implications and impact of prolonged, detailed geological investigations in your area.  In some areas the physical intrusion of deep borehole drilling rigs, and securing the required planning permissions, may be easier to do compared with another place.  In other areas, the presence of National Parks or Areas of Outstanding Natural Beauty (AONBs) may complicate investigations.  Coastal communities can look to potential undersea sites for the GDF, easing the need for intrusive land-based local geological investigations in populated areas.

There will be those who question the validity and truthfulness of the geological information.  But the data has been collated and prepared by Britain’s world-leading expert institution, the British Geological Survey (BGS); the issues have been extensively debated by the Geological Society learned society; and the process has been overseen and interrogated by an independent international expert panel of geologists — some of whose work was conducted in public and streamed live.

If you go to the RWM website, you will find all the regional summaries and videos.  From the maps provided, select your region (based on the BGS’s geological regions of the UK), which will then take you to the sub-regions within each region.  This is where you will find information most relevant (but not specific) to your village or town.  RWM have said they are planning to update the webpages, so that it is easier for you to find the sub-region video and summary which interests you.

There are many sources of additional information and advice to help you make sense of these analyses.  Contact GDFWatch at info@gdfwatch.org.uk  for assistance in sourcing further information.

GEOLOGICAL DISPOSAL: 2019 INTERNATIONAL PREVIEW

i Jan 11th No Comments by

The country briefs below provide a headline overview of anticipated geological disposal and related activity across the world in 2019.  From a socio-political perspective, it could be a very interesting year for geological disposal.

The country summaries are not ‘technical’, but place national geological disposal programmes within the context of wider political and social discourse.  The nuclear sector has long-accepted that the barriers to progressing geological disposal are political and social rather than technical, and these summaries are designed to help foster evolving thought on these issues.

A review of media output from around the world highlights a coherent global geological disposal narrative, with key common socio-political themes threading their way through geological disposal programmes, eg:

  • project timescales make it easy for politicians and political institutions to continually defer or avoid decision-making
  • financial tensions between investing for the future and meeting short-term budget constraints
  • acceptance of the principles of geological disposal, but lack of trust in those making decisions or implementing the programme locally.

Some of these issues may be confronted head-on during 2019, for example:

  • the United States seems to be approaching a point where the financial costs to the taxpayer of doing nothing exceed the costs of actually doing something – such stark economics, driven by a vocal weight of public and media opinion, and new Congressional arithmetic, may deliver movement on the Yucca Mountain project;
  • the United Kingdom has relaunched its geological repository siting process, based on a ‘community consent’ approach that potentially provides a platform for trialling new models of local democracy, citizen engagement, and how society democratically plans for the longer-term without being disrupted by shorter-term political and electoral considerations;
  • Germany is about to embark on a public engagement process. This against a backdrop of post-Merkel political change, with intergenerational and other societal differences of opinion over issues like migration, Europe, climate change, energy security and sources.  Some surprising public attitudes may yet come from the geological disposal dialogue in Germany;
  • the Taiwanese government will have to respond to the recent referendum in which the public over-turned the government’s policy to phase-out nuclear energy – as a consequence of the referendum result, what to do with nuclear waste has already shifted up the political agenda.

What will also be interesting to observe in 2019 is the impact of the wider political and social challenges occurring in many countries around the world.  Geological disposal clearly does not operate in a political or social vacuum.  Public sentiment towards it can be driven by wider ‘non-nuclear’ issues.  For example, the disconnect felt between the governed and their current political infrastructures seems to be a feature of ‘populism’ planet-wide.  In this context, geological disposal could be seen negatively as a totemic example of that wider general public perception of national government making decisions without reference to the needs and concerns of people at a local level.  But as societies discuss resolving these broader political governance grievances, public attitudes and behaviours will have to shift, with potentially positive implications for geological disposal if the programmes can be aligned with broader societal ambitions such as those for improved local democracy and public accountability, intergenerational decision-making, etc.

The attached country summaries are not a comprehensive review of all geological disposal and repository programmes.  They only cover countries for which there is credible or verified information.  Some countries not covered by the summaries will have interesting stories to tell.  If your country is not mentioned, please do tell your story.  We want to be as accurate as possible but rely upon your input for veracity.

These summaries will be updated during the year.  Please alert us if there are any factual inaccuracies, other errors, or country programme updates, by emailing editorial@gdfwatch.org.uk

You can download the summaries in word document format here.

 

COUNTRY SUMMARIES: 2019 

Australia
Progress in 2019 for Australia’s repository program will hinge on the outcome of a court case initiated by a South Australian Aboriginal group.  The group wants their people to be included in a community ballot to determine whether the proposed radioactive waste management facility for the disposal of Australian low-level waste and the interim storage of the country’s intermediate-level waste (which is slated to be situated in the Kimba or Hawker areas) should proceed.

There is a Federal Court Hearing on 30 January.  No judgement is expected on that date.  With the possibility for appeals, and potential further legal actions brought by other interest groups, the Australian repository program could yet be a protracted process.  For example, over Christmas, another Aboriginal group tabled a new, separate law suit claiming they were not properly involved during the public consultation process.

The current federal Australian government is seeking to negotiate an out-of-court agreement, to build trust and to avoid a potentially protracted delay in the siting process.  However, there are federal government elections due in 2019 (expected to be held by May).  While there is bipartisan agreement on the need for a national radioactive waste management facility, the results of the election could further complicate political decision-making.

Belgium
In 2018, ONDRAF made recommendations to the Belgian Government advising that geological disposal is the best available option for managing the country’s higher-level radioactive wastes.  The Government was also advised to conduct an extensive public engagement programme before final decisions are taken on the siting of any repository.  However, the Belgian Government has not yet reached any decisions.  The coalition government is not stable, and it is uncertain when the Belgian Government will make a decision on geological disposal.

In the meantime, construction progresses on the low-level waste repository in Dessel (due for completion in the first half of the 2020s).

Canada
There are three separate repository programmes in Canada.  The Nuclear Waste Management Organization Organisation (NWMO) is responsible for the national deep geological repository for higher-activity radioactive waste; Ontario Power Generation (OPG) is planning a deep geological repository for low and intermediate wastes; Canadian Nuclear Laboratories (CNL) seeks a near-surface facility for low-level radioactive waste.

Each project is deeply engaged in conversations with local communities.  There are no major project milestones in 2019 for any of the planned repositories.  It is an on-going process of working with affected communities, paying particular attention to the needs and concerns of indigenous peoples.  Canada has led the way in early and proactive community engagement – vital for building public acceptance, but necessarily moving at a pace with which the communities feel comfortable.

NWMO have started the deep borehole drilling phase of their geological investigations, and this will continue through 2019.

The added complication for Canada are the cross-border concerns of environmentalists in Canada and the US about building radioactive waste repositories close to the Great Lakes.

Croatia (see also Slovenia)
Croatia’s Krsko nuclear power plant is located in Slovenia and is shared with Slovenia.  Discussions continue between the two countries on finding a site for the deep geological disposal of higher activity radioactive waste.

In the meantime, Croatia is pressing ahead with a low-level radioactive waste facility despite objections from Bosnia-Herzogevina that the proposed facility is located too close to their shared border and that there has been too little consultation and engagement with Bosnia.

Czech Republic
In 2019 the Czech Republic are expected to finalise the shortlist of areas which could potentially host a deep geological repository.  Advice and recommendations will be put to the Czech Government, but no further decisions or activity is planned in 2019.  The siting process and geological investigations will start after the government has finalised the shortlist of areas.
Finland  
The Finns continue with the excavation and construction of their deep geological repository.  The process is governed by regular reviews and staged regulatory licensing approvals.  No significant events are expected in 2019.
France
French authorities remain confident that a general licence application for the proposed repository at Bure will be submitted by the end of 2019.

A formal public debate organised by the National Commission of Public Debate was expected during 2019.  The debate is not intended to review geological disposal policy, but is intended to sustain transparency by staging a further discussion that engages the public in radioactive waste management.  However, the Commission’s priorities may be changed following the recent ‘gilets jaunes’ protests in France.  Time may now be given to more pressing issues of public interest rather than geological disposal of radioactive waste.

Germany
2019 could be an interesting year for Germany.

Legislation in 2017 laid out a new framework for how Germany would go about selecting a radioactive waste disposal site, and also ensured there would be significant public consultation and engagement in that process.

In the coming year, Germany will initiate a public communications and engagement programme, as a key part of the process of presenting the federal government with a detailed dossier in 2020 of geological information, analysis of public sentiment, and recommendations on the next stage.

Japan   
Understandably the Japanese are taking a steady and cautious approach to their repository site selection process.  The social and political fall-out from Fukushima only adds to the problems of managing long-established anti-nuclear public sentiment, distrust in politicians and the nuclear sector, and the geological complexity and insecurity of parts of the country.

The Japanese Government published a “Nationwide Map of Scientific Features relevant for Geological Disposal” in 2017, which identified potential geological ‘green areas’ where it could be possible to safely construct a deep geological repository.  This map has been the basis on which   NUMO (Nuclear Waste Management Organisation) has been building awareness and understanding of the issues and opportunities amongst mayors and municipal officials across the country.

NUMO’s difficulties are evident from separate actions by a number of the Prefectures, which have already indicated that they are not prepared to host a deep geological repository.

The Japanese will continue their cautious consensus-building approach through 2019.  Not just with mayors and municipalities, but with a programme of public information events.

It is worth noting that despite broader post-Fukishima anti-nuclear public and political reaction, recent media commentary has been urging decisions be made on radioactive waste disposal.  It seems the mainstream Japanese media believe that removing radioactive waste from the surface is a better option.

Korea
South Korea is conducting a significant public consultation and discussion programme, alongside its technical preparations to build a deep geological repository for higher-activity radioactive waste.

These public discussions and the technical analysis will inform subsequent Government decisions on how to select a site for the repository.  There are no plans for significant announcements in 2019.

Luxembourg
Luxembourg produces very small quantities of higher-activity radioactive waste, mainly from medical sources.  In 2018 the country entered into an agreement with Belgium for the interim storage and final disposal of its radioactive waste.  Legislation has been laid before the Belgian parliament.
Saudi Arabia
The Saudi’s have not yet published a detailed radioactive waste management programme and timeline.  During 2018 Saudi Arabia announced an intention to build their repository in a militarised zone to be established on the border with Qatar.  This announcement came at a time of heightened tensions between the two countries.  Whether Saudi Arabia persists with its proposal may be subject to wider geopolitical and diplomatic discussions in the region.
Slovenia (see also, Croatia)
Slovenia and Croatia share a nuclear power plant, at Krško – a legacy from the former Yugoslavia. The countries are planning to build a joint deep geological repository somewhere in Slovenia or Croatia for spent fuel and higher-activity radioactive waste from the Krško plant.

In the meantime, Slovenia is pressing ahead with a facility for low and intermediate level radioactive waste.  An environmental impact assessment is to be conducted to secure the necessary environmental consents.  With other documentation expected to be completed in the new year, the Slovenian Government is confident a final building permit will be granted during 2019.  Construction is planned from 2020-22, with the facility starting operations in 2023. 

Sweden
Following the decision of the Environmental Court in January 2018, SKB are required to submit further information on copper corrosion to the Swedish Government by 30 April 2019.

However, currently there is effectively no Swedish Government.  Discussions continue between the political parties about forming a government, following the results of the September 2018 elections.  It remains possible that another election may be necessary, further delaying the formation of a government.

Regardless of the outcome of these political discussions, it is expected that the Government will take 6-9 months to consider and respond to SKB’s copper corrosion evidence.   That would mean it would be at the end of 2019 at the earliest before next steps were taken – assuming the Swedish Government are content to proceed.

A final decision by Osthammar municipality is required before the government can give a permit for the planned repository at Forsmark to proceed.  Although a local referendum is not required, it is thought the municipality will hold one before taking their own decision. Nobody is expecting these local votes until 2020 at the earliest.

Switzerland
The Swiss press ahead with their siting programme, and will be spending 2019 drilling boreholes.

The Swiss Federal government announced in November 2018 that it had approved the third and final stage of the site selection process – deep borehole investigations in the three shortlisted regions.  These investigations will take place over the next 3-4 years, and the results analysed to find the region/s considered to be most suitable and safest for the construction of a deep geological repository.  Nagra, the organisation responsible for developing the repository, is expected to submit a general licence application for the disposal facility by 2024.

Approval of the licence is then not expected until around 2030.  There is still some uncertainty whether a national or local referendum will be required after the federal council and Swiss parliament have approved the general licence.  The repository is expected to be operational around 2040, initially taking low and intermediate level wastes, with higher-activity waste ten years later.

Taiwan
Taiwan updated its geological disposal programme in February 2018, ruling out certain parts of the country on geological grounds, and moving to the next phase of identifying potential areas in which to site a repository.  This stage was not expected to be completed until 2028.

The November public referendum result up-ended the Government’s nuclear phase-out policy, and has subsequently brought focus back to bear on the country’s management and disposal of its radioactive waste.

It will take some time in early 2019 for the Government to absorb the referendum result and reassess potential implications for its wider energy strategy – including geological disposal and the interim storage of radioactive waste.  It is a possibility that the Taiwanese Government will refocus on and give more impetus to its radioactive waste management and disposal programme.

United Arab Emirates (UAE)
The Government recently announced that radioactive waste will be stored on-site at the UAE’s new nuclear power station for up to 80 years after site closure.  The UAE Government has not yet decided its longer-term radioactive waste management policy, and it is unclear whether such an announcement will happen in 2019.
United Kingdom (UK)
The UK Government announced the re-opening of its geological disposal siting process in a long-awaited, but still surprise announcement just before Christmas 2018.

It is unclear at this stage how the process will proceed.  The proposed siting process is complex, and there remains a high-level of public and community unawareness of the issues.  The wider UK social and political environment, certainly for the first part of 2019, is also clouded by the uncertainties of Brexit.  It is therefore thought unlikely there will be much movement in the GDF siting process until later in the year.

United States of America (USA)
Political uncertainty also shapes the 2019 outlook in the United States, though probably in a more positive fashion from the perspective of the geological disposal programme.

Despite sustained and overwhelming bipartisan support in the House of Representatives, in recent years the US Senate has blocked all attempts to fund the Yucca Mountain programme.  However, after the midterm elections, the Republican Party no longer needs to protect the Senator from Nevada.  Although the Democrats now control the House of Representatives, there is no reason to suppose bipartisan support will change.

The financial costs of and local political sentiment towards maintaining radioactive waste in interim surface facilities (because the planned disposal repository has not been built) are building pressure for political action/decisions.

Countries with geological disposal programmes, but for which we have insufficient credible or verified information
Belarus  :  Bulgaria  :  Estonia  :  China  :  Hungary  :  India  :  Italy  :  Latvia  : Lithuania  :  Pakistan  :  Romania  :  Russia  :  Serbia  :  Slovakia  :  Ukraine
Countries with no known immediate plans to progress a geological disposal process, either because it is too early in their nuclear programmes, the issue has been deferred, or the underpinning policy and legislative frameworks are under development
Austria  :  Azerbaijan  :  Bangladesh  :  Denmark  :  Ghana  :  Greece  :  Holland  : Indonesia  :  Iran  :  Israel  :  Jordan  :  Kazakhstan  :  Kenya  :  Kuwait  :  Kyrgyzstan  :  Lebanon  :  Moldova  :  Nigeria  :  Norway  :  Poland  :  Portugal  :  Philippines  : Singapore  :  South Africa  :  Spain  :  Tajikistan  :  Thailand  :  Turkey  :  Uganda  :  Uzbekistan  :  Vietnam