The Document
15. The process of consultation has been set in motion
with the publication of the September 2001 consultation document.
The document recognises that public acceptance depends on effective
consultation on the principles, options and implementation of
radioactive waste policy. It invites comments on how the process
of policy-making should be developed, on the institutional structures
necessary to carry it forward, on methods for securing deliberative
participation by stakeholders and a wider public, and on the programme
for action.
16. The consultation document[20]
has had a mixed reception. During an oral evidence session of
the House of Lords Select Committee on Science and Technology
the document was described as "vacuous" by a member
of the Committee.[21]
Professor Judith Petts expressed concern at the document's lack
of clarity, and specifically at the absence of clearly defined
objectives for the consultation process. She noted that "there
is no detailed discussion of the objectives of engaging the public,
other than to 'earn support'", and that "really engaging
people can only be done effectively when you are clear about the
objectives".[22]
The Nuclear Free Local Authorities wrote that "simply publishing
a consultation paper and inviting comments will not enable a proper
exploration of public views".[23]
Friends of the Earth has said that "whilst the DEFRA document
does contain important initiatives, namely the commitment to dialogue
and the recognition of plutonium as a problem that requires serious
attention, it repeatedly demonstrates a lack of understanding
and knowledge of the problem at hand."[24]
The Managing Director of Nirex, however, told us that "this
is a pre-stage, and the idea is that this will throw up issues,
which will then help to illuminate all the discussion about options
that is going to follow; and that is a new way of going about
things."[25]
17. The current document is effectively a consultation
on the consultation process. The consultation document is to
be commended for its acceptance that any approach to developing
radioactive waste policy must be developed with full public involvement
and a consensus about the most appropriate course of action. The
consultation is intended to define the remainder of the policy
development process, but the format and relatively low profile
of this first stage mean that it is unlikely to engage many members
of the public in addition to the usual stakeholders.
Timescale
18. Despite their support for the consultation process,
the view has been expressed by BNFL[26]and
British Energy[27] that
the proposed timescale for the programme of action is too protracted.
According to the consultation document a final decision on radioactive
waste policy will not be made until 2007. In his evidence to us
Mr Meacher said that he wanted "to very strongly refute any
suggestion that the Government is dragging its feet, or thinks
there is all the time in the world. That is absolutely not the
case".[28] In fact,
he argued, if "we have half a million tonnes to dispose of,
and it is going to remain hazardous for thousands or tens of thousands
of years, five or six years is the twinkling of an eye."[29]
RWMAC commented "This represents a challenging programme
of work. However it is essential that the process should not be
allowed to extend indefinitely"[30]
A measured and open staged process enabling participation and
involving stakeholders and the public has the potential to yield
the acceptability necessary to ensure an effective decision. But
delay is an ever-present danger. The timetable for the programme
of action should not be allowed to extend beyond 2007.
19. Concerns have also been expressed that the staged
consultation process set out in the Government's consultation
document is ill-defined. The process could be construed, not as
a genuinely open consultation, but as an information gathering
exercise designed to confer legitimacy on a pre-determined policy.
Professor Judith Petts told us that "what is needed now is
a clear characterisation of the decisions that have to be made,
by whom, over what timescale and to what purpose."[31]
RWMAC said that "proposals for future policy must be seen
to flow logically from the process. This indicates the need for
a carefully structured and phased approach to the identification
and evaluation of options." It has set out an alternative
and less limited five stage process to lead up to a decision on
the management option.[32]
20. Although we have some reservations about the
usefulness of the consultation document and the extent to which
the Government has thought through the consultation process, we
welcome the document as a first step towards developing a long
overdue policy for the disposal of radioactive waste. We are however
concerned that the process of policy development should be well-defined
and transparent at all stages. The Government should address concerns
that a generally phrased consultation document will not engage
the public in the debate. It should also set clearer objectives
defining the nature of the outcome of each of the remaining stages
of the consultation and policy development process, and provide
further details of how it will ensure that the programme of action
will be completed by 2007.
1 Managing Radioactive Waste Safely: Proposals for
developing a policy for managing solid radioactive waste in the
UK, DEFRA and the devolved administrations, September 2001, pp.14
ff. Back
2
Managing Radioactive Waste Safely: Proposals for developing
a policy for managing solid radioactive waste in the UK, DEFRA
and the devolved administrations, September 2001, p.7. Back
3
Managing Radioactive Waste Safely: Proposals for developing a
policy for managing solid radioactive waste in the UK, DEFRA and
the devolved administrations, September 2001, pp.14 ff. Back
4
Managing Radioactive Waste Safely: Proposals for developing
a policy for managing solid radioactive waste in the UK, DEFRA
and the devolved administrations, September 2001, p.7. Back
5
Managing Radioactive Waste Safely: Proposals for developing
a policy for managing solid radioactive waste in the UK, DEFRA
and the devolved administrations, September 2001, pp.7 and 8. Back
6
Members serving on the Radioactive Waste Policy Sub-committee
were: Mr David Curry MP (Chairman), Mr David Borrow MP, Mr Colin
Breed MP, Mr David Drew MP, Patrick Hall MP, Mr Michael Jack MP,
Mr David Lepper MP, Diana Organ MP. Back
7
See http://intra1.parliament.uk/commons/selcom/efrapnt03.htm. Back
8
We heard from Mr Chris Murray, Managing Director, and Dr Alan
Hooper, Chief Scientific Adviser, Nirex, from Mr David Bonser,
Transformation Director, and Mr George Beveridge, Director, Nuclear
Decommissioning and Clean-up (Europe), BNFL, and from Mr Robert
Armour, Director, Corporate Affairs, and Company Secretary, Mr
John Luke, Head of Fuel Cycle and Liabilities, and Mr Tony Free,
Liabilities Manager, British Energy, on Monday 26 November 2001;
from Mr Stephen Tindale, Executive Director, and Mr Mark Johnston,
Campaigner, Greenpeace, and Dr Rachel Western, Nuclear Research
Officer, Friends of the Earth, and from Professor Judith Petts,
Professor of Environmental Risk Management, University of Birmingham,
on Monday 3 December 2001; and from Professor Charles Curtis,
Chairman, and Mr Fred Barker and Dr Wynne Davies, RWMAC, and from
Rt Hon Michael Meacher MP, Minister of State, and officials, Department
for Environment, Food and Rural Affairs on Monday 17 December
2001. Back
9
HC Deb, 28 November 2001, cols.990 ff.w. Back
10
HC Deb, 28 November 2001, col.991 w. Back
11
See Prime Minister announces Energy Policy Review, Cabinet
Office Press Release CAB 124/01. Back
12
Royal Commission on Environmental Pollution Sixth Report Nuclear
Power and the Environment, September 1976, Cmnd 6618, para
27. Back
13
Taken from the Nirex website, at http://www.nirex.co.uk/iabout.htm. Back
14
The Way Forward: A Discussion Document, Nirex, 1988. Back
15
The Way Forward: A Discussion Document, Nirex, 1988, p.4. Back
16
HC Deb, 21 March 1989, col.508w. Back
17
House of Lords Science and Technology Committee Third Report on
the Management on Nuclear Waste, Session 1998-99, HL 41. Back
18
House of Lords Science and Technology Committee Third Report on
the Management on Nuclear Waste, Session 1998-99, HL 41,
para. 8.10. Back
19
The Government Response to the House of Lords Select Committee
Report on the Management of Nuclear Waste, DETR, October 1999. Back
20
Managing Radioactive Waste Safely: Proposals for developing a
policy for managing solid radioactive waste in the UK, DEFRA and
the devolved administrations, September 2001. Website www.defra.gov.uk Back
21
House of Lords Science and Technology Committee First Report on
Managing Radioactive Waste: the Government's Consultation,
Session 2001-02, HL 36. Back
22
Evidence taken on 3 December 2001, Ev 62, Q. 194. Back
23
Memorandum submitted by the Nuclear Free Local Authorities Steering
Committee, Ev 93.(apps). Back
24
Memorandum submitted by the Friends of the Earth, Ev 47. Back
25
Evidence taken on 26 November 2001, Ev 6, Q.2. Back
26
Memorandum submitted by BNFL, Ev 14, para 1.2 Back
27
Evidence taken on 26 November 2001, Ev 35, Q.101. Back
28
Evidence taken on 17 December, 2001, Ev 83, Q.264. Back
29
Evidence taken on 17 December, 2001, Ev 85, Q.274. Back
30
Memorandum submitted by RWMAC, Ev 69, para 2.11. Back
31
Memorandum submitted by Professor Judith Petts, Ev 60, para 20. Back
32
Memorandum submitted by RWMAC, Ev 69, para 2.9. Back