Draft National Policy statement for Geological Disposal Infrastructure Contents

Conclusions and recommendations

National Parks and Areas of Outstanding Natural Beauty

1.We believe that given the nature of the material to be stored in a GDI, safety matters should be paramount and be given a greater weight than any other criterion. (Paragraph 22)

2.We also note the conclusions from the Appraisal of Sustainability that the overall impact of the GDI on the Appraisal criteria is “positive”, although we recognise that it is necessarily less “positive” than if National Parks and AONBs were excluded from developments. In our view existing planning legislation and the NPS contain sufficient safeguards against intrusive developments and environmental damage in National Parks and AONBs, particularly because any development requires community consent. We agree with the Government that a site could conceivably be designed in a way that would be acceptable to communities, preserve the benefits of National Parks and AONBs and avoid any surface facility in conservation areas. (Paragraph 23)

New nuclear build

3.Successive governments have for too long left it for future generations to find a solution to dispose safely of higher activity radioactive waste. It is time for a decision. Regardless of whether the Government should have embarked upon a new nuclear build programme and regardless of whether geological disposal is the best approach to dispose of waste, any long-term waste management strategy should include waste from new nuclear. (Paragraph 29)

4.We understand that the Government thought it would be enough to rely on references to CoRWM’s recommendations in the NPS. However, we think that advice from both RWM and CoRWM that further justification for geological disposal is needed in the NPS should be taken seriously. We therefore recommend that the Government work with CoRWM and RWM to strengthen the justification for geological disposal in the NPS. (Paragraph 30)

5.Given the changing nature of inventories and the timescales at stake, we reject the idea that the total the UK Derived Inventory should be finalised before proceeding with the final NPS. However, we agree with the evidence that before communities are asked to volunteer to host the GDI, it should be made absolutely clear to them that the inventory is uncertain and likely to change. As currently drafted, the NPS does not make that point clearly enough, especially to lay readers. Although the NPS is primarily aimed at the Planning Inspectorate and the developer, it should also be helpful to communities that are thinking of volunteering to host the GDI. We recommend that the Government clarifies in the NPS the level of uncertainty regarding the inventory and explains to prospective host communities how this will affect their right to reject the GDI at any point during the siting process. (Paragraph 34)

6.Volume of waste and underground footprint are two separate but crucial issues which will affect the type of facility required. It is essential that communities understand what responsibility—both in terms of volume of waste and level of radioactivity—they would be signing up for by hosting the GDI. For transparency purposes, the Government should clarify in the NPS the level of radioactivity that, to its knowledge, waste from the 16 to 18 gigawatt electrical new nuclear build programme would add to the total volume of radioactivity in the GDI and how that will impact the infrastructure requirements of the facility. The Government should also provide details in the NPS on the level of radioactivity from new nuclear build waste as a proportion of the total level of radioactivity in the GDI. (Paragraph 37)

Local community consent

7.We conclude that what may be a clear framework to the developer and Planning Inspectorate may not be as easily accessible to a lay audience. It is of paramount importance that prospective host communities understand how their ‘right of withdrawal’ interacts with the development consent orders for boreholes and geological disposal. We do not suggest that community consent should become an Assessment Principle as we think the ‘Working With Communities’ policy already guarantees to communities that no GDI could be granted development consent without their express approval. However, the NPS as currently drafted does not explain clearly how these two frameworks interact. The Government should clarify the degree of priority afforded to community consent in the NPS in a way that is accessible to a lay audience so as to give prospective communities all the tools they need to engage with the siting process. (Paragraph 44)

Industrial Strategy

8.For this reason, it is acceptable for the NPS not to contain any specific mention of the Industrial Strategy. However, the Government should refrain from drawing connections between the Industrial Strategy and geological disposal in order to justify its policy choices. If it wants to maintain the link between the two policies, the Government should justify in detail how geological disposal will be integrated within the Industrial Strategy framework. (Paragraph 48)

9.Beyond making payments to prospective communities and incentivising the developer to rely on local skills, it is hard to see how the NPS would expressly guarantee a development consent order that has robust socioeconomic benefits for the host community. It is also disappointing that the Government plans do not make local growth and skills a priority for the GDI if it is not one of the decisive factors of the development consent order. (Paragraph 52)

10.The Government must clarify in the NPS how the Secretary of State will have regard to local skills and employment opportunities when considering development consent orders for geological disposal. The Government should also place stronger requirements on the developer in the Impacts section of the NPS to establish robust local skills partnerships with the host community and to rely on local employment and sourcing opportunities. (Paragraph 53)

Published: 31 July 2018