CHAPTER 4: Summary of Recommendations
4.1. In this Chapter we set out our recommendations
in full. The numbers in brackets refer to the relevant paragraphs
in the text.
4.2. The Government should acknowledge the potential
for conflict and confusion inherent in their proposed institutional
arrangements for the MRWS programme, and take steps to ensure
that clear leadership and lines of accountability are established.
(2.17)
4.3. We therefore urge the Government to look
again at our 1999 recommendation for a wholly independent, permanent
body, subject to regular endorsement by Parliament, to oversee
implementation of the MRWS programme. However, if they are unable
to recognise the merits of that proposal, we would strongly endorse
the setting-up of an independent overseeing body, as recommended
by CoRWM. (2.18)
4.4. The Government must make it clear how they
intend to approach the site screening process. If it is not already
their intention, we recommend that they accept CoRWM's recommendation
on initially "screening out" geologically unsuitable
sites. "Screening in" runs contrary to the voluntarist
principle and will inevitably lead to anxiety among local communities.
It would not only impede and even hinder the partnership process
but would also constitute a waste of time and resource. (2.26)
4.5. We recommend that the Government conduct
a phased site-selection process. The Government should begin by
using scientific criteria to screen out unsuitable areas of the
country. Subsequently, socio-economic criteria would need
to be considered in parallel with the partnership process. In
our view, rushing through this process in three or four months
is disproportionate to the importance and length of the overall
project. We recommend that the Government reconsider the timescale
for this process, which forms the foundation of the geological
disposal programme. (2.31)
4.6. Progress on the MRWS programme must, as
we first noted in 1999, be steady and measured. We therefore recommend
that the Government delay the publication of the consultation
document until the terms of reference of the successor to CoRWM
have been finalised and the new Committee has been appointed.
We regard the consultation as the first important step in the
implementation process, and one which should also involve the
new CoRWM. (2.35)
4.7. We recommend that the Government, at an
appropriate time in the future, amend the Energy Act in order
to reflect the changing nature of the NDA's responsibilities as
it approaches the end of the current decommissioning process.
(2.41)
4.8. We recommend that in coming to their conclusion
on how best to engage at local level, the Government and the NDA
should take advice from all relevant local organisations, and
in particular NuLeAF, rather than relying on the NDA's existing
stakeholder groups. (2.48)
4.9. Decisions on how to implement the geological
repository programme should be evidence-based. Simply "believing"
something to be the right approach is not an adequate foundation
on which to build. We recommend that the reasons and evidence
for policy decisions in this area, in particular for the decision
to set up an advisory committee instead of an overseeing body,
should be published in full. (2.61)
4.10. We have already recommended that the Government
reconstitute the new CoRWM as an independent, overseeing body
with strengthened scientific, technological and social science
expertise. It should have a clearly defined and authoritative
role in scrutinising geological disposal strategy development
and implementation. In doing so, it should submit periodic reviews
to the MRWS Implementation Group and the Repository Development
Monitoring Committee. These reports should be properly responded
to and form an integral part of the MRWS policy process. The Committee
should have regular access to Ministers and its Chairman should,
when necessary, have access to the Secretary of State. (2.62)
4.11. Even if the Government's current proposals
are accepted in outline, the proposed remit of the new CoRWM is
highly confusing, and raises questions about the committee's independence.
These in turn may undermine the integrity of the scrutiny it is
intended to deliver. If the Government decide to proceed with
their current proposals, at the very least the terms of reference
will require substantial revision. We therefore recommend:
- Any scrutiny function assigned
to the new CoRWM, and the required responses to such scrutiny,
should be clearly defined and made explicit in the terms of reference.
- The relationship between the new CoRWM and the
NDA should be clarified, so as to avoid the prospect, which currently
looks likely, that the NDA will find itself both liaising with
CoRWM in developing advice to Government, and also , through the
Repository Development Monitoring Committee, itself considering
and responding to that advice.
- The relationship between the new CoRWM and the
NDA, as implementing body for geological disposal, should also
be defined in the NDA's revised governance arrangements. (2.68)
4.12. We recommend that the Defra Chief Scientific
Adviser should play a prominent role in developing the new CoRWM's
terms of reference and membership. We further recommend that the
Government look to the relevant Learned Societies for advice on
the Committee's membership. (2.71)
4.13. A legal opinion, casting doubt on the legality
of the merger between Nirex and the NDA, has now been released.
We recommend that the Government now publish in full their view
of this legal opinion and their reasons for proceeding with the
merger in spite of it. (3.17)
4.14. We agree with the Environment Agency that
the setting of packaging standards from within the NDA can only
be a transitional arrangement, and we recommend that, in order
to ensure rigorous independent regulatory scrutiny, an implementation
contractor should be appointed within the next two years. (3.18)
4.15. We therefore urge the Government to consider
giving responsibility for the long-term planning and co-ordination
of the required R&D for the MRWS programme to a strategic
overseeing body constituted with scientific, technical and socio-economic
expertise. This would ensure that the programme was optimally
integrated with policy needs. The research itself could still
be carried out at the National Nuclear Laboratory. (3.25)
4.16. We welcome the different initiatives undertaken
by the NDA and by the Government to ensure the supply of specialist
nuclear skills. However, particular attention should be paid to
training up and maintaining the specific expertise and skills
required for the long-term geological disposal programme. (3.29)
4.17. The Government must engage in a much more
open dialogue with local communities and other stakeholders regarding
the risks presented by current temporary storage and the steps
taken to address them. We therefore recommend that the Government
review the amount and level of detail of information on nuclear
security that is made available to stakeholders or published.
Security arrangements form an integral part of the implementation
programme and information on their nature should be readily available.
(3.35)
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