Just before Christmas (19 December 2018) the Business Energy and Industrial Strategy (BEIS) department published two important new documents dealing with the UK radioactive waste strategy. They received no mainstream media print coverage.
One document was a new 68-page consultation policy paper on ‘Implementing geological disposal – working with communities: long term management of higher activity radioactive waste’ described as “An updated framework for the long term management of higher activity radioactive waste.” (https://www.gov.uk/government/publications/implementing-geological-disposal-working-with-communities-long-term-management-of-higher-activity-radioactive-waste)
The second was a 40-page ‘Summary of Responses to the Consultation ‘Working with Communities’: implementing Geological Disposal’ https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/766661/Summary_of_responses_to_the_consultation_working_with_communities_-_Implementing_geological_disposal-rev.pdf
The summary states “There were 118 responses to the consultation from a range of organisations and members of the public.” This included a submission by myself, although my name is omitted from listed respondees.
In my opening paragraph of my submission I say:
“The Working With Communities consultation document asserts at para 2.4:
“The work to take into account the views of stakeholders and the public has supported an open policy making approach throughout the development of the Working with Communities policy proposals. We are continuing this approach by seeking views through this consultation from the general public and stakeholders on the policy proposals. Once the consultation has closed, and the responses have been considered, a Government response and final policy position will be published.”
While public engagement is a good practice, listening to the views expressed, and altering draft policy as a result is better practice. Experience suggests this rarely happens in radioactive waste consultations, and when it does, the changes are minimal.
It is hoped this consultation will mark a significant change from this hitherto counter-productive policy of early alienation of interested parties.”(my emphasis)
But, sadly, the same old BEIS strategy of ignoring responses containing inconvenient ideas and proposals has continued.
Paragraph 22 of BEIS’s response asserts “The Government does not agree that the Potential Host Community should extend beyond those directly affected by the impacts.”
We believe it is fair that only those that are directly impacted should have a say in whether their community hosts a GDF. (emphasis added) The Government, therefore, intends to maintain the approach set out in the consultation document, which allows for a clear definition of the boundaries of the Potential Host Community. It will include all the electoral wards in which the following are located:
• proposed surface and underground elements of a GDF;
• any associated development (as defined under the Planning Act 2008 in England) and any land required to mitigate impacts;
• transport links/routes from the GDF site to the nearest port, railhead or primary road network (i.e. out to where minor roads meet the nearest A roads);
• direct physical impacts associated with underground investigations, construction and operation of the GDF (identified through environmental impact assessment work carried out to support RWM’s engagement with communities and its development consent applications).
This thus dismisses the main substance of my own consultation submission, but without any reason for rejection being presented.
I made the following arguments:
Q1.Do you agree with this approach of identifying communities? Do you have any other suggestions that we should consider?
In the consultation document, the energy minister responsible for nuclear waste policy, Richard Harrington writes: “We believe the best way to select a site for a geological disposal facility is in partnership with communities.”
He adds “Building and operating a geological disposal facility is a multi-billion pound, intergenerational, national infrastructure project, which is likely to bring substantial benefits to its host community, with skilled jobs for hundreds of people over many decade.”
This short quote embodies the problem with how BEIS has characterised what comprises community for the purposes of the consultation document “Working with Communities (WWC).” For BEIS in this document a “community” is really a “directly affected host community” around the location of the above-ground receipt and transfer terminal for waste packages transported to the GDF. It is a great pity BEIS has decided to use such a narrow definition, because it excludes by fiat several much wider issues of public, political and safety concerns that will inevitably arise with development of a GDF.
In the WWC consultation summary, it describes the nature of community concerns as follows:
“There are many different ways in which people identify with areas, or define themselves against localities within those areas. Lessons learned from previous processes have underlined the importance of finding an approach that is clear, flexible, reflects the long-term nature of the siting process, and represents local government at all levels and other community groups appropriately.”
BEIS thus sees the relevant community as a “locality” relatively closed to and surrounding the GDF above ground workings.
But several years ago, BEIS actually established and sponsored a ‘Community Representation Working Group (CRWG) to explore the meaning of community, and the consequences of defing “community” in a particular way. The WWC consultation summary states:
“Efforts have been made to include input from a range of stakeholders and the public. A call for evidence, a literature review and public dialogue events in Manchester and Swindon have been undertaken to help develop the proposals”
The relevant footnote points out that the call for evidence can be found at: https://www.gov.uk/government/consultations/implementing-geological-disposal-working-with-communitie
The literature review and public dialogue events can be found at: https://www.gov.uk/government/publications/public-dialogue-on-geological-disposal-and-working-with-communities
BEIS needs to revisit this evidence when determining the final scope for the definition of community in this decision making process. Below I have extracted some of the discussion from reports published by the CRWG, which demonstrates the differing implications for policy of adopting narrow or broader conceptualization of “community.”
One major issue underpins the reason why the wider definition is essential is any GDF will require the transport to the GDF receipt facility of the radioactive waste packages, even if the GDF were to be build close to Sellafield, where the preponderance of waste ( both by volume and radioactivity) is currently stored. This is actually recognised - in a minor way- in the WWC consultation, when it concedes that there are wider ‘affected’ communities from such a 100 plus year development, at Paragraph 4.7, which makes clear that transport links/routes, from the geological disposal facility site to the nearest port, railhead or primary road network (i.e. as far as where minor roads meet the nearest ‘A’ roads used for transport on a regional or county level’ will be considered relevant.
At footnote number 26 to the document adds: “In selecting a site, the ‘delivery body’ would give consideration to existing transport infrastructure, suitable transport modes and routes, and appropriate mitigation measures to minimise any adverse impacts on a community.”
But the potentially hundreds of miles of ‘affected communities’ along road and rail routes from radioactive waste stores, to any centralized repository, are essentially ignored. Why does BEIS believe people living in these communities with multiple hundreds of loads of radioactive materials coming past where they live for many decades do not deserve significant attention, not least because radioactive waste in transit is more immediately dangerous to people close to transport routes than it is in an engineered GDF deep underground?
The Draft National Policy Statement recognizes at para 4.11.3 that there are security implications of developing a GDF, stating inter alia:
“Where national security implications have been identified, the applicant should consult with relevant security experts from the Centre for the Protection of National Infrastructure, the Office for Nuclear Regulation Civil Nuclear Security Programme and the Department for Business, Energy and Industrial Strategy (BEIS) to ensure that physical, procedural and personnel security measures have been adequately considered in the design process and that adequate consideration has been given to the management of security risks. If the Centre for the Protection of National Infrastructure, the Office for Nuclear Regulation Civil Nuclear Security Programme and the Department for Business, Energy and Industrial Strategy (BEIS) are satisfied that security issues have been adequately addressed in the project when the application is submitted to the Examining Authority, they will provide confirmation of this. The Examining Authority should not need to give any further consideration to the details of the security measures in its examination.(emphasis added) The Office for Nuclear Regulation Civil Nuclear Security Programme is responsible for approving security arrangements within the civil nuclear industry and enforcing compliance to prevent the theft or sabotage of nuclear or other radioactive materials, the sabotage of nuclear facilities, and to protect sensitive nuclear information; it does this in accordance with the Nuclear Industries Security Regulations 2003 and the Ionising Radiations Regulations 1999. The Secretary of State is entitled to rely on appropriate regulation of impacts in considering development consent applications.”
The Centre for the Protection of National Infrastructure was contacted in February, asking for further details of the work it has done on protecting the GDF and associated transport networks, but failed to even acknowledge the request, let alone answer it.
It is surely unacceptable that a potentially key Government body that will be involved in the future security of the GDF project can ignore enquiries for relevant information helpful to clarifying the important consultation questions.
On page 19 of the new consultation document is a very short two paragraph section on ‘Transportation’, which reads as follows:
2.28. The UK has more than 50 years’ experience of safely transporting radioactive waste and materials by road, rail and sea. Nuclear fuel is transported routinely from fuel fabrication plants to nuclear power stations, and spent nuclear fuel is transported from power stations to Sellafield for reprocessing and storage.
2.29. This transportation is subject to strict controls and is robustly and independently regulated in order to protect people, property and the environment. There have been no transport incidents resulting in any significant radiation dose to an individual in connection with the transportation of radioactive waste and materials between UK nuclear facilities15.
Reference 15 refers to the following document, a report already three years old. Office for Nuclear Regulation report: Events reported to the Nuclear Safety Regulator in the period of 1 April 2001 to 31 March 2015 (http://www.onr.org.uk/documents/2016/events-reported.pdf)
In my own submission to the ‘Communities Consultation’ early in 2018, I raised the transport issue as follows:
One day before the consultation closed, BEIS delivered by e-mail an additional set of four answers to questions raised at consultation forums several weeks earlier. One Question asked was:
If the eventual site for a GDF is not near Sellafield, what are the plans for transporting all of this waste out of Sellafield? Have (RWM) considered the costs and safety and security considerations for transporting most of the GDF inventory out of Sellafield to the GDF?
The answer given was:
“Higher activity radioactive waste is currently stored at over 30 sites in England and Wales. It will be transported to a GDF site over a long period of operation and therefore the rate of movement of radioactive waste will be low. The preferred modes of transport for radioactive waste would be rail or sea, though consideration of the mode of transport will be undertaken on a site specific basis. As the developer, RWM will have to consider the transport impacts (and consult on this and other impacts) as part the planning process. Radioactive waste has regularly been transported around the country for many decades.
Waste arriving at a GDF site will be in highly engineered transport containers. Radioactive materials have been safely transported not only in the UK but worldwide for over 60 years. There is a lot of experience in this area. There are very strict safety requirements laid out in national and international law. A number of large-scale safety demonstrations have been conducted to demonstrate that transport packages can withstand severe accident conditions.”
This is both an inaccurate and misleading answer by omission and commission.
BEIS needs to do better and more credible background research, rather than make unsupported safety assertions. Its claim “radioactive materials have been safely transported not only in the UK but worldwide is highly misleading. BEIS should review the internationally available reports on nuclear materials transport accidents, such as
‘Transportation accidents/incidents involving radioactive materials (1971--1991)’
The Radioactive Materials Incident Report (RMIR) database contains information on transportation-related accidents and incidents involving radioactive materials that have occurred in the United States. (USDoE, Office of Science and Technology, OSTI, International symposium on the packaging and transportation of radioactive materials: PATRAM '92, Yokohama (Japan), 13-18 Sep 1992; https://www.osti.gov/biblio/7193124 & https://inis.iaea.org/search/search.aspx?orig_q=RN:24038415
The international standards and arrangements are included in this 468 page IAEA document: ‘Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material- Specific Safety Guide (No. SSG-26).’ (https://www-pub.iaea.org/books/IAEABooks/8851/Regulations-for-the-Safe-Transport-of-Radioactive-Material-2012-Edition-Specific-Safety-Requirements)
The regulator of nuclear materials transports, the Office for Nuclear Regulation, published report in which indicated over 1000 accidents/ events involving radioactive material in transit within, to or from the UK since 1958. The abstract states:
“This report includes descriptions of thirty eight accidents and incidents involving the transport of radioactive materials from, to, or within the United Kingdom, which occurred in 2011. The number of events reported in 2011 was higher than in 2010 (30 events), and near the top of the range of the number of events that have occurred in the last five year period: 30 events in 2010, 33 events in 2009, 39 events in 2008, 26 events in 2007 and 29 events in 2006. Of the 38 events included in this review 11 involved irradiated nuclear fuel flasks (there were also 8 such events in 2010). Only one of the events reported, involving the transport of a radiopharmaceutical source, resulted in any potentially significant radiation dose.
The details of these events have been entered into the RAdioactive Material Transport Event Database (RAMTED), which now contains information on 1018 events that are known to have occurred since 1958.”
(Radiological Consequences Resulting from Accidents and Incidents Involving the Transport of Radioactive Materials in the UK – 2011 Review; http://www.onr.org.uk/transport/hpa-crce-037.pdf)
Thus the very error I spent considerable time researching and providing demonstrable information to explain why it was factually inaccurate has been completely ignored as the error is repeated in the new consultation!
I also include the following material in my consultation submission:
Here is what the Nuclear Free Local Authorities policy Briefing 145 on Nuclear security concerns – how secure is the UK civil nuclear sector? (http://www.nuclearpolicy.info/wp/wp-content/uploads/2016/05/A258_NB145_Nuclear_Security_concerns.pdf) – published in May 2016 - said on the security hazards from nuclear transports:
Risks from an attack on a nuclear material transport
One of the key issues for UK nuclear regulators and policy makers is around security with the
transportation of radioactive materials and their protection from a malicious attack. Many transports
of radioactive materials involve mildly radioactive material such as pharmaceuticals, ores, low-level
radioactive waste, and consumer products containing radionuclides (e.g., watches, smoke
detectors). However, increasing quantities of much more radioactive - and thus hazardous -
nuclear materials such as irradiated (“spent”) nuclear fuel and fresh, un-irradiated nuclear fuel,
including some containing plutonium (in so-called MOX or a mixed oxide plutonium-uranium mix),
is beginning to be transported around the UK as the existing nuclear programme is wound down
and decommissioned; and a new build programme of over a dozen new reactors distributed
around the country is planned.
High-level nuclear waste materials, such as spent nuclear fuel, are transported in very heavy,
robust containers, which must meet extremely demanding standards to ensure their integrity in the
most severe conditions, including sabotage.
International assessments of risk to transportation casks -
After September 11, 2001, the US NRC issued to licensees special new orders to increase security
in the transportation of specific types of radioactive materials, including spent fuel shipments. (24)
The September 11, 2001 terrorist attacks on the US caused the German government to reassess the
security of its nuclear power plants and spent fuel storage facilities. The German Nuclear Safety
Commission issued a statement recommending that an analysis be carried out on each plant to
assess its vulnerability to September 11-type attacks. Plant operators assert that terrorist attacks are
a general risk of society and should be treated like attacks on other infrastructure (e.g., chemical
facilities). Moreover, general analysis of the impact of the different civilian aircraft on commercial
nuclear plants was requested by the German Environment Ministry and has been carried out by a
nuclear industry consortium. (25)
A series of tests simulating terrorist attacks on transportation casks were undertaken in Germany,
France, the United States (for the German Government), and Switzerland (for the Swiss
Government). Additional tests may have been done that are not publicly acknowledged. As long ago
as 1979–1980, at the German Army facility in Meppen, a hollow charge (i.e. “ shaped charge”)
weapon was fired at a ductile cast iron plate and fuel assembly dummy to simulate a CASTOR cask.
The cask plate was perforated but release fractions from the fuel assembly were not examined.
From this experiment, the German government concluded that the wall thickness of the cask should
not be less than 300 millimetres. (26) (27)
Other tests were carried out at the Centre d’Etude de Gramat in France in 1992 on behalf of the
BMU involving shaped charges directed at a CASTOR cask filled with nine fuel element dummies
with depleted uranium. The shaped charge perforated the cask and penetrated fuel elements. This
damaged the fuel and resulted in the release of fuel particles from the cask.
UK issues around the transportation of radioactive materials -
Looking more closely at these issues for the UK, regulations covering the safety and security of
transport of nuclear materials are based on the recommendations of the IAEA. (28)
The UK nuclear regulator, ONR states of its responsibilities and mission: ―ONR Transport carries out
a range of regulatory activities to assure the safe transport of radioactive materials. Approval is
granted for the designs of packages used to carry high-hazard radioactive materials to ensure they
meet exacting international safety standards, and the packages are built to robust quality assurance
plans, and are correctly used and maintained. Regulation is also carried out through a programme of
targeted, risk-informed inspections and engagement with duty holders which may lead to
interventions. Inspections examine the management systems utilised by duty holders, as well as
compliance with safety and security legal requirements. ONR Transport inspects duty holders across
nuclear; non-nuclear; and industrial, medical and carrier sectors. (29)
But groups like CND, CORE and the local pressure group Highland Against Nuclear Transport have
been critical about the robustness of the ONR oversight of such transports in practice. (30) NFLA
have also consistently been raising concerns over the safety of nuclear material transports for a
number of years, whether they be of radioactive waste material transports or nuclear weapon
convoys (which is being considered in a parallel briefing on the defence nuclear sector).
Of particular recent concern has been the transport of highly radioactive materials from Dounreay to
Sellafield. These exotic‘ fuels have been to date sent on rail transports, but the Nuclear
Decommissioning Authority (NDA) has also commenced sea transports. NFLA‘s concern relates to
the occurrence of a malicious incident or an accident taking place on a remoter part of the rail
network or close to one of Scotland‘s large towns or cities…
The [then] UK Energy Minister Andrea Leadsom also informed Parliament in April 2016 of a relevant new
report by the Office of Nuclear Regulation (ONR) Details of safety events involving the transport of
nuclear material both by rail and on the strategic road network.
This report noted that there have been 3866 noteworthy events‘ relating to health and safety and
security recorded either at civil sites or with the transport of nuclear materials between the 1st April
2001 and 31st March 2015 (a list which also includes conventional health and safety events). Of
these, 3141 were rated on the INES scale as being of ‘no nuclear safety significance‘ (INES level 0
or not rated), and 716 were rated at INES level 1 (anomaly), being the lowest level of nuclear safety
significance on the INES scale. There were eight events rated at INES Level 2 (incident), and a
single event rated at INES level 3 (serious incident), which was in 2005. No events occurred that
merited a higher INES rating during this period, and none were designated as ‗accidents‘. (33)
NFLA welcomes the publication of this report as a serious attempt to develop a culture of openness
and transparency between the nuclear regulator and nuclear policy groups on such matters. It also
welcomes the steady reduction of incidents in recent years. NFLA still remains to be convinced that
the large and increasing amount of nuclear transports taking place in the UK is best practice for the
future, despite a good safety record. NFLA would rather see transportation of nuclear materials
limited as much as is practical, with safe on-site storage facilities developed instead.
This comment of Dr John Large lay at the heart of NFLA‘s concerns:
“Movement of nuclear materials is inherently risky both in terms of severe accident and terrorist
attack. Not all accident scenarios and accident severities can be foreseen; it is only possible to
maintain a limited security cordon around the flask and its consignment; the transportation route will
invariably pass through or nearby centres of population; terrorists are able to seek out and exploit
vulnerabilities in the transport arrangements and localities on the route; and emergency planning is
difficult to maintain over the entire route” (34)
25) Federal Ministry for the Environment, Nature Conservation and Nuclear Safety Summary of GRS study -
Protection of German nuclear power plants against the background of the terrorist attacks in the USA on 11
September 2001, English version:
(26) F. Large, G.Pretzsch, J.Döhler, E.Hörmann, H.Busch, and W.Koch. 1994. ‗Experimental Determination of UO2-
Release from a Spent Fuel Transport Cask after Shaped Charge Attack‘. 35th INMM Annual Meeting
Proceedings (Naples, Florida). Vol. 23, pp. 408–413.
(27) RSK (Reaktorsicherheitskommission). 2001. Safety-Related Guidelines for the Dry Interim Storage of Spent
Fuel Elements in Storage Casks. Recommendation of the Commission on Reactor Safety. April 5. Available at
(28) Regulations for the Safe Transport of Radioactive Material 2012 Edition; IAEA, Vienna, http://wwwpub.
(29) Office for Nuclear Regulation http://www.onr.org.uk/transport/
(33) Office for Nuclear Regulation, April 2, 2016 http://news.onr.org.uk/2016/02/events-reported-to-nuclear-safetyregulator-2001-15/
(34) John Large, Briefing on the safety of transports of radioactive material transports for Greenpeace UK, 2006 http://www.greenpeace.org.uk/MultimediaFiles/Live/FullReport7848.pdf
The case for considering the implications of a GDF in respect of the impact on the interests of affected en-route communities along the transport routes is thus unchallengeable, and the revised tests must address this in detail.
Finally, in my submission to the Communities consultation, I forcefully made the following point about why so-called Learned Societies such as the Royal Society cannot nor should not be trusted to provide accurate, impartial evidence to potentially affected communities
“The WWC consultation identifies at para.4.31, Table 2, the important role to be played by ‘Independent facilitators” in managing the local discussions of interested stakeholders with the formative engagement team as a “Community Stakeholder Forum” – to be engaged in ‘outreach’ activities to the wider communities- is established, stating:
“Independent facilitators can help ensure that discussions progress in a constructive and informative manner. The facilitators can assist in designing and delivering engagement with communities; asking relevant questions and directing conversation to cover the points of interest from the interested parties and other members of the community.”
What will be crucial to the legitimacy of the process is the genuine independence of the facilitation team. The Government needs to study very carefully how the West Cumbrian MWRS Partnership worked well; and learn from the instances where it did not deliver successfully.
The WWC consultation states at para. 4.53
“To support the operation of the Community Partnership, a Community Stakeholder Forum could be set up to provide outreach to the people in the community more widely. In addition, working groups could be set up to address specific issues, for example on technical issues or communication and engagement issues..”
But unfortunately, any further detailed description or framework for the establishing of any CSF is missing from the consultation document. It is unclear whether this is because BEIS has not yet devoted sufficient thought to how this should happen, or lacks sufficient interest to do so.
The UK Government says it “will ensure that communities will be able to access third party expert views on contested and unresolved technical and/or scientific issues once communities are constructively engaged. There will be an agreed process whereby third party expert views can be accessed from Learned Societies, as was committed to in the 2014 White Paper. The delivery body will produce guidance to help communities understand when and how they can access the process for third party expert views.”
The BEIS memorandum of 10 April 2018 states, in respect of information availability to interested parties in the volunteer host community, that:
“The intention of the working with communities proposals is for the delivery body (RWM) to be held to account, tasked with providing communities with all the information they require and with listening and responding to views and concerns in an open and responsive way.” ( emphasis added)
Neither the availability of Third Party expert views from so called ‘Learned Societies’ nor from the implementer, RWML, is acceptable, as they do not cover the range of relevant expertise from which analysis and assessment may be drawn.
Clearly the developer/implementer RWML, has a central stake in delivering the GDF project, so its information is almost certainly going to be selected to support the successful outcome of the project. RWML is very unlikely to provide the interested parties in the Directly Affected Host Community or less still affected communities, with
“all the information they require.”
It is known from experience that when DECC decided to produce its own supportive information for a national public consultation on the National Policy Statement for Nuclear Power, it was forced to re-hold the consultation after a High Court Judgment supporting a judicial review appeal from Greenpeace, based on the Ngo’s claim that information provided by DECC was biased in favour of the Government policy This would be an extant concern in the case of RWML providing information for the GDF project.
The issue of the independence of the Learned Societies is more complex, and perhaps more contestable. In general, British Learned Societies have a globally respected reputation for high quality of research competence, scholarship and excellence.
Unfortunately, this reputation is underserved when it comes to work they have undertaken and published on nuclear power, including nuclear waste. In this atomic arena, the reports have tended to be much too uncritically supportive eof nuclear projects, drawing their references form a far too narrow base, and resulting in conclusions which are more cheerleading than objective. The Royal Society, the pre-eminent Learned Society, has been especially bad in publishing poorly edited and uncritically peer-reviewed papers on nuclear issues.
Two examples of this poor scholarship are:
Fuel cycle stewardship in a nuclear renaissance
The Royal Society Science Policy Centre report 10/11
October 2011 DES2159
A note by the Royal Society revealed in respect of this report: ‘The Royal Society is very grateful to the UK’s Strategic Programme Fund for its financial support and the Foreign and Commonwealth Office for its assistance’
Strategy options for the UK’s separated plutonium
Policy document 24/07
Appendix 5 on page 29 of this report comprises map of nuclear facilities in the UK, but totally omits the UKAEA Dounreay fast breeder nuclear plants in Caithness, demonstrating shoddy scholarship and equally shoddy editing.
BEIS should re-examine the proposal that Learned Societies (LSs) should be the primary information source in the Third Party Mechanism. Citizens concerned over different aspects a of the GDF proposals should have the right to obtain funds to engage genuinely independent expertise- whether based in the UK or abroad- to examine aspects that concern them.
But ministers clearly know better. Despite my setting out why such Learned Societies cannot be trusted, they have nevertheless decided to rely upon them exclusively to provide information support to affected communities. In a third document, also released on 19 December, entitled MEMORANDUM OF UNDERSTANDING (MoU)
regarding the geological disposal facility Third Party Expert View Mechanism
BETWEEN THE DEPARTMENT FOR BUSINESS, ENERGY & INDUSTRIAL STRATEGY & WELSH GOVERNMENT & RADIOACTIVE WASTE MANAGEMENT LIMITED & THE LEARNED SOCIETIES The Geological Society of London, The Institute of Environmental Management and Assessment, The Learned Society of Wales, (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/766645/Third_Party_Expert_View_Mechanism_and_Annex.pdf)
BEIS sets out how this information arbitration will work.
One paragraph reads:
“The purpose of this MoU is to establish a framework for the cooperation between BEIS, Welsh Government, RWM and the LSs to provide a Third Party Expert View Mechanism in circumstances where there exist contested and unresolved technical and/or scientific issues that have arisen during the GDF siting process, and one of the parties feels that a further view from a relevant LS member could be helpful. The mechanism will be available from the beginning of what is referred to as the ‘community engagement’ of a community in the GDF siting process and continue throughout the subsequent discussions with communities during the GDF siting process.”
The way BEIS has dismissed critical, inconvenient evidence, makes me wonder over the utility of spending time researching and preparing a reponse to the new public consultation, when the ministerial track-record is to dismiss and/or ignore factual information that contradicts Governmental ideological bias or pure pro-nuclear prejudice.