An Open Letter to all Cumbrian Councillors

January 18th 2013 Today Friends of the Earth wrote an Open Letter to all Cumbrian Councillors urging them not to proceed with the search for a site for burying nuclear waste in West Cumbria. Here is the text of the letter:

We congratulate the leaders of the 3 Councils for identifying some of the issues that need to be resolved before a decision can be taken, and 'pausing' the process.

However, we note with great concern the intention of Baroness Verma to subject Stage 4 to a 'thorough re-examination' in her letter to the CALC in November, re-iterated in her letter to the 3 Councils in December which says a change in the process should not be ruled out. This will remove any basis whatever for evaluating the willingness of people to go ahead to Stage 4 and undermines the 3 1/2 years work of the MRWS Partnership - which as you will recall, consulted on whether to proceed to a Stage 4 that would consist of 'desk studies' only, as outlined in the White Paper. A different Stage 4 - which could now involve site investigations with all the associated works - has not been consulted on. It therefore also undermines the principle of volunteerism. The enhanced budget provided to the NDA of £50m for Stage 4 strongly implies the inclusion of site investigations.

We therefore urge you to reject the proposal for the Council to move on to Stage 4 of the MRWS process for this reason and also because even if Stage 4 WERE as originally envisaged we believe that:

(a) Opinion in Cumbria is moving strongly against such a decision as the public learns more about the proposals, calling 'volunteerism' into question;
(b) Moving on to a search for a site is likely to have a negative impact on tourism and the wider economy even before a decision is made to go ahead with the construction of a nuclear waste dump; it will irrevocably damage the prospect of developing a diverse Cumbrian economy based on principles of sustainable development which reinforce the clean and green image of the Lake District National Park;
(c) Once a decision has been made to move on to the next stage the pressure to go ahead with construction of a dump, even on an inferior site, will be virtually irresistible.

Volunteerism
The Government says it supports 'volunteerism', so a nuclear dump shouldn't be imposed on a community that doesn't want it, though what constitutes a host community has never been properly defined. The MRWS Partnership's opinion poll found a small majority in favour of moving on to the next stage. But across Cumbria, 19% of those asked had never heard of the proposals; and 61% had either just 'heard of it or knew 'just a little' about it. A better indication of Cumbrian opinion would be the votes taken by the local Parish and Town Councils who would be directly affected. The Cumbria Association of Local Councils says out of 88 councils in Copeland and Allerdale, 53 have expressed a view and only 8 are in favour of moving on to the next stage, the rest against.

But most important, no-one has been asked about a different Stage 4.

The Cumbrian Economy
The Lake District National Park Authority has warned about the negative impact a nuclear waste dump could have on the Park's image. It said a dump "would not be in the long-term interests of the Lake District, its farming and resident communities and visitor economy." Friends of the Earth carried out a survey of more than 500 visitors in Keswick with the help of other groups. 89% of people thought a dump would have an impact on the image of the National Park, and all of them thought it would be negative. This would affect many related businesses. There is no evidence that the funding provided by DECC to 'protect' the Cumbrian 'brand' will succeed.

The Nuclear Decommissioning Authority says that a Geological Disposal Facility would on average create only 437 direct jobs over the first 10 years of implementation. , In our view it will perpetuate an overdependence on the nuclear industry which will discourage the development of more sustainable industries in keeping with the Lake District's clean green image.

The Right of Withdrawal
The MRWS Advertorial published in the local press during December continues to characterise Stage 4 as not implying further commitment. However as the Councils have rightly pointed out, this depends very much on whether there will be a right to reject the construction of a nuclear waste dump at a later stage, and who exactly will have such a right. We understand that the three councils involved have been seeking more legal clarity on the right to withdraw, but there have not been any moves to make this legally binding and/or unconditional.

Initiatives such as re-examination of Stage 4 make this even more worrying.

No other volunteers, no 'Plan B'
Scepticism about the right to withdraw is unsurprising because the Government has no "Plan B". No other area has made an expression of interest. Nor has the Government carried out a proper examination of the alternatives. Under the Environmental Impact Assessment Directive, developers must show they have considered alternative options to the one proposed or explain why others were not investigated. Even if plans for a dump go ahead, waste will still need to be stored for decades while it is built and while hot waste cools. This was outside the scope of the MRWS process, but it is essential to consider the management of ALL radioactive waste safely, not just a future repository. As you will know the National Audit Office recently criticised Sellafield for neglect. In this context West Cumbria and North Lakes Friends of the Earth is particularly concerned about the lack of response from the Government to the recommendation from the Committee on Radioactive Waste Management (CoRWM) that:

"A robust programme of interim storage must play an integral part in the long-term management strategy. The uncertainties surrounding the implementation of geological disposal, including social and ethical concerns, lead CoRWM to recommend a continued commitment to the safe and secure management of wastes that is robust against the risk of delay or failure in the repository programme."

Pressure on councillors to give the go-ahead to site investigations because a negative decision could put new nuclear development at risk only serves to increase the concern that Cumbria could be forced to go ahead on an inferior site. Because of the nature of West Cumbrian geology any search could only be for a "least worst" rather than best site. Site investigations would take around 15 years. If ten years of research were to take place, without considering any alternative, the impact on a nuclear programme, which by then could have several new reactors under construction, would be so devastating that the temptation to go ahead with an inferior site could be almost irresistible.

Geology 'unsuitable' or 'not promising'
As you will no doubt be aware Professor Stuart Haszeldine of Edinburgh University and Emeritus Professor David Smythe of Glasgow University, both say more than enough information already exists to show the overall geographical situation and the hydrogeology in Allerdale and Copeland is unsuitable. The Partnership asked geologist Dr Jeremy Dearlove to look into these claims. His view was that there are two areas of West Cumbria where the geology may be suitable - the area around Silloth and the Eskdale and Ennerdale area. But he said neither should be regarded at this stage as particularly promising. The likelihood of finding even an adequate site, let alone an ideal one, appears to be extremely low. As the Nirex Inquiry Inspector, Chris McDonald, said he "...was very surprised to find that West Cumbria was being floated once more ... the probability of their finding a suitable site is low."

Cumbria already has most of the waste
Councillors should not feel pressured by claims that 70% of the waste is already in Cumbria. The Government is hoping around 10 to 13 new nuclear reactors will get built over the next decade or so, and wants the dump to include waste from these. According to CoRWM the wastes from 10 new reactors would contain almost three times the amount of radioactivity of existing waste. So, in fact, most of the waste intended to go in the dump, in terms of radioactivity, would come from outside of Cumbria, with huge impact on the whole County in terms of transportation.

Inventory
The MRWS report identified several problematic issues. Some of these have been raised publicly by the 3 Councils with DECC, but not all of them. The fact that it is not known what would go into the dump is a major concern which has not assumed the importance it merits. How can any decision be taken in the absence of such crucial information?

Our position
In our view it would be extremely dangerous to move on to Stage 4 of the process when it is in the process of being redefined by Government. It is also unsafe to do so without an unconditional legally binding right to withdraw for the affected communities because the Government has yet to come up with an alternative to a geological disposal facility in Cumbria, and there are no other expressions of interest, so there will be, as we are already witnessing, huge pressure from Government to move on to repository construction whatever the views of Cumbrian people.

There is an urgent need for work on long-term waste storage options, and European legislation will probably require an examination of alternative options and sites. We therefore urge you to demand that an alternative radioactive waste management strategy is set out in some detail for wide consideration; and that the right to withdraw is enshrined in legislation before any further decisions are taken.

Over the next few months, West Cumbria and North Lakes Friends of the Earth will be setting out its vision of a vibrant sustainable economy for Cumbria with a reduced dependence on the nuclear industry, making the most of the clean and green image of the Lake District, and which relies instead on modern, community-controlled, clean technologies. We urge councillors to do the same.

Yours etc

Dr Ruth Balogh
Nuclear Issues Campaigner