FOI 03648 – Requests related to Allerdale Working Group
Response issued: 17/11/21
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Thank you for your request received on 25 October 2021 for information related to the Allerdale Working Group. I have treated your request under the Environmental Information Regulations 2004 (the EIRs) and confirm that we hold information related to your request. Please see our responses below.
Confirmation of the stage(s) at which consent will be sought and what will halt the progress if it is shown that the community is not providing consent?
The government’s policy on implementing geological disposal by working with communities was developed following several years of consultation and sets out a process that allows for engagement without early commitment on the part of communities and requires informed consent prior to decisions on site selection. All of the requirements are set out in Chapter 6 of the policy at: https://www.gov.uk/government/publications/implementing-geological-disposal-working-with-communities-long-term-management-of-higher-activity-radioactive-waste.
The process starts with discussions, fact-finding and engagement through a Working Group that can look to establish a Community Partnership to take the process forward with RWM, relevant Principal Local Authorities and community members working together. A Community Partnership can only be formed if at least one elected relevant Principal Local Authority agrees to participate. At any point prior to a Test of Public Support the elected relevant Principal Local Authorities can withdraw the community and halt the process. Once the necessary work has been undertaken to investigate the area and propose a potential site then the final Potential Host Community can be confirmed around that site. It is this community that will take a final decision on whether or not it consents to host a facility through a Test of Public Support. The elected relevant Principal Local Authorities on a Community Partnership will take the decision on when to hold a Test of Public Support but this would only be taken after extensive community engagement when the community has had time to ask questions, raise any concerns and learn about a GDF.
The Government policy is clear that if the result of the Test of Public Support is not positive, RWM will not be able to seek regulatory approval and development consent for a GDF and the siting process will cease in that community.
How do you plan to ensure consent received is informed and representative?
Community Partnerships could be working collaboratively to address issues, questions and concerns over a period of many years as technical work is carried out in parallel to provide more information, alongside the development of local community visions for the long-term future. As the Government policy that establishes the GDF siting process makes clear, “the Test of Public Support would only be taken after extensive community engagement when the community has had time to ask questions, raise any concerns and learn about a GDF”. It will be for Community Partnerships to decide how they wish to approach delivery of the Test of Public Support in their area, with the elected relevant Principal Local Authorities deciding the timing. The Government policy is also clear on the importance of this being carried out in a way that is fair and robust. It refers to three example mechanisms that could currently be used – a local referendum, a formal consultation or statistically representative polling – but also recognises that new methods to test public opinion may emerge in the future and Community Partnerships may wish to consider a different approach. More deliberative approaches that allow for more in-depth examination of issues by the public are being developed all the time and these may offer interesting opportunities for community decision making in future.
Please supply a summary of the age, gender and (if available) socioeconomic data for respondents to the survey carried out in April 2021 and how they represent the make-up of the consultation area as a whole.
The age and gender profile of the Allerdale sample is provided below. Quotas and weights were used to ensure the sample was representative of the known census profile of adult residents of Allerdale. The socio-economic group was not captured in the survey.
| Weighted proportion of sample | Unweighted base | Weighted base | |
|---|---|---|---|
| Total | 100% | 401 | 401 |
| Male | 49% | 188 | 196 |
| Female | 51% | 211 | 203 |
| Gender not provided | <1% | 2 | 2 |
| Aged 18-44 | 36% | 86 | 142 |
| Aged 45-64 | 36% | 157 | 143 |
| Aged 65+ | 28% | 155 | 113 |
| Aged not provided | <1% | 3 | 3 |
Share a copy of the Engagement Snapshot Report provided to Allerdale Borough Council.
Please see attached.
Provide examples of other locations which have agreed to a GDF, where the population density is similar to that of Allerdale.
Geological disposal is the chosen approach to dealing with higher activity radioactive waste in other countries including Sweden, Finland, Canada, and France. Finland and Sweden have reached the point of final community decisions. In Finland, all six sites under consideration were close to towns – although their towns are smaller than those in UK. For example Rauma, which is 15 km away from Olkiluoto, has 40,000 inhabitants and is as such a medium-size “city” in Finland and the 29th biggest municipality out of 309.
There are no regulatory requirements that would exclude Allerdale from consideration in the GDF siting process on grounds of population density.
Share any impact assessments or other related findings in the following areas:
- House prices
- Compulsory purchase of property
- Increased traffic and types of traffic
- Changes to transport (e.g. new or wider roads)
- Restricted access to areas previously accessible by the public (shoreline, sea, local footpaths)
- Provide a calculation for the financially negative impact on residents should a GDF be based in their area.
At this early part of the siting process the evaluation work completed by RWM is high level and focused on understanding if there is any reason to suggest that the areas identified could not be considered further and we do not hold the information requested above. The evaluation work completed has not confirmed that the Search Area is suitable to host a facility, only that it has the potential to contain a suitable location. The process to identify and select a suitable site will require much more detailed technical work considering a wide range of matters, including the long-term implications of delivering a GDF, that will take many years.
Share a full list of the other locations in England being considered as a potential site.
As well as Allerdale, GDF Working Groups have also been formed in Copeland and Theddlethorpe, Lincolnshire. The formation of the first GDF Community Partnership in Mid-Copeland has also been announced this week. You can visit all the GDF Working Group and Community Partnership websites from the main Working in Partnership site here: https://www.workinginpartnership.org.uk/.
Provide a list of all the reasons why the LDNP area of Allerdale was excluded from consideration.
The GDF siting process established in Government policy begins with interested parties proposing areas of potential interest for discussion, leading to a Working Group to begin engagement and propose a “Search Area” around which a Community Partnership can take forward more detailed work. Interested parties and Working Groups can start with any area they wish to propose as a starting point. In the case of Allerdale the original proposition from the Interested Party, agreed by all members of the Working Group, was to consider the whole of Allerdale except for the area within the Lake District National Park. The process is not based on consideration of entire Districts or Counties. There is no requirement for the LDNP to be considered at all and no-one on the Working Group is proposing that it should be.
Please add a page to your website detailing questions and feedback you have received to date, along with your responses.
The Working Group includes updates from engagement activity on its communications channels, such as the website for the monthly newsletters (sent directly to subscribers and also available on the Working Group website). An example of a newsletter with feedback from recent engagement events is here: https://allerdale.workinginpartnership.org.uk/allerdale-gdf-working-group-october-newsletter/
Confirm how many members of the Working Group live in the proposed GDF area.
There are only 6 members of the Working Group and we consider that if we provided the number of members who live in the Allerdale area it may be possible to determine personal information about individual Working Group members using other information that is already in the public domain. Under Regulation 13(1) of the EIRs, we are not obliged to provide personal information about someone other than you if releasing it would contravene the principles of the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR) which require that personal data be processed lawfully, fairly and transparently in relation to the individual concerned.
It may be helpful to add that the Working Group is responsible for opening up engagement, proposing a Search Area and identifying initial Community Partnership members. It is for the elected relevant Principal Local Authority/ies to decide whether or not a Community Partnership can be formed to take the work forward.
If you are unhappy with the way in which RWM has dealt with your request, you have the right to require us to review our actions and decisions. If you wish to request a review, please reply to this email or write to me at rwmfeedback@nda.gov.uk within 40 working days of receipt of this response. You will receive a full response to your request for review within 20 working days of its receipt.
Please remember to quote ref FOI 03648 in any correspondence about this request.
If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:
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