This is a memorandum on behalf of NuLeAF—the Nuclear Legacy Advisory Forum of the Local Government Association—to submit comments on the Government's response to CoRWM's recommendations.

  NuLeAF welcomes the broad thrust of CoRWM's recommendations and the Government response, although we do have some initial concerns as outlined below.

  NuLeAF is responding positively to the Secretary of State's invitation to engage in discussions about development of the MRWS process and, in particular, the implementation framework. We particularly welcome the commitment to explore the way in which the concepts of willingness to participate, partnership and support packages can be built into the Government's approach. Indeed, we have a series of meetings arranged with Government to discuss our proposals on these issues.

  Our proposals are being developed in a series of Briefing Papers on the following subjects:

—  Proposals for Siting Partnerships.

—  Initial Invitations and Local Decision-Making about Participation.

—  Funding Participation and Enhancing Community Well-Being.

—  Siting, Planning Requirements and Rights of Withdrawal.

  I would be happy to supply copies of these Briefing Papers to the Committee.

  In terms of NuLeAF's preliminary views about the Government response to CoRWM, we would like to draw attention to the following:

NDA AS IMPLEMENTING ORGANISATION

  There is concern about the pace and process of decision making about arrangements for developing the NDA's role as implementing organisation. As stated in NuLeAF's policy statement on "Institutional Arrangements for Implementation",[1] there are disadvantages associated with the NDA model and, to ensure stakeholder confidence, there will be a need for Government to show how these disadvantages can be overcome, reduced or managed.

  In particular, there will be a need to ensure that the NDA's drive to accelerate the decommissioning and clean-up of nuclear sites does not put undue pressure on the timetable for repository siting. To increase the prospect for success, we consider that the siting process must allow sufficient time for potential host communities to participate effectively and for their concerns to be properly addressed. A second issue is that careful thought will need to be given to how to develop the NDA's capacity to work effectively in genuine partnership with potential host communities. A third will be to ensure that the NDA's contractor model enables an appropriate level of NDA involvement in decisions about repository design as site investigations and development proceeds.

RECONSTITUTED CORWM

  It will be important for developing stakeholder confidence that:

—  the reconstituted committee is able to deliver timely advice and recommendations on any aspect of the implementation programme;

—  its advice and recommendations are given formal consideration by the relevant bodies; and

—  responses from these bodies are published.

  To this end, we have suggested to Government that it would be appropriate to make an addition to the Committee's terms of reference along the lines of: "The Committee's advice and recommendations will be central to Government's determination to maintain general public, and local community, confidence in the delivery of a geological disposal facility. Government will expect all parties subject to CoRWM's advice and recommendations to publish responses within a jointly agreed timeframe."

PROCESS FOR INVITING PARTICIPATION

  Based on CoRWM's recommendations, there is an expectation that an initial screening of the UK will be undertaken so that invitations to participate in the siting process are only issued to those local authorities in areas that are potentially suitable for repository development. This approach attracts support because it would enable local authorities in areas, for example, with little prospect of having potentially suitable geologies, to avoid unnecessary and difficult discussions about whether to participate in the siting process.

DEVELOPING APPROPRIATE FORMS OF PARTNERSHIP WITH PARTICIPATING COMMUNITIES

  In essence, the purpose of a local partnership would be to ensure that all the concerns of participating communities are properly addressed. Its role would be to scrutinise, research, consult, and negotiate as appropriate, so that decisions within the siting process are fully informed and secure the confidence of local stakeholders. In developing appropriate models of partnership, there is no need to start from a blank sheet because there is considerable UK and international experience, as recently reviewed in a recent NuLeAF briefing paper, "Proposals for Siting Partnerships", October 2006. This briefing highlights the need to build on current learning about partnership working, including issues associated with development of a shared vision, representation, skills development, resourcing and timescales for effective working.

RESOURCING OF LOCAL AUTHORITY INVOLVEMENT

  CoRWM's proposals for "involvement packages" to meet the financial costs of participation in the siting process are strongly supported. In addition, we have drawn Government's attention to the need to address issues of resourcing local authority involvement in the steps prior to participation in the siting process, including engagement in developing the implementation framework, and responding to invitations to participate in the siting process.

5 January 2007