NDA Business Plan Consultation Freepost SEA 12430 Thornton Heath CR7 7XT Sent by e-mail to: facilitators@dialoguebydesign.com 6 January 2009
Dear Sir/Madam, DRAFT BUSINESS PLAN 2009/2012
I write on behalf of NuLeAF - the Nuclear Legacy Advisory Forum of the Local Government Association - to submit comments on the NDA‟s draft Business Plan. Our comments are as follows: Consultation Period and Basis for Site Funding Allocations As NDA Business Plans present three year rolling programmes, and there is limited scope for significant amendment of draft plans, we consider it acceptable to reduce the period of consultation to six weeks (p4). However, we think that this reduction should be accompanied by (a) opportunity for participation in pre-consultation discussions (including application of the Value Framework – see comments below) and (b) greater effort on the NDA‟s part to explain how it reaches decisions on site funding allocations and how those decisions are justified. In our comments on the 2008-2011 draft Business Plan, we expressed concerns that:
… the process for reaching decisions about the prioritisation of funding, and the reasons for those decisions, are not transparent. In particular, it is important for stakeholder confidence that a convincing explanation is available about how the reprioritization of funding on high hazard facilities will bring benefits in hazard reduction that justify reduced funding at other sites and the resulting impacts, including in some cases job losses.
As far as we are aware, the requested explanations are not yet being made available. We would suggest that more detailed information be published to provide transparent and robust justifications for spending decisions across sites.
Value Framework We note the commitment in the draft plan to continue to refine the Value Framework to inform decisions about funding priorities (p11). In our comments on the 2008/2011 draft Business Plan we highlighted that:
NuLeAF welcomes the increased effort that is being put into developing a robust and transparent process for informing decisions about prioritisation of spending across sites. It will be important that stakeholders are able to understand this process, and be able to see how it is being applied in practice. There are also likely to be benefits in involving stakeholders in the process, particularly where it involves value judgements on the relative importance to accord to different criteria such as hazard reduction and jobs. The benefits of stakeholder participation can include increased stakeholder confidence in the process and outcome, and more robust decision-making about priorities.
Since the submission of these comments, little has been done to engage external stakeholders in the development, refinement and application of the Value Framework. In the light of this, we would be grateful if NDA could provide clarification about: The lessons learnt to date from applying the current version of the Value Framework to this year‟s site funding allocation process; The forward programme for developing and refining the Value Framework; and How stakeholders will be involved in future development, refinement and application of the Value Framework.
Safe Secure Sites (S3) Contingency We note the expectation that S3 work will be completed soon (p11). Given the potential impact on local communities, the possibility of implementation of the S3 contingency is a matter of considerable concern to NuLeAF member authorities. I would be grateful, therefore, if NDA could provide further information about its decision-making timetable and process for adoption of its preferred approach. The reasons for adopting or rejecting the S3 contingency should also be clearly explained. Best Practice Conferences We welcome the proposal for a series of best practice conferences (p15) and suggest that NDA give consideration to including non-technical topics within the programme, potentially including, for example, topics such as socio-economic support and development, managing planning application processes, and stakeholder engagement. Maximising Income from Sale of Assets We support the optimisation of the use of assets to enable real and timely progress to be made in programmes of nuclear legacy management across the portfolio of NDA sites (p18). However, we consider that this needs to be done in a way that ensures: openness and transparency; effective engagement with local authorities; robust regulation; and due regard being paid to the long-term (not just short-term commercial benefit). See also our comments under „flexible solutions‟ for VLLW.
THORP and SMP We note that both SMP and THORP are subject to review and would welcome early publication of the findings (p19). “Flexible Solutions” for VLLW We note the reference to securing LLWR capacity and cost savings through “flexible solutions” for disposal of VLLW (p21), but urge caution in pursuing off-site routes within communities that are not familiar with the nuclear industry. Subject to suitability of the nuclear licensed site in question, NuLeAF‟s preference is to encourage development of local or regional LLW (and VLLW) management facilities at or adjacent to existing nuclear sites, rather than at non-nuclear sites. We would suggest that the scope for development of such facilities on NDA land be reviewed as part of the process of „asset optimisation‟. NuLeAF will be making further representations on LLW management during development and consultation on the NDA‟s LLW Strategy. Interim Storage of Higher Activity Wastes We suggest that the Business Plan give explicit recognition to the need to work with local authorities on the interim storage of higher activity wastes (p21). This will be particularly important with regard to the potential consolidation of storage at a smaller number of sites. Socio-Economic Support and Development NuLeAF remains concerned about the relatively modest amount of money (£10 million per year) that will be provided for socio-economic support, and that it is subject to planned efficiency savings being achieved in practice (p23). We consider that levels of socio-economic support should not be reduced because of the current “tight fiscal environment”. I hope that these comments are useful. Yours sincerely,
Fred Barker Executive Director