Key documents on Scottish Government policy
The Scottish Government does not support geological disposal.
The developing policy allows two methods of dealing with higher activity wastes:
In early 2010 the Scottish Government published the Detailed Statement of Policy for Scotland’s Higher Activity Radioactive Wastes for consultation.The consultation documents included: the Policy Statement, Environmental Report and Supporting Information.
What we have done
- Scrutinised the development of the consultation documents, including attending meetings with the Scottish Government and offering informal advice
- Held meetings with a wide range of stakeholders to seek their views on the policy and the implications of its implementation. Stakeholders included: site operators, Local Government, regulators and NGOs
- Agreed a response to the consultation (doc2795) and submitted it to the Scottish Government
All documents relevant to preparation of our response, including reports of meetings, are in our Document Store.
Summary of our principal comments on the proposed policy
As well as detailed responses to the specific questions in the consultation documents, we made the following main comments.
- The policy would benefit from having more information about the nature of the waste being produced in Scotland. The Policy Statement should bring out that a sizeable portion of the higher activity waste in Scotland (perhaps 25% by volume) will not be suitable for near-surface disposal. The Policy Statement should clarify the process for arriving at an end-state for this waste.
- The policy is general and enabling, placing responsibility for developing an implementation strategy on waste producers and owners. It does not ensure optimisation and co-ordination. Explicit guidance about the aims of the implementation strategy is needed. Is there a preference for disposal? What are the criteria for arriving at decisions on sites for disposal facilities? More guidance about the process for developing the implementation strategy and the likely timelines is needed.
- The Policy Statement needs to make it clear that the NDA will lead the development of an implementation strategy. Scottish Government will have to direct and enable the NDA to take on this lead role.
- The Policy Statement needs to spell out how considerations of cost, affordability and best value will be taken into account in developing an implementation strategy.
Our future work on Scottish Government policy
- We will scrutinise how the Scottish Government finalises the policy, taking into account the responses to the consultation.
- We will report on our scrutiny in a position paper.
- In due course we will scrutinise and advise on how the policy is implemented.
Page last modified: 16/06/2010 15:44:56