Comments on NWMO’s Draft Plan by J.A.L. Robertson

“The road to Hell (somewhere unknown deep underground) is paved with good intentions.”

The proposed planning in the Draft Plan is necessary and laudable but I am concerned that there is not yet any open discussion on the siting process. The primary purpose of these comments is to urge urgency on the NWMO in preparing an information package before mention of any specific location, including those considered for only research.

This recommendation is based on painful experience. In the 1970s proposed geological field research, notably a site near Madoc, Ontario, had to be abandoned in the face of public protests. In a mass meeting in a school auditorium about a thousand people opposed the research fearing that it would lead to a repository. As one of a handful of those trying to explain the proposal, I found the atmosphere threatening.

In the 1990s the Siting Task Forces (STFs) for Low-Level Radioactive Wastes Management ran into similar trouble, largely attributable to inadequate preparation. The result was that antagonistic attitudes were established in communities before the nature and details of any proposal were known. Social scientists, e.g., Fischhoff and colleagues, claim that how people digest new information may depend on their preconceptions: it either reinforces existing opinions or is rejected. Opinions, once formed, are hard to change.

The lesson to be learned from these experiences is that any potential host community should have available a fair account of what is proposed before opposition arises. In any community there will be some people who will oppose the proposal and they will be quickly reinforced by well organized anti-nuclear groups with prepared material. The NWMO must anticipate this if it is not to repeat history.

The generic information package should contain, in language intelligible to the public, an illustrative description of a repository, essential and desirable geological criteria, an explanation of why it is believed to be safe, an unbiased list of the advantages and disadvantages to the host community including illustrations of mitigation and compensation, and how safe operation would be ensured. This should be available before any approach is made to specific communities and, ideally, before the siting process is announced publicly. While such a generic proposal would not be perfectly suited to any community, it would be better than the alternative, a vacuum.

Another lesson from the STFs was the need, from the start, for a proposal champion. Because the STFs and their Community Liaison Groups (CLGs) wished to be seen as facilitators and unbiased sources of factual information they did not promote the proposal. The communities and their media were subjected to much criticism of the proposal with nobody identified to defend it. The NWMO will have to accept that in its implementing role it is no longer unbiased and has to champion the proposal actively.

The STFs experience also demonstrated that the question of what constitutes the affected community is a difficult one that deserves serious discussion before approaching the public. To avoid causing intercommunity antagonisms the negotiation for benefits and the compensation package should ensure that these are attractive beyond the host community as defined on a narrowly legal definition. Ideally, the attractiveness should extend to all communities that perceive themselves to be subject to the risks. The possibility of having zones of different radius for different purposes should be considered. The need for surrounding communities to learn the positive as well as the negative aspects from the start should be recognized in preparing the generic proposal.

A lack of definition of “community” was one of the factors responsible for the STFs’ first-referendum fiasco in Deep River. This experience demonstrated that any referendum must be carefully planned and managed to ensure its integrity.

CLGs can serve a useful function but, like “community” their composition and terms of reference require advance consideration. The objective should be to have the affected communities feel that their CLGs truly represent them. Direct election, to replace nomination by elected councils, is a possibility. Constitution of a CLG as a committee of council would encourage the council to take a greater interest in the process but would exclude surrounding communities. Having councillors from all affected communities on the CLG might be an acceptable compromise but would impose an additional burden on busy councillors.

The Deep River CLG’s frustration culminated in a mass resignation. Part of the cause was a failure to obtain answers from the STFs for the communities’ questions. STF activities were heavily weighted to the technical while the community sought more information on the social side. Based on STF experience, the NWMO will have to maintain control over its scientific and engineering staff that may, by reason of their training and culture, favour a more technocratic approach. (Some professional codes of ethics require the practitioners to do what is best for their clients, which can be interpreted as requiring them to ignore public perceptions where these differ from their own professional assessments.)

The single page (p.22) of the Draft Plan devoted to the “Siting Process” provides little information on the NWMO’s approach to this vital activity, one on which many previous proposals have foundered. The wording is reassuring in its talk of collaboration. However, reference to “The site selection process…” (stress added) suggest the old paternalistic (DAD) approach of Decide, Announce, Defend. I strongly recommend that the NWMO include in its considerations the voluntarism principle, whereby communities, having been provided with the information package and any desired follow-up, state the conditions under which they would be prepared to accept a repository. The NWMO would still be responsible for selection but only after establishing what communities would require for them to accept a repository in a free market. The selection should be based not only on technical optimization but also on community acceptance. This process was working in Deep River until the relevant federal minister failed to endorse an agreement reached with one of her officials.

2008 April