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MANAGING RADIOACTIVE WASTE SAFELY

Chapter Seven : Conclusions and Recommendations

7.1 In this final chapter we present conclusions and recommendations for action at different levels arising from what we have learned in the course of the study. Following the criteria identified in the model (Figure 5.1) the conclusions are grouped under the relevant headings:

• reason for engagement
• rules of engagement
• techniques for engagement
• processes of engagement
• support mechanisms
• resource implications
• quality assurance

7.2 Participants demonstrated levels of interest and willingness to engage in discussion of a complex issue of long-term significance ²⁹. The majority believed that it was important to be involved in this process and were hopeful that their participation would make a difference. This could not be assumed at the outset, particularly among those focus group participants who did not see themselves as directly affected or to have much knowledge about the issues in advance. Indeed, the majority of participants concluded that the issue is so important that it is essential for the public to become better informed and to have opportunities to be more closely involved in decision-making processes.

7.3 The research was designed to identify different responses to the issue of managing nuclear waste among people whom we assumed were directly affected by it and those who saw themselves as unaffected. Participants challenged this assumption. There was certainly a difference in understanding and experience between participants in the 'affected public' group and the other groups, but most of those described as the 'unaffected' public did feel affected by the issues being discussed and were prepared to challenge others who did not see the direct relevance of the discussion to their own lives.

Public engagement and policy dilemmas

Reasons for engagement

7.4 Recent trends suggest that some of the big dilemmas for decision-makers of the next decade and beyond will be matters of an ethical nature, where values and principles for decision-making will need to be negotiated with the public. Examples include the MMR triple vaccine (mentioned by several participants as a 'live' issue at the time of the fieldwork), BSE, GM foods and gene therapy ³⁰. On these and other matters, the "genie of doubt" is out of the bottle: it appears that appeals to evidence-based policy by Ministers and scientific advisers will not fully satisfy an inquiring public. "Who can we trust now?" asked a number of participants, aware that relying only on 'experts' will not lead to the best course of action if they cannot come to some agreement on the facts or feasible options, or their independence is believed to be compromised.

7.5 How should such decisions be made in future on how and where radioactive waste should be stored? What are the levels of technical knowledge or agreement that exist among scientific experts? How can the public become engaged in the process? The UK does not have a referendum culture or an ultimate community right of veto, with public involvement securely resourced as in some other European countries. Nor is the planning system used explicitly, to lever maximum benefits for communities directly affected. Lacking these structural supports, there is a need to consider with some urgency how the public can engage in a more meaningful dialogue with government and the industry about perceived and actual risks and options for action.

Engaging the public: ingredients for success

Rules of Engagement

7.6 Ingredients for successful public engagement include the need for information that is widely available, provided by sources that can be trusted and comprehensive enough to provide participants with the knowledge to become engaged in the discussion. While some participants believed the amount of information provided to be adequate, others felt it was important to become involved in further discussion to deepen their understanding and offer the possibility of influencing decisions that are made. In addition, information should be accessible in language and style, particularly on issues of a complex or technical nature. Participants agreed that a 'jargon-busting' role, where information was translated into plain English, had been essential to their level of understanding.

Clarity of purpose

7.7 Consultation as one common strand of public engagement does not imply any necessary shift of power towards the public as citizens or consumers. Consultation should open up a process of active dialogue, where all participants are open to changing how they think and act over time. According to one industry stakeholder, governments in Westminster and Edinburgh are changing the nature of consultation, applying new tools more often and in new areas, but it is not yet clear how far these have influenced decision-making processes or outcomes.

7.8 Organisations seeking to engage the public need to demonstrate a high level of awareness about the outcomes they are aiming for, in order to be clear about the type of process they are engaging in. A clear sense of purpose should first be identified, followed by decisions on appropriate tools and techniques, when they should be applied, forms of feedback and linkages into future dialogue and action. A growing number of methods for involving the public have emerged in recent years. The primary strategic question is not, which of these works best in different circumstances, but why the public is to be involved in dialogue around particular issues. Are they being involved as customers or as citizens? Without prior attention to these questions, there is a risk that future exercises to engage the public are conducted as projects, without context or sufficient linkage to mainstream decision-making.

7.9 Creating consensus for decision-making where there are issues of genuine uncertainty and legitimate action cannot be secured without deeper public awareness. There are various motives among consulting bodies for involving the public:

• seeking out new sources of policy-relevant ideas
• research/informational purposes
• public relations
• corporate social responsibility reasons

7.10 It is important to be clear about where on the spectrum from one-way information flow; through consultation to joint decision-making (a two-way relationship based on partnership) a particular engagement is intended to sit. As discussed in the literature review, this will allow the engaging organisation to clarify the scope for public and stakeholder involvement, and to be explicit about the role of participants in the decision-making process. If participants expect to influence decisions and action through a process that is not designed for this purpose, the validity of the exercise will be undermined.

Trust and expertise

Techniques for Engagement

7.11 An important tension was evident around the issue of independent expertise. Participants expressed relatively low levels of trust in how engagement processes tend to work in practice, combined with a strong belief that engaging the public is a positive thing in principle. Participants tended to have low levels of trust in government and the nuclear industry as sources of information (although the industry was the most trusted source among those most directly affected in the 'affected public' group) and identified a need for independent information and expertise to be available to the public to assist their informed engagement. The public invested a higher degree of trust in environmental NGO expertise.

7.12 Information provision, like engagement is a dynamic process. Providing people with accurate and evidence-based information is unlikely to build trust, unless judgements about the sources of information are also changed. Participants placed a premium on the trustworthiness of information sources in the development of a successful engagement process.

7.13 Participants recognised that there are some major disagreements about what the "best" solutions might be and expressed a desire to access information from experts with different opinions. The majority of participants would welcome a mix of experts from different sectors and with different views communicating with each other (and with the public) in search of common solutions. This would help to ensure that decisions are made on the basis of "what's best", rather than vested interests getting in the way. Some participants pointed to expertise within their group among people who had worked in the nuclear industry or had other direct experience of the issues. A smaller number of participants believed that the specific nature of this issue meant that current expertise and technology were not sufficiently advanced to offer anything like an "ideal" solution. A few admitted to feeling "terrified" by the uncertainty and risk they read into the consultation document. Others believed the best that can be done is to find a legitimate and "safe enough" approach free from conflicting interests around profit, while addressing waste and energy issues at an international level

7.14 Two further elements were identified as important in building trust: full disclosure of information and appropriate feedback. Underlying our findings was a clear desire for "the whole story - the good news as well as the bad" to be easily accessible.

Engagement as an ongoing process

Supporting Engagement

7.15 Our study has focused mainly on management of legacy waste, where the task is to put into practice government commitments to make the safest decisions possible on disposal, recycling and storage. There are, however, future decisions to be made on waste minimisation, efficiency in power generation and waste volumes/types from whatever system of nuclear reactors is in place in future. Participants were interested in becoming involved in a wider discussion about energy, some noting that Scotland and the rest of the UK could decide to reduce its dependence on nuclear power and/or replace older technological installations with newer, more efficient, clean ones.

7.16 The key finding here is not that participants had clear views about the best way forward, but that they were aware that the technology could advance significantly and that appropriate ways of informing and engaging the public would be needed in the long-term. Thereby ensuring decisions are taken in the public interest, rather than by assuming that government, the nuclear industry or even independent experts know best. True engagement was thought to emerge from a continuing process of involvement rather than a series of snapshot consultation events.

Resourcing Engagement

7.17 Making a commitment to engage the public in the long-term has resource implications, including time, money and investing in people's skills. Evaluation is needed to identify the most appropriate and effective use of these resources for organisations undertaking this type of engagement.

Inter-generational engagement

7.18 Participants felt that the issue of radioactive waste needed to be considered by decision-makers at all level, from the neighbourhood to international agreements, as well as over time. Feeling that they could not bind future generations to a solution that may be inadequate (because of future technological advances for example), participants wanted to see a commitment to public engagement stretching beyond the lifetime of any one elected parliament and beyond their own life times.

Strengthening public engagement

Quality Assurance

7.19 Successful engagement points to appropriate feedback and "proof of being listened to" as a basic requirement. This is essential if engagement is to lead to opportunities to influence decisions. Participants stated that bodies undertaking consultation and involvement processes need to demonstrate an ability to listen and respond to their views if they are to be persuaded of their validity. Very little is known about the impact of consultation and engagement processes. We believe there needs to be a systematic evaluation of government performance in providing information, undertaking consultation and engaging citizens in policy making by government agencies if public engagement exercises are to build confidence and legitimacy on all sides.

7.20 Strengthening relations between citizens and government represents a sound investment in building civil society. However, we are still at an early stage on the learning curve towards a society where politically mature and active citizens can work with government and other agencies determined to engage the public more closely in setting policy in a variety of areas. Very little is documented which sets out the terms of engagement of consulting bodies and those who actively participate. Meaningful involvement requires clarity around roles and responsibilities for all involved, and potentially a shift in the decision-making process towards communities and individuals.

7.21 Traditional means of engagement, using published government consultation documents to seek responses from interested members of the public and key stakeholders, is not always the most appropriate method. Where there are issues of a technical nature or that require ongoing deliberation, rather than the presentation of well-developed views, it is important to choose the most effective process of engagement. Some consultation issues require a level of expertise that the public does not have and cannot communicate in ways that organisations are able to. In these cases, sticking with traditional methods is likely to be disappointing, frustrating and engender a lowering of expectations on all sides. We believe the approach taken by the Scottish Executive in commissioning this study takes us closer to a more appropriate way of engaging the public and other stakeholders on complex issues.

7.22 While members of the public are more motivated to engage with issues rather than processes, it is important to make the process as transparent and open as possible. In the 'unaffected public' focus group, participants were recruited without knowing the theme of the meeting. They may have been attracted by the general reference to "an issue of long-term significance", the fact that the Scottish Executive had commissioned the study or by having their time and expenses covered. Some of these participants said that they would have been unlikely to take part in a public meeting about radioactive waste.

7.23 No consistent set of definitions is applied to ways of enabling the public to explore significant issues and express their views more effectively. "Engagement", "consultation", "involvement" and "participation" have tended to be used interchangeably, despite meaning different things to consulting bodies and those engaged in the process. Re-branding of traditional consultation approaches as "engagement" even by default can only exacerbate the problems. Consistency in language across Government, its agencies and other organisations in the private and voluntary sectors, is important to help create a higher level of understanding about what is being proposed and why, the role of each participant, how decisions will ultimately be reached and by whom. The existing body of knowledge should be developed around the notion that the process of public engagement encompasses information provision, consultation and involvement leading to ongoing participation and delegation (shared decision-making).

7.24 Additional research is needed to help the Scottish Executive and others involved in engaging the public to manage the converging trends of growing demand for public involvement and rapidly evolving information technology. The issues of access, equity, learning, accountability, and management of information should be considered to help anticipate and respond to the challenges of providing accessible, understandable and interactive engagement processes posed by increased use of electronic participation. This would allow the identification of appropriate opportunities and recommendations as to how these should fit into an overall strategy for civic participation. We would note that the Internet could be a powerful tool for wider engagement, but it is not a process in itself. Continued reliance on conventional methods of consultation through hard copy or web-based materials will make inclusion difficult for those facing literacy, language or technology barriers. As a minimum, the quality of on-line content should be continually enhanced and actual as opposed to potential effectiveness properly evaluated.

Responsibility for action

7.25 Current structures provide a variety of ways for the public to become engaged in decision-making processes. There was energy and enthusiasm from participants in this study about becoming engaged and a lack of knowledge from the general public of current engagement structures. It is important to develop a culture of engagement based on the 'values' described, knowledge, relevance, transparency, dialogue, trust and full disclosure, rather than focussing only on structures for engagement.

7.26 Participants expressed a sense of responsibility, alongside government and the industry, for becoming involved in finding the safest possible approach to managing radioactive waste available to us at any time. Some were also willing to take the initiative in sharing information with others. Participants in the Young People's group, for example, concluded that peer education is an important way of engaging other young people. However, participants did not assume the process of securing agreement and raising awareness would be easy. There was a strong desire for responsibility to be located with bodies able to take decisive and legitimate action. The findings of this study suggests all stakeholders should reconsider the responsibilities expected of them:

• Government needs to demonstrate it acts in the public interest and with due regard to what has been called the 'precautionary principle', particularly on matters of safe management of radioactive waste. Those undertaking engagement processes need to be aware of the skills and capacity issues required to do so effectively. A relative lack of evaluation suggests the need to set up an appropriate framework for evaluation linked to a holistic set of performance measures (including feedback and forward links to future action).
• Agencies charged with regulatory powers must be sufficiently independent of government and the industry to inspect and advise, and must demonstrate willingness to use its full range of powers if necessary.
• The nuclear industry has a responsibility to communicate its actions fully and to be open to scrutiny.
• Environmental NGOs have a particular responsibility, given their position as the most trusted sources of information and perceived role as protecting the public interest more effectively than others. While NGOs are influential advocates of how energy policy should change in future, this should not prevent them from fully engaging with government and the industry, as well as public and media campaigning, on how best to address current dilemmas.
• All stakeholders have a responsibility to engage the wider public in an informed way, helping to develop relations with media commentators about the long-term as well as immediate challenges.
• The media has a responsibility to promote understanding of the strategic options facing Scotland and the rest of the UK on how to manage radioactive waste and shape future energy supply, in addition to the 'fire-fight' reporting of short-term events.

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