Geological Disposal

A Proposed Approach to StrategicEnvironmental Assessment duringMRWS Stage 4

December 2010

NDA Technical Note no. 13824468

Geological Disposal

NDA Technical Note no. 13824468

A Proposed Approach to StrategicEnvironmental Assessment duringMRWS Stage 4

December 2010

CONDITIONS OF PUBLICATION

This report is made available under the NDA Transparency Policy. In line with this policy, the NDA is seeking to make information on its activities readily available, and to enable interested parties to have access to and influence on its future programmes. The report may be freely used for non-commercial purposes. However, all commercial uses, including copying and re-publication, require permission from the NDA. All copyright, database rights and other intellectual property rights reside with the NDA. Applications for permission to use the report commercially should be made to the NDA Information Manager.

Although great care has been taken to ensure the accuracy and completeness of the information contained in this publication, the NDA can not assume any responsibility for consequences that may arise from its use by other parties.

© Nuclear Decommissioning Authority 2010. All rights reserved.

BIBLIOGRAPHY

If you would like to see other reports available from NDA, a complete listing can be viewed at our website www.nda.gov.uk, or please write to the Library at the address below.

FEEDBACK

Readers are invited to provide feedback to the NDA on the contents, clarity and presentation of this report and on the means of improving the range of NDA reports published. Feedback should be addressed to:

John Dalton, Head of Communications, Nuclear Decommissioning Authority (Radioactive Waste Management Directorate), Curie Avenue, Harwell Campus, Didcot, Oxon, OX11 0RH, UK.

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Executive Summary

The Managing Radioactive Waste Safely (MRWS) White Paper contains a commitment from Government to fully assess and account for environmental and sustainability issues in the geological disposal programme through the application of Strategic Environmental Assessment (SEA), Sustainability Appraisal (SA) and Environmental Impact Assessment (EIA).

A high level approach to this work is outlined in the NDA’s Strategy for Sustainability Appraisal and Environmental Assessment. The Strategy proposes that during MRWS Stages 1 to 3, a generic (i.e. not site-specific) assessment be carried out to help identify the potential environmental and socio-economic effects of implementing a geological disposal facility (GDF). This work has now been completed and is being used to inform the development of disposal system concepts and to provide information to communities that have expressed an interest (or are considering expressing an interest) in participating in the site selection process and in hosting a disposal facility.

The Strategy also proposes that during MRWS Stage 4, a more detailed assessment be carried out, considering how a GDF could be implemented in each potential host community. Unlike the generic assessment work, this will include information about specific areas and/or sites. It will be fully compliant with the SEA Regulations and, again, will incorporate socio-economic assessments to ensure relevant sustainability issues are covered.

This Technical Note presents a proposed approach / technical methodology for the SEA during MRWS Stage 4 and provides the basis for developing a “Scoping Report” which will be used for consultation with external stakeholders on the scope of / approach to the SEA following a Decision to Participate.

It is important to note that SEA is a process and not a product. The product is a better strategic decision (expressed as an adopted plan or programme), supported by a record of the SEA in the form of an environmental report and by post adoption information explaining how both the SEA and consultation feedback have influenced plan or programme development.

Key characteristics of the “geological disposal implementation plan” that have had a particular bearing on the proposed approach include:

• the principle of volunteerism and the decision making process for site selection;

• the relatively detailed (site-specific) baseline information that is likely to be available for the SEA;

• the relatively detailed information that is likely to be available on the design, construction and operation of a disposal facility, albeit much of this information is likely to remain illustrative until future stages of the implementation plan;

• the long timescales over which a geological disposal facility would operate – probably well into the next century - and the very long (post closure) timescales considered by radiological safety assessments.

The key recommendations for the SEA are:

• it will be based on the procedural stages described in ODPM Guidance on SEA, suitably tailored to the geological disposal implementation plan;

• it will be baseline-led, with no requirement to define SEA objectives or to evaluate the implementation plan against such objectives;

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• it will adopt a relatively detailed, objective and quantitative approach, reflecting the level of baseline information likely to be available, a well defined plan (and project) definition and the requirement to support the site selection process;

• where possible, the significance of potential effects will be assessed by considering the importance (or sensitivity) of affected resources and receptors, and the magnitude of the effect;

• “reasonable alternatives” to be considered by the SEA will be defined as the potential candidate sites for implementing geological disposal offered by / agreed with participating communities, together with the alternative approaches to site investigation, alternative concept designs and alternative waste transport options relevant to those sites. Scenarios will be considered that take into account possible changes to the radioactive wastes and materials that might be placed in a GDF. The baseline definition, i.e. what would happen if geological disposal was not implemented, will also be considered;

• alternatives to geological disposal will be kept under review, as required by the MRWS White Paper. These alternatives will not be subject to assessment as part of the SEA, but the review findings will provide essential context for both the SEA and development of the implementation plan;

• the relative merits of alternative sites will be considered within the MRWS site selection process. The environmental and socio-economic assessment work undertaken for the SEA will feed relevant information into the site selection process as required;

• consultation on the SEA and on a draft implementation plan for geological disposal will be carried out as part of the decision making process at the end of MRWS Stage 4;

• the draft plan will propose a series of co-ordinated activities to implement geological disposal of higher activity radioactive waste, based on a voluntarism/partnership approach to site selection. Implementation of the plan will start with surface based investigations at one or more candidate site(s)before moving on to subsequent underground investigation at the preferred site to confirm it’s suitability; the draft plan will also include construction, operation, closure and post closure phases of the proposed disposal facility and its associated infrastructure.

• a mitigation register will be used to track environmental and socio-economic issues and to provide an audit trail for decisions made on proposed mitigation and enhancement measures;

• a Health Impact Assessment will be carried out as part of the SEA;

• a Habitats Regulations Assessment will be carried out in parallel with the SEA, but using common baseline data and providing inputs as required to the SEA biodiversity assessment.

Following review, finalisation and agreement of the proposals in this Technical Note, a “generic” scoping report for the SEA will be drafted in preparation for the start of MRWS Stage 4. Following a decision by one or more communities to participate in the MRWS process the scoping report will be updated in the light of area / site-specific baseline information and will then be subject to consultation before substantive work on the formal SEA begins.

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List of Contents

1 Introduction 1 1.1 What is SEA? 1 1.2 SEA in context 2 1.3 Structure and content of the Technical Note 3 2 Regulatory Requirements 5 2.1 Consulting on the scope and level of detail 5 2.2 Carrying out the assessment 5 2.3 Dealing with alternatives 6 2.4 Reporting the assessment 6 2.5 Consulting on the draft plan or programme 7 2.6 Decision making 8 2.7 Monitoring plan or programme implementation 8 2.8 Who carries out the SEA? 8 3 Published Guidance 9 3.1 European Commission Guidance 9 3.2 ODPM Guidance 10 3.3 DfT Guidance 12 3.4 DCLG study on the efficient and effective use of SEA and SA 13 3.5 EA Guidance 14 4 Links to Other Work Streams 15 4.1 NDA Strategy II 15 4.2 The Site Selection Process 15 4.3 Disposal System Safety Case 16 4.4 Preparatory Work for Surface Investigations 17 4.5 Geological Disposal Concept Options 17 4.6 Disposal System Development 18 4.7 Transport Assessment 19 4.8 Habitats Regulations Assessment 19 4.9 Health Impact Assessment 20 5 Technical Issues and Approaches to the Assessment 21 5.1 Level of detail 21 5.2 Baseline definition 22 5.3 Plan definition 22 5.4 Project definition 23

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5.5 Defining reasonable alternatives 23 5.6 Predicting effects 25 5.7 Evaluating effects 26 5.8 Mitigation and enhancement 27 5.9 Dealing with uncertainty 28 6 Proposed Approach to the SEA 29 6.1 Stage A: Setting the context, establishing the initial baseline and deciding on the

scope of work 29 6.2 Stage B: Developing and refining alternatives and assessing effects 30 6.3 Stage C: Preparing the Environmental and Sustainability Report 33 6.4 Stage D: Consulting on the draft plan and the Environmental and Sustainability

Report 34 6.5 Stage E: Monitoring plan implementation 35 6.6 Quality Assurance checklist 35 7 Recommendations and Next Steps 40

References Appendix A: Proposed outline of the “draft plan” for implementing geological disposal Appendix B: Indicative list of baseline information requirements

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1 Introduction

The Managing Radioactive Waste Safely (MRWS) White Paper1 contains a commitment from Government to fully assess and account for environmental and sustainability issues in the geological disposal programme through the application of Strategic Environmental Assessment (SEA), Sustainability Appraisal (SA) and Environmental Impact Assessment (EIA).

A high level approach to this work is outlined in the NDA’s Strategy for Sustainability Appraisal and Environmental Assessment2. The Strategy proposes that during MRWS Stages 1 to 3, a generic (i.e. not site-specific) assessment be carried out to help identify the potential environmental and socio-economic effects of implementing a geological disposal facility (GDF). This work has now been completed and is being used to inform the development of disposal system concepts and to provide information to communities that have expressed an interest (or are considering expressing an interest) in participating in the site selection process and in hosting a disposal facility3.

The Strategy also proposes that during MRWS Stage 4, a more detailed assessment be carried out, considering how a GDF could be implemented in each potential host community. Unlike the generic assessment work, this will include information about specific areas and/or sites. It will be fully compliant with the SEA Regulations4 and, again, will incorporate socio-economic assessments to ensure relevant sustainability issues are covered.

The environmental and socio-economic assessment work during MRWS Stage 4 will be used in local decision making about whether or not to continue participation in the site selection process and in national decision making on which candidate sites to investigate further in MRWS Stage 5. It will also be used to support consultation on, and subsequent adoption of an implementation plan for geological disposal.

This Technical Note:

• provides a vehicle for discussing and agreeing a detailed approach / technical methodology for the SEA work;

• highlights links and interdependencies between the SEA and other NDA / RWMD work areas so that the SEA and related work can be effectively co-ordinated and managed;

• provides a framework for developing a “Scoping Report” which will be used for formal consultation with external stakeholders on the scope of / approach to the SEA.

1.1 What is SEA?

In 1996 Sadler and Verheem5 defined SEA as

…a systematic process for evaluating the environmental consequences of proposed policy, plan or programme initiatives in order to ensure they are fully included and appropriately addressed at the earliest appropriate stage of decision making…

With the advent of sustainability appraisal (particularly in relation to spatial planning and the new National Policy Statements) and the UK’s approach to Sustainable Development, there has been a gradual move towards more integrated assessments considering socio-economic as well as environmental issues.

The overall aim of SEA is to help people make better strategic decisions - “better” in the sense that decisions are aligned with (or at least informed by) the principles of environmental protection and sustainable development.

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It is important to note that SEA is a process and not a product. The product is a better strategic decision (expressed as an adopted plan or programme), supported by a record of the SEA in the form of an environmental report and by post adoption information explaining how both the SEA and consultation feedback have influenced plan or programme development.

In July 2001 the SEA Directive6 was adopted. It came into force in July 2004, making SEA a legal requirement within the EU for certain strategic plans and programmes. Article 1 of the Directive states:

The objective of this Directive is to provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development, by ensuring that, in accordance with this Directive, an environmental assessment is carried out of certain plans and programmes which are likely to have significant effects on the environment.

The requirements of the Directive have been implemented in England, Wales and Northern Ireland through the Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations) and in Scotland through The Environmental Assessment (Scotland) Act 20057. In Scotland the scope of SEA has been widened to include the assessment of policies and strategies, as well as plans and programmes.

1.2 SEA in context

Environmental assessment is (or should be) a continuous, tiered process, from policy level, through the development of strategies, plans and programmes to the promotion of individual projects. Progressively more detailed analysis is required at each stage with successive assessments building on the work that preceded them. Figure 1.1, taken from the Environment Agency’s SEA Toolkit8 illustrates the process:

Figure 1.1 SEA in Context

Source: re-drawn from http://www.environment-agency.gov.uk/static/documents/Research/SEA-EIA_Diagram_25_6_09(1).pdf

SEA can be undertaken at a number of different levels and in varying degrees of detail. At the policy level it is often not possible for an SEA to provide anything more than a series of qualitative comments against broadly defined evaluation criteria, sometimes augmented by a simple “traffic light” or +/- scoring system. These comments are usually supported by an extensive evidence base but are, nevertheless, inherently subjective and reliant on professional judgement. That said, simple subjective analysis may be all that’s needed to identify a key issue and to inform a strategic decision making process.

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At the more detailed level of plans or programmes, there is an expectation that more detailed (and possibly more objective) assessments will be undertaken. This is recognised in the European Commission’s guidance on SEA9 which states that:

…in the environmental report for a broad-brush plan or programme, very detailed information and analysis may not be necessary; whereas much more detail would be expected for a plan or programme that itself contained a higher level of detail.

At an individual project level, at least for most major projects, a very detailed assessment is usually required in the form of an Environmental Impact Assessment (EIA) carried out under the UK EIA Regulations10. This process ensures that the environmental implications of project implementation are fully understood before planning permission is granted. The Strategy for Sustainability Appraisal and Environmental Assessment proposes that EIAs are undertaken during Stages 5 and 6 of the MRWS site selection process – for both intrusive surface investigations (which may require separate planning permission) and for implementation of a geological disposal facility at a specific site (or sites).

There is not always a clear boundary between SEA and EIA, particularly where a strategy, plan or programme proposes quite specific projects and /or quite specific locations for projects. In such cases, the sustainability and environmental assessment work for the EIA may simply be a development and update of that undertaken for the SEA. The key difference in such cases is that SEA considers strategic alternatives or options, whereas EIA generally considers only a single (proposed) option. However, the EIA Regulations require that in reporting the assessment an outline of the alternatives considered is provided, together with reasons for choosing the proposed option.

During Stage 4 of the MRWS site selection process a number of discrete areas / sites will be identified where a geological disposal facility might be located and the nature of such a facility will be reasonably well defined. Therivel11 considers the assessment problem posed by “high level strategic actions that also propose quite specific projects, often ‘in the national interest’”. She notes that the choice of where to put a project should be influenced by assessment of the different effects it would have in different places. This implies a more detailed level of assessment than is the norm for SEA – perhaps something closer to an EIA. However, the assessment for geological disposal will still be strategic in nature because several strategic options will still be under consideration (different locations for implementing geological disposal, alternative approaches to site investigation programmes, different waste transport options, different disposal facility concepts and so on).

1.3 Structure and content of the Technical Note

In Section 2 the requirements for compliance with the SEA Directive are set out, including key stages and regulatory milestones in the SEA process.

Section 3 provides an overview of guidance documents on SEA, particularly those from Government departments and regulatory authorities. These provide guidance on how the SEA Directive should be interpreted and implemented.

There are a number of important links and interdependencies between SEA and other NDA / RWMD work streams – notably the MRWS site selection process, development of the Disposal System Safety Case, engineering design development and transport assessment. Section 4 highlights these links and associated information flows between the different work areas.

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Section 5 discusses technical approaches to the various elements of SEA and suggests which of these may be most appropriate for MRWS Stage 4. Issues considered include:

• the level of detail for the assessment work;

• how the baseline for the assessment will be defined;

• how the plan to be assessed will be defined;

• how the geological disposal project will be defined;

• how strategic alternatives for consideration in the SEA will be developed and defined;

• the prediction and evaluation of environmental and socio-economic effects;

• the development of mitigation and enhancement measures;

• dealing with uncertainty;

• reporting the outcome of the SEA and monitoring predicted effects.

Section 6 builds on the previous sections to propose an overall approach to the SEA, based on the assessment stages identified in A Practical Guide to the Strategic Environmental Assessment Directive (ODPM, 2005):

• Stage A: Setting the context and objectives, establishing the baseline and deciding on the scope;

• Stage B: Developing and refining alternatives and assessing effects;

• Stage C: Preparing the Environmental Report;

Consulting and decision making; •

• or programme.

Section 6 also maps the proposed approach onto the regulatory requirements, using the

Stage D: Stage E: Monitoring implementation of the plan

quality assurance checklist provided in the ODPM Guidance.

Finally, Section 7 highlights key recommendations for the SEA and sets out how the work will be taken forward to the initial scoping stage.

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2 Regulatory Requirements

As noted in Section 1.1, SEA became a legal requirement for certain plans and programmes (likely to have a significant environmental effect) in 2004 following publication of the SEA Directive and transposing UK regulations. The key requirements of the Directive are detailed below.

2.1 Consulting on the scope and level of detail

Article 5(4) requires that:

The authorities referred to in Article 6(3) shall be consulted when deciding on the scope and level of detail of the information which must be included in the environmental report

Article 6(3) leaves it to member states to designate the consultation authorities and in the UK these are defined in the SEA Regulations as being:

• England: the Environment Agency, Natural England (formerly the Countryside Agency and English Nature) and English Heritage;

• Northern Ireland: the Department of the Environment’s Environment and Heritage Service;

• Scotland: Historic Scotland, Scottish Natural Heritage and Scottish Environmental Protection Agency;

• Wales: cadw (Welsh Historic Monuments), Countryside Council for Wales, and the Environment Agency Wales.

There is no requirement in the Directive for wider consultation on the scope of the SEA, although it is now common practice to include non-government organisations and the general public. For example, the NDA’s SEA Scoping Report for the UK Nuclear Low Level Waste Strategy12 (2008) and the Department for Energy and Climate Change’s (DECC’s) proposed scope for the SEA of the Severn Tidal Power scheme13 (2009) were both subject to public consultation, with the responses being published shortly afterwards.

It should be noted that the SEA Protocol came into force in July 2010 and that the European Union is a signatory. The Protocol places special emphasis on the consideration of human health issues and, consequently, it is possible that the SEA Directive (and enabling UK legislation) may have to change to include consultation with health bodies.

2.2 Carrying out the assessment

Articles 3(1) and 4(1) of the Directive require an environmental assessment to be carried out during preparation of the plan or programme and before the plan or programme is adopted. Although the scoping process will determine those topics that should be considered during the assessment, Annex II of the Directive provides some guidance on both the characteristics of the plan / programme and of the area likely to be affected that should be taken into account. These include:

1. The characteristics of plans and programmes, having regard, in particular, to

• the degree to which the plan or programme sets a framework for projects and other activities, either with regard to the location, nature, size and operating conditions or by allocating resources,

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• the degree to which the plan or programme influences other plans and programmes including those in a hierarchy,

• the relevance of the plan or programme for the integration of environmental considerations in particular with a view to promoting sustainable development,

• environmental problems relevant to the plan or programme,

• the relevance of the plan or programme for the implementation of Community legislation on the environment (e.g. plans and programmes linked to waste-management or water protection).

2. Characteristics of the effects and of the area likely to be affected, having regard, in particular, to

• the probability, duration, frequency and reversibility of the effects,

• the cumulative nature of the effects,

• the transboundary nature of the effects,

• the risks to human health or the environment (e.g. due to accidents),

• the magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected),

• the value and vulnerability of the area likely to be affected due to:

• special natural characteristics or cultural heritage,

• exceeded environmental quality standards or limit values,

• intensive land-use,

• the effects on areas or landscapes which have a recognised national,

Under Article 5(1) assessing the likely significant effects of implementing the plan or ount

selecting

Article 5 of the Directive sets out the requirement to produce an “environmental report”

a) an outline of the contents, main objectives of the plan or programme and relationship

b) vironment and the likely evolution

c) icantly affected;

Community or international protection status.

2.3 Dealing with alternatives

programme must include consideration of “any reasonable alternatives taking into accthe objectives and geographical scope of the plan or programme”. This is normally an iterative process with the assessment work feeding back into plan or programme development. There is also a requirement to provide “an outline of the reasons forthe alternatives dealt with”. This means that some form of audit trail is required that explains and justifies the shortlist of alternatives that have been selected for assessment.

2.4 Reporting the assessment

documenting the results of the assessment work. Annex 1 of the Directive lists the information to be provided:

with other relevant plans and programmes;

the relevant aspects of the current state of the enthereof without implementation of the plan or programme;

the environmental characteristics of areas likely to be signif

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d) any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC[ ]1 ;

e) the environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation;

f) the likely significant effects (1) on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors;

g) the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme;

h) an outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information;

i) a description of the measures envisaged concerning monitoring in accordance with Article 10;

j) a non-technical summary of the information provided under the above headings.

2.5 Consulting on the draft plan or programme

Article 6(1) requires that:

The draft plan or programme and the environmental report prepared in accordance with Article 5 shall be made available to the authorities referred to in paragraph 3 of this article and the public.

In the UK the authorities referred to are defined in the SEA Regulations and are as listed in Section 2.1 above.

Article 6(2) goes on to state that:

The authorities……..and the public….. shall be given an early and effective opportunity within appropriate time frames to express their opinion on the draft plan or programme and the accompanying environmental report before the adoption of the plan or programme…

Neither the Directive nor the SEA Regulations define specific consultation periods. However, EC Guidance on the Directive notes that:

Different time frames may be appropriate for different types of plan or programme but care should be taken to allow sufficient time for opinions to be properly developed and formulated on lengthy, complex, contentious or far reaching plans or programmes. Adequate time will also be needed for the planning authority to take these views into account before deciding on the plan or programme. Sometimes

1 The EU Bird’s Directive and the EU Habitats Directive respectively.

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requests for additional information may be made and the time frame for consultation may also need to take into account the time for the responsible authority to respond.

Article 7 requires that:

Where a Member State considers that the implementation of a plan or programme being prepared in relation to its territory is likely to have significant effects on the environment in another Member State, or where another Member State so requests……

…..then the Member States shall enter into consultations before the adoption of the plan or programme.

Article 7 also notes that Member States entering into such consultations shall agree on a reasonable timeframe for their duration.

2.6 Decision making

Article 8 requires that the findings of the SEA and the opinions expressed during consultations are taken into account during preparation of the plan or programme and before its adoption.

Article 9 requires that the plan or programme, as adopted, is made available to the public, together with a statement explaining how the findings of the SEA and consultation responses were taken into account in the decision making process. The reasons for choosing the plan or programme, as adopted, must be explained in the light of the other reasonable alternatives considered.

2.7 Monitoring plan or programme implementation

Article 10 requires implementation of the plan or programme to be monitored from an early stage to identify any unforeseen effects and in order to undertake appropriate remedial action if needed. Article 9 requires that the proposed monitoring measures be included in the statement explaining the decision to adopt the plan or programme.

2.8 Who carries out the SEA?

Neither the Directive nor Regulations specify who should carry out SEA. But, the obligation to ensure that an SEA is carried out lies with the “responsible authority” which produces the “plan or programme” . It is assumed that for the geological disposal implementation plan the role of “responsible authority” will be undertaken by the Secretary of State and NDA.

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3 Published Guidance

The European Commission, Government, regulatory authorities, professional bodies and academic institutions have all published guidance on SEA and its application to various types of plans and programmes. The most relevant for the geological disposal implementation plan is described below, noting key points in relation to the proposed work during stage 4 of the MRWS site selection process.

3.1 European Commission Guidance

In 2002, the EC published guidance on implementing the SEA Directive. The guidance is particularly useful for interpreting the terms used in the Directive and for explaining the relationship between the plan or programme and the environmental report. Terms of particular relevance to Stage 4 of the MRWS site selection process are “plans and programmes” and “reasonable alternatives”.

Plans and programmes

Article 2 of the SEA Directive states:

’plans and programmes’ shall mean plans and programmes, including those co-financed by the European Community, as well as any modification to them:

- which are subject to preparation and/or adoption by an authority at national,regional or local level or which are prepared by an authority for adoption, through a legislative procedure by Parliament or Government, and

- which are required by legislative, regulatory or administrative provisions.

The EC Guidance notes that:

…..plans and programmes are not further defined. The words are not synonymous but they are both capable of a broad range of meanings which at some points overlap. So far as the Directive’s requirements are concerned, they are treated in an identical way. It is therefore neither necessary nor possible to provide a rigorous distinction between the two. In identifying whether a document is a plan or programme for the purposes of the Directive, it is necessary to decide whether it has the main characteristics of such a plan or programme. The name alone ('plan', 'programme', 'strategy', 'guidelines', etc) will not be a sufficiently reliable guide: documents having all the characteristics of a plan or programme as defined in the Directive may be found under a variety of names.

The kind of document which in some Member States is thought of as a plan is one which sets out how it is proposed to carry out or implement a scheme or a policy. This could include, for example, land use plans setting out how land is to be developed, or laying down rules or guidance as to the kind of development which might be appropriate or permissible in particular areas, or giving criteria which should be taken into account in designing new development.

In some Member States, programme is usually thought of as the plan covering a set of projects in a given area, for example a scheme for regeneration of an urban area, comprising a number of separate construction projects, might be classed as a programme. In this sense, 'programme' would be quite detailed and concrete.

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A plan or programme is clearly thought of in terms of “a document” although little guidance is given on its form or content. The guidance does note, however, that the Directive defines the environmental report as “a part of the plan or programme documentation with a specified content”. It also notes that the Directive does not specify whether the report should be integrated in the plan or programme itself or produced as a separate document.

The EC Guidance also notes that implementation of a plan or programme may involve the implementation of one or more (often similar) projects (e.g. a road building programme) and that it “may include elements that are not project-related but are important to its success”.

Reasonable alternatives

The SEA Directive requires the likely significant effects of reasonable alternatives to be identified, described and evaluated. The EC Guidance notes that no distinction is made between the assessment requirements for different alternatives and states that “the essential thing is that the likely significant effects………are identified, described and evaluated in a comparable way”.

The Directive does not define “reasonable alternative” but the EC Guidance notes that:

In practice, different alternatives within a plan will usually be assessed (e.g. different means of waste disposal within a waste management plan……….). An alternative can thus be a different way of fulfilling the objectives of the plan or programme.

The Guidance also suggests that:

For plans or programmes covering long time frames, especially those covering the very distant future, alternative scenario development is a way of exploring alternatives and their effects.

Finally, the Guidance notes that alternatives should be “realistic” and must fall “within the legal and geographical competence of the authority concerned”.

3.2 ODPM Guidance

In 2005 the Office of the Deputy Prime Minister (ODPM) published A Practical Guide to the Strategic Environmental Assessment Directive14. It suggests five main stages for the SEA process (A-E) that are intended to be universally applicable in all sectors and geographies – see Figure 3.1.

The guidance also provides some useful advice on the level of detail in SEA, which is particularly relevant to the geological disposal implementation plan:

It is not usually appropriate in SEA, and is often impracticable, to predict the effects of an individual project-level proposal in the degree of detail that would normally be required for an EIA of a project. If, however, a plan or programme proposes a specific development or type of land-use for a particular area or location, the Environmental Report should include information which can reasonably be provided on the likely significant effects of that proposal and alternatives to it.

….and on broadening the scope of the assessment:

Responsible Authorities wishing to cover the full range of sustainable development issues in their assessments are free to broaden the scope of the assessment to include social and economic effects of their plans and programmes in addition to environmental effects.

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The stages suggested in the guidance, and the relationships between the various tasks are summarised in Figure 3.1.

Figure 3.1 Suggested stages in the SEA process (from ODPM Guidance)

Source: re-drawn from ODPM, 2005

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Although this staged approach is relatively prescriptive, the guidance does note that SEA should be treated as a flexible process, tailored to the scale, nature and needs of the different types of plans and programmes to which the Directive applies – while at the same time ensuring that the requirements of the Directive are met.

The guidance advocates the development of SEA objectives, noting they are a recognized way of considering the environmental effects of a plan or programme and of comparing alternatives. The guidance also advocates assessing environmental effects by considering the impact of the plan or programme on a defined baseline (i.e. the situation in the absence of the plan or programme). This “hybrid” approach to assessment, which attempts to be both “objectives-led” and “baseline-led” can be quite confusing. Jackson and Illsey15 note that this situation seems to have resulted from an “uneasy compromise” by policy makers which “seeks to retain the substantive benefits of proofing PPPs for compliance with official sustainability frameworks, whilst acknowledging the need for baseline studies to meet the procedural requirements of the SEA Directive”. This issue is discussed further in Section 3.4 below.

3.3 DfT Guidance

In April 2009, the UK Department for Transport (DfT) published (draft) guidance on SEA for transport plans and programmes16. The transport implications of geological disposal are an important consideration in the site selection process and in design development – in terms of both a disposal facility itself and any remote transport infrastructure that may be required.

The DfT guidance highlights the overlap in assessment methods for SEA where individual sites or projects have been identified, and project level EIA. In common with most approaches to EIA, the guidance suggests assessing the significance of predicted effects by considering the importance (or sensitivity) of affected resources or receptors and the magnitude of the effect. It also suggests using quantitative measures for the assessment where possible and appropriate.

The guidance notes that SEA for transport plans and programmes should be integrated with the Department for Transport’s New Approach To Appraisal (NATA)17. This is designed to prioritise proposals for major transport schemes by assessing their performance against high level Government objectives for transport, using associated sets of sub-objectives (evaluation criteria).

The DfT guidance adopts the same staged approach suggested by the ODPM guidance, although more detail is provided on possible technical assessment methods by reference to NATA.

A particularly useful appendix considers how to deal with certain aspects of uncertainty in an SEA. An important point made by the guidance is that “Decision-makers need information that is both correct and precise enough”. Defining an appropriate level of precision usually involves a trade off between being confident that the information is correct and having information that is precise enough to distinguish between the different options / alternatives being assessed.

In dealing with uncertainty the guidance also notes that the SEA should be “fit for purpose”. In other words, assessments should only be as precise as is necessary to inform the relevant decision. To some extent this will depend on the importance that decision makers attach to particular issues and/or the likelihood that certain indicators might go beyond a tolerable (or statutory) limit.

The guidance also notes the importance of communicating uncertainty and suggests using ranges / sensitivity analysis to describe predictions, using colours and symbols rather than figures, and clearly setting out assumptions that underpin the assessment work.

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3.4 DCLG study on the efficient and effective use of SEA and SA

In March 2010 the Department for Communities and Local Government (DCLG) published the results of a research study which considered how the efficiency and effectiveness with which SEA (and SA) is carried out might be improved in spatial planning work18. The study makes two recommendations, both subsequently accepted by DCLG, that are particularly relevant to the geological disposal implementation plan:

Recommendation 6: Plan impacts should be identified and evaluated with reference to the baseline situation.

To date, the identification and evaluation of impacts in SA/SEA has rested primarily on professional judgement. However, a more explicit focus on using baseline information to identify and evaluate impacts would be more in keeping with the requirements of the SEA Directive and the expectations of the SEA Consultation Bodies in particular.

In relation to an “objectives-led” approach resting largely on professional judgement the study notes a number of problems, including:

• difficulties in explaining the difference between SEA / SA objectives and plan or programme objectives to stakeholders;

• agreeing on the number of objectives that should be generated and the extent to which they assist in distinguishing between alternatives;

• concerns over the balance between environmental and socio-economic objectives;

• a sense that an objectives-led approach comes at the expense of an assessment against the baseline situation.

In contrast, the research suggests that a “baseline-led” approach could yield numerous benefits, including:

• an assessment more in keeping with the requirements of the SEA Directive

• an assessment more in keeping with the expectations of stakeholders (particularly the Consultation Bodies) in terms of impact identification and evaluation

• A shift away from a matrix-based methodology – the study notes a poor reputation among planners and stakeholders for Environmental Reports which is largely attributable to the preponderance of pages and pages of tables which make for large, inaccessible reports which contribute little to decision making.

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Recommendation 7: The level of detail the appraisal enters into should reflect the level of detail in the plan.

The level of detail an appraisal enters into should reflect the level of detail in the plan (i.e. it should be proportionate). For example, if a plan allocates sites, then the appraisal should consider impacts at the site scale. This has clear implications for the scope of the evidence base; for site level impacts to be evaluated, the evidence base would need to include site-level information.

In terms of the level of detail, the study findings mirror the advice in the ODPM guidance that if a plan or programme proposes a specific development in a specific location, then the level of detail in the assessment should reflect that.

3.5 EA Guidance

The Environment Agency (EA) has published comprehensive guidance and advice for SEA on their website19. They also advocate a baseline-led approach and suggest that assessing the effects of a plan or programme should involve:

Predicting the effects of the plan or programme on the environment….

• Identifying changes to the environmental baseline that are predicted to arise from the plan, programme and/or proposed alternatives.

• Describing these changes in terms of their magnitude, geographical scale, time period; permanent/temporary, positive/negative, probable/improbable, frequent/rare, direct/indirect, secondary, cumulative, synergistic.

Evaluating the predicted effects of the plan or programme on the environment….

• Determining the significance of predicted changes (beneficial or adverse) to the environmental baseline

• Identifying preferred environmental alternatives

The last point assumes that SEA is used as a decision making tool, which may not always be the case. For some plans and programmes an SEA is used to inform the decision making process but does not, itself, explicitly identify a preferred option or options. For the MRWS site selection process the main decision making tool for comparing the proposed locations for a facility will be a form of multi-criteria decision analysis. This analysis will consider a number of issues in addition to environmental and socio-economic factors, such as safety, technical challenges and cost. The relationship between SEA and the MRWS site selection process is discussed further in Section 4.

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4 Links to Other Work Streams

There are / will be several links and interdependencies between the SEA and other work streams. These are discussed below, highlighting the key flows of information between the different areas. In many cases the relationship between different work areas is an iterative one, with the SEA informing and influencing other work areas and vice versa. Careful thought will have to be given to the relative phasing of different work streams and when information will be needed.

4.1 NDA Strategy II

The NDA is required to periodically update and publish its strategy for carrying out its functions under the Energy Act (2004). The NDA’s current strategy was published in 2006. An updated strategy – “Strategy II” – was published in draft form for consultation in September 201020 with a view to finalising it no later than March 2011. Under the theme of Integrated Waste Management, various alternatives for the conditioning, storage, treatment and disposal of higher activity radioactive wastes have been considered. These alternatives include near surface disposal and geological disposal. An overarching SEA has been carried out for Strategy II which identifies, at a relatively high level, the potential environmental and sustainability effects of Strategy implementation. Part of this work has involved drawing on the NDA’s generic assessment work for a geological disposal facility referenced in Section 1 above. Strategy II notes that decisions on individual strategic options will be accompanied, where appropriate, by their own SEA and also notes that the SEA for geological disposal is under development. This “tiering” approach (see Section 1.2 above) ensures that an appropriate level of assessment is applied at the different planning levels of the NDA’s work, within a consistent framework and with clear, overarching objectives.

4.2 The Site Selection Process

SEA will be an important and integral component of the site selection process during MRWS Stage 4. The precise nature of the relationship has yet to be developed, but it will reflect the roles of the key parties during different parts of the process and how these roles relate to the requirements of the SEA Regulations and the site selection process. In any event, there will be a number of key points during Stage 4 when RWMD’s environmental and socio-economic assessment work will support and inform activities and decisions in this process:

The identification of potential candidate sites.

This is a process that will be led by participating communities early in MRWS Stage 4. RWMD is currently developing a national framework for the process (and for the subsequent assessment of potential candidate sites) and will consult on it during 2011. Although the national framework and how it would be applied at a local level have yet to be fully developed and agreed, it seems likely that the process would be subject to SEA – the identification of potential candidate sites may be seen to “set the framework for future development consent” (SEA Directive Article 3(2)).

The most effective way to approach this issue would be to include the process for the identification of potential candidate sites within the overall SEA for MRWS Stage 4. Relevant information from RWMD’s environmental and socio-economic assessment work could be discussed and agreed with participating communities and then fed into the process. RWMD would be available to support the process as needed.

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The assessment of potential candidate sites

Later in Stage 4, the SEA will feed information into the process for assessing the suitability of potential candidate sites (an NDA-led process).

For assessing the suitability of potential candidate sites the MRWS White Paper suggests six broad criteria that should be taken into account. These are:

1. geological setting 2. potential impact on people 3. potential impact on the natural environment and landscape 4. effect on local socio-economic conditions 5. transport and infrastructure provision 6. cost, timing and ease of implementation

In 2008 the NDA proposed that the assessment should be based on scoring sites against a number of more detailed criteria relevant to each of the main criteria21. Multi Criteria Decision Analysis (MCDA) could then be used to explore the differences between sites, the effects of uncertainty in data sets used for the assessment and the effects of differences of opinion between various stakeholders (e.g. in the way the evaluation criteria should be weighted).

The information needed for the assessment of potential candidate sites and to feed into the MCDA model would come from a number of sources. For the environmental and socio-economic criteria, much of the information would come from work underpinning the SEA.

Whatever the approach agreed, the environmental and socio-economic assessment work will be developed so that it satisfies both SEA requirements and those of the MRWS Stage 4 site selection process. The development of the site selection process and SEA will proceed in a co-ordinated way, with outputs from the assessment work being carefully defined against each SEA topic and each relevant site assessment criterion.

Decision making

At the end of Stage 4 the SEA will be used to inform local and national decisions about continued participation in the MRWS site selection process and which sites to take forward for surface investigations during MRWS Stage 5.

4.3 Disposal System Safety Case

NDA / RWMD has developed a generic safety case to demonstrate the safety of geological disposal, using a collection of arguments and evidence. Safety in the context of geological disposal addresses the packaging of radioactive waste, the transport of the waste to a disposal facility, the construction and operation of the facility and long term safety after the facility has been sealed and closed. Although the focus of the safety case is primarily radiological safety, it also addresses related chemo-toxic issues and relevant aspects of conventional safety.

Much of the information used to inform and support development of the safety case will also be used for the SEA. The safety case work has also generated information useful to the SEA - notably information on the potential environmental and health effects of predicted radiological and chemo-toxic dose rates. This information will be incorporated into the environmental and socio-economic assessment work. Figure 4.1 overleaf illustrates this process in relation to potential effects of disposal facility construction and operation on non-human biota.

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Conversely, the SEA work will generate environmental and socio-economic information relevant to biosphere characterisation for the on-going development of the safety case and, if relevant, proposed mitigation measures that may influence the safety case and / or some of its underlying assumptions (either directly, or through related changes to disposal concepts).

Figure 4.1 Incorporating radiological issues into the SEA

4.4 Preparatory Work for Surface Investigations

During MRWS Stage 4, the site characterisation work stream will provide information on proposed surface based investigations that would be carried out during Stage 5 of the MRWS site selection process both at a regional level and at remaining candidate sites. This will include information on non-intrusive work (e.g. airborne surveys, geophysical surveys and surface mapping) and on intrusive work such as borehole construction and associated testing and monitoring. Much of this information will be generic, but some will be site specific – reflecting different conditions and information requirements at different sites.

Conversely, the SEA will feed information on appropriate mitigation and monitoring measures into the design process for the site characterisation work.

4.5 Geological Disposal Concept Options

At the current stage of the MRWS process RWMD is examining a wide range of potentially suitable disposal concepts so that a well-informed assessment of options can be carried out at appropriate decision points22, 23. Drawing from this work, illustrative concepts have been set out for each of three generic geological settings, including the associated variants on overlying rocks. During MRWS Stage 4 these will be used to support scoping and

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assessment of the safety, environmental and socio-economic effects of implementing geological disposal. It is not intended that one of these illustrative concepts is necessarily the one that would be used in a relevant geological setting. As yet, no geological concept has been ruled out, although for the purposes of the SEA the assessment of environmental and socio-economic effects will be bounded by the range of concept options considered during MRWS Stage 4 as being broadly applicable to potential candidate sites.

4.6 Disposal System Development

RWMD’s engineering design work will provide information on the design of the disposal system (i.e. disposal facility and associated transport infrastructure), and on activities during its construction, operation and closure. This information will be collated into a “project definition” document that will inform much of the environmental and socio-economic assessment work (see section 5.4 below). As with the site characterisation work, much of this information will be generic, but some will be site-specific.

The iterative process of environmental assessment feeding back into disposal system development will help to ensure that development of the site characterisation work, disposal facility and its associated transport infrastructure take full account of environmental and socio-economic issues. However, this process is largely reactive and will not necessarily capture and address all of the environmental and sustainability issues associated with design development – particularly at a detailed level. To provide a more proactive input, sustainable design objectives will be built into the Disposal System Specification (i.e. the Disposal System Functional and Technical Specifications). This “twin track” approach is shown in Figure 4.2 and is discussed in more detail in RWMD technical note NDA/RWMD/1383521024. These objectives will be key assumptions underpinning the project definition and subsequent environmental and socio-economic assessment work.

Figure 4.2 Influencing disposal system development

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4.7 Transport Assessment

The current transport work streams within RWMD are geared towards meeting regulatory requirements for the carriage of dangerous goods. They are driven by the need to address radiological hazards associated with waste transport and to develop a robust safety case. Transport safety assessments are being carried out at both package specific and transport system levels. However, there is also a need for transport studies to support the SEA and, ultimately, to support applications for planning permission. Such work will have to consider a wide range of non-radiological issues at the various stages of GDF development. The first stage of this work will be a (strategic level) Transport Assessment (TA) carried out during MRWS Stage 4. This will focus on transport related land-use planning issues including effects on the transport network, access to community services, accident rates and so on. Transport Assessments also cover transport related environmental issues. DfT guidance25 suggests that where overlaps occur between environmental and transport assessment work, environmental effects should be dealt with as part of the environmental assessment, but cross referenced from the TA. Similarly, some transport related socio-economic effects are normally dealt with as part of an environmental assessment.

There are a number of important outputs from the TA that will feed into the SEA. These include information on transport movements (associated with the transport of waste packages and with non-radiological matters such as the transport of construction materials and site workers), effects on baseline travel patterns and accessibility, and compatibility of the transport proposals with local and national transport strategies and plans.

The relationship between the transport and environmental / socio-economic assessment work is discussed in more detail in RWMD technical note NDA/RWMD/1377250926.

4.8 Habitats Regulations Assessment

Under article 6(3) of the EU Habitats Directive27, as transposed in the UK by the Habitats Regulations28, “appropriate assessment” needs to be undertaken for any plan or project that:

• Either alone or in combination with other plans or projects would be likely to have a significant effect on a site designated within the Natura 2000 network – these are Special Areas of Conservation (SACs) and Special Protection Areas (SPAs) (Natura 2000 sites are also known as European Sites)

• Is not directly connected with the management of the site for nature conservation e.g. a site conservation plan.

Appropriate assessment is actually one of several iterative stages in the process of deciding whether or not a proposed plan or project will significantly affect the integrity or conservation objectives of European Sites. It is preceded by screening and scoping work and, if significant effects are judged likely, is followed by the consideration of alternatives. If no satisfactory alternatives can be found, or effective mitigation measures applied, then the proposal may only go ahead on the basis of “imperative reasons of overriding public interest”. In this case compensatory measures must be developed and implemented to maintain the integrity of the Natura 2000 network and the overall conservation status of affected flora and fauna. The whole process is referred to as a Habitats Regulations Assessment (HRA).

For the geological disposal implementation plan it has been assumed that, following an initial screening study, a (plan level) Habitats Regulations Assessment (HRA) will be undertaken alongside the SEA. Because it addresses a very specific regulatory requirement the HRA will be a discrete assessment process and will be reported as such. However, it will be properly co-ordinated with the SEA. It will consider potential effects on the Natura 2000 site network and associated protected species. It will also consider, as part of the baseline definition, existing environmental problems associated with such sites and feed this information into the SEA to satisfy the requirements of SEA Directive Article 5 d). This requires that any existing

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environmental problems relating to areas of particular environmental importance (such as Natura 2000 sites) should be noted in the environmental report.

The information requirements for the HRA will be in common with those for the biodiversity assessment topic for the SEA. The output from the HRA will also inform the SEA biodiversity assessment, although the latter will be much broader in scope, covering nationally designated wildlife sites and other nature conservation resources of more local interest.

Given that HRA is more of a “pass / fail” test than a comparison of options and that demonstrating “imperative reasons of overriding public interest” is a particularly onerous requirement, it is likely that HRA will be a key consideration during the early part of MRWS Stage 4 and in the identification of potential candidate sites.

4.9 Health Impact Assessment

The SEA Directive requires consideration of the likely significant effects of a plan or programme on human health. While the safety case work will address human health in terms of radiological and associated chemo-toxic issues, there are a number of non-radiological issues associated with implementing geological disposal that may have a health impact. The SEA will draw together both the radiological and non-radiological issues in the form of a Health Impact Assessment (HIA).

HIA is a means of assessing the likely health effects of plans, programmes and projects. In itself it is not a statutory requirement, but the ODPM Guidance on SEA (see Section 3.2) notes that “Responsible Authorities may find it helpful to draw on the methods of Health Impact Assessment when considering how a plan or programme might affect people’s health”.

Unlike the HRA, the HIA will be an integral part of the SEA and is likely to be presented as a technical appendix to the environmental report, with its findings integrated with the main report text as appropriate. The assessment will consider the wide range of factors that can influence health and well-being. It will consider potential effects on lifestyles (e.g. effects on diet / nutrition, education and learning opportunities); the physical environment (e.g. effects on living and working conditions, pollutant levels and public and worker safety); and access to services (e.g. effects on the provision of and access to health care, social services and leisure opportunities). It will consider the links between socio-economic and health issues (e.g. effects on employment and income levels and how these relate to well-being). It will also consider equality issues such as effects on discrimination, equality of opportunity and the relationship between different societal groups.

NDA / RWMD is currently developing detailed proposals for the HIA work and will ensure that it is properly co-ordinated with the safety case work and is fully integrated with the SEA.

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5 Technical Issues and Approaches to the Assessment

Published guidance on SEA (see Section 3) focuses on process (what to do) rather than technical methods (how to do it). This section discusses technical approaches to the various elements of SEA and considers what would be most appropriate for the geological disposal implementation plan.

5.1 Level of detail

As noted in Section 1.2, the assessment of effects in an SEA is often little more than a series of qualitative comments against defined evaluation criteria. The lack of focus on technical methods sometimes reflects a lack of detailed baseline and project design information on which to base a more objective / quantitative assessment (this is often the case for a plan or programme level study and for generic assessments). Also, it sometimes reflects a need to convey information effectively to a diverse range of stakeholders and a need to take on board their interests and sensitivities - something a detailed analytical approach may not allow. However, for contentious projects where the environmental and socio-economic effects are complex, a relatively rigorous (and replicable) approach to the assessment work may be needed. There is also an expectation that when SEA deals with specific projects and/or sites, more detailed assessments will be undertaken (see Section 3).

For Stage 4 of the MRWS site selection process there will be a defined project and a discrete number of specific areas or sites where the project might be implemented. In addition, to effectively support the site selection process (see Section 4.2), outputs from the sustainability and environmental assessment work at this stage will have to be:

• relevant to the site selection process and associated evaluation criteria

• detailed enough to distinguish between effects at the different sites

• detailed enough to highlight the degree of difference between sites

• detailed enough to allow the effective identification of key issues, but no more

• easy to understand by the wide range of stakeholders involved

The level of detail required will, to some extent, be influenced by those issues that participating communities and regulatory bodies see as being important – something that will be established during scoping work. For the more important issues, small differences between sites may have a significant bearing on site selection. Conversely, for less important issues even relatively large differences may have little bearing on site selection. Where an issue is not an important discriminator it may not be necessary to undertake a detailed analysis.

It is worth noting that CoRWM, in their response to the SA / EA strategy, stated that “Great care will be required in the selection of appropriate methodologies to ensure that the assessment of specific impacts in the SEA and EIA can be used in decision making.....”.

It is our intention to adopt a relatively detailed, objective and quantitative approach, but one which is transparent and “accessible” to a non-technical audience. To aid understanding and the ease with which outputs from the sustainability and environmental assessment work can be fed into the site selection process, we need to ensure an appropriate degree of consistency between assessment topics – in terms of both methodology and presentation.

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5.2 Baseline definition

The “baseline” is simply the situation in the absence of the proposed plan or programme, at any defined point in time. Baseline data provide a yardstick against which the predicted effects of the plan or programme can be compared - and useful context for assessing their significance.

The environmental and socio-economic assessment work during MRWS Stage 4 will be based largely on readily available baseline data, although some limited survey and modelling work may be undertaken to better define and characterise the baseline for certain topics. The level of information available will dictate, to a large extent, the level of detail possible for the technical assessments.

The baseline will be defined by considering the existing situation and identifying likely trends through time. It will reflect the different project phases and will focus on the period up to and including facility closure. It will consider other proposed developments and likely future changes to the environment within and around candidate sites for geological disposal.

Some consideration will be given to the longer term post-closure phase although the degree of uncertainty associated with baseline forecasting over very long periods of time is such that this is likely to be at a relatively high level. The safety case will consider geosphere and biosphere evolution over long time periods and this work will be used to inform development of a longer term baseline for the SEA.

A key consideration for the baseline definition will be the management of higher level radioactive waste in the absence of geological disposal. The NDA’s Strategy II, due for publication early in 2011, will provide a starting point for addressing this issue.

Much of the baseline data will be spatial and, once collected will be held in a Geographical Information System (GIS). The GIS will facilitate collation and presentation of spatial data for many of the assessment topics and will also be used to support the site selection process.

5.3 Plan definition

The SEA Regulations require the “draft plan or programme” to be published alongside the environmental report, as it describes the subject of the assessment work.

For the purposes of the SEA, the “draft geological disposal implementation plan” is defined as follows:

The draft plan proposes a series of co-ordinated activities to implement geological disposal of higher activity radioactive waste, based on a voluntarism/partnership approach to site selection. Implementation of the plan starts with surface based investigations at one or more candidate site(s)before moving on to subsequent underground investigation at the preferred site to confirm it’s suitability; the draft plan also includes construction, operation, closure and post closure phases of the proposed disposal facility and its associated infrastructure.

Thus the draft plan cannot be fully defined and adopted until after the decision making process towards the end of MWRS Stage 4 has been completed. This decision making process will be informed by the SEA as described in Section 4.2 above.

Geological Disposal: Steps towards implementation29, published in 2010, describes the preparatory work for geological disposal undertaken so far, the planning of RWMD’s future work and the management arrangements to deliver it. The report is intended to provide information to a wide range of interested parties on the steps RWMD believes will be

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required for successful implementation of geological disposal. For current purposes, this serves as the “draft plan” for implementing geological disposal.

As the implementation plan progresses and some of its current uncertainties are resolved, it will be revised to reflect significant developments in the planning of RWMD’s work and key decisions in the MRWS site selection process. In a revised form, supplemented with additional information, it will be published as part of the decision making process, with the environmental report included as an annex. Appendix 1 suggests a structure and outlines the possible content of the “draft plan” at that stage. An internal draft will be required earlier during Stage 4 to feed into the environmental and socio-economic assessment work.

5.4 Project definition

In order to complete the SEA, some technical information will be needed on the proposed site investigation work and on the design, construction, operation and closure of the GDF. Given the relatively early stage of plan development, much of this information will be based on assumptions and associated consideration of uncertainties (see Section 5.9 below).

This “project definition” will form an integral part of the “plan definition” and will provide information on topics such as the likely layout and footprint of surface facilities, the likely layout and footprint of underground facilities, the amount of spoil likely to be generated, the number of transport movements required for the delivery of construction materials / disposal of spoil, direct employment, likely requirements for remote transport infrastructure, the activities associated with each implementation phase, etc. This information will be collated from a number of different sources including engineering design reports, transport logistics work, site characterisation proposals and work on disposal concept options.

Work on-going through 2010/11 is being carried out to define the information requirements for the SEA, to identify the sources of that information (and any information gaps) and to produce an outline project definition document.

Even though candidate sites will have been identified, much of the project definition during MRWS Stage 4 is likely to remain illustrative. However, certain elements may be tailored to particular sites. For example: certain aspects of the proposed site characterisation work, layout of the surface facilities and associated site transport infrastructure.

5.5 Defining reasonable alternatives

The statutory requirement to include the assessment of “reasonable alternatives” in SEA, and to justify the selection of these alternatives, has often been problematic. Little guidance is available on what constitutes a “reasonable alternative” and SEAs have been successfully challenged for inadequately defining and assessing alternatives. In 2009 Hertfordshire County Council and St Alban’s District Council mounted a successful legal challenge to the East of England Plan on the basis the SEA had not considered reasonable alternatives to development in Green Belt30.

The Severn Tidal Power scheme (sponsored by DECC) was recently subject to an SEA and, in some respects, was similar to the geological disposal implementation plan. It considered the implementation of a tidal power project in the Severn estuary and looked at different options for implementation at a number of different locations within a defined geographical area31. Both the baseline and implementation options were relatively well defined and site-specific. From an initial long-list of ten, an initial screening process identified a short-list of 5 options which were defined as “reasonable alternatives” for the SEA. The feasibility of options on the long-list was assessed against a number of evaluation criteria based on technical risk, cost (vs amount of energy produced), value for money, environmental impacts and socio-economic impacts. Those considered unfeasible were discounted from further consideration.

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Unlike the Severn Tidal Power scheme (and most other examples), the geological disposal implementation plan is underpinned by the principle of voluntarism, established in the MRWS White Paper. This means that communities voluntarily express an interest in taking part in the process that will ultimately provide a site for a GDF. Participation up until quite late in the process, when underground operations are due to begin, is without commitment to further stages. During MRWS Stage 4 it is anticipated that Community Siting Partnerships will be set up, representing local community interests, to identify and evaluate candidate sites. RWMD’s role will be to support Partnerships and to ensure compliance with technical and regulatory requirements.

To ensure democratic accountability, Local Government in the form of a “Decision Making Body” will be responsible for major decisions within the site selection process. Such decisions will relate to issues such as continued participation in the process and the acceptability of proposed candidate sites for geological disposal. Decision Making Bodies are expected to take careful account of advice and recommendations from Community Siting Partnerships.

RWMD is currently developing a national framework for identifying potential candidate sites that could be used by potential host communities, adapted as necessary to reflect local issues and circumstances. Like the Severn Tidal Power project, the identification of potential candidate sites will involve a screening process. Initially, a sub-surface unsuitability test will be carried out by the British Geological Survey, based on defined sub-surface screening criteria. Areas not screened out by this test may then be subject to further screening based on a number of additional criteria. It has been suggested that these criteria should be based on those proposed in the MRWS White Paper for site evaluation (see Section 4.2 above), adapted as necessary to reflect local circumstances. In any case, Government, the communities involved in the MRWS process and RWMD will work together to agree how to consult on, develop and implement a framework for identifying potential candidate sites.

Given the principle of voluntarism, it would not be reasonable to consider sites other than those offered by and agreed with potential host communities. This in turn constrains both the site investigation programmes and the facility designs that might be suitable for the geology of these sites.

Notwithstanding these constraints, the “reasonable alternatives” likely to be considered include:

• different potential candidate sites for implementing geological disposal (for planning purposes it has been assumed that a total of 4 sites will be offered by / agreed with participating communities);

• alternative site investigation programmes at the different potential candidate sites;

• alternative concept designs for implementing geological disposal at the different potential candidate sites;

• alternative options for the transport of waste to the different potential candidate sites;

• different approaches to monitoring, mitigation and enhancement;

• the baseline definition, i.e. what would happen if geological disposal was not implemented (see Section 5.2 above).

These will be clearly defined and described as part of the plan and project definitions (see Sections 5.3 and 5.4 above).

Scenarios will also be considered that take into account possible changes to the radioactive wastes and materials that might be emplaced in a disposal facility. The MRWS White Paper provides an estimate – the “Baseline Inventory” – of the higher activity radioactive waste and other materials that might need to be managed in the future through geological disposal.

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However, it is recognised that there is uncertainty in this inventory, e.g. in relation to the estimates of wastes and materials that have not yet arisen and in relation to future operation of existing facilities (e.g. how long existing reactors will operate). Also, there may be wastes and materials not recognised in the inventory because they either exist but are not considered as wastes or because they will arise from future activities. This latter category includes wastes that could arise from a new build programme for nuclear power stations.

RWMD has therefore compiled an “Upper Inventory” to allow the implications of these uncertainties to be explored. However, this is not intended to be a maximum inventory and does not set out the largest inventory which could be disposed of in a GDF.

Alternatives to geological disposal will not be considered, other than through the baseline definition. However, as essential context for the SEA, the environmental report will include a description of the work undertaken in developing Government policy on the long term management of higher activity radioactive wastes - in particular, the work undertaken by the Committee on Radioactive Waste Management (CoRWM) on assessing waste management and disposal options32. It will also include a summary of the work undertaken to keep other disposal options under review – as required by the MRWS White Paper:

“Whilst Government policy is to pursue the geological disposal of higher activity radioactive waste, Government recognises the need to take account of developments in storage and disposal options, as well as possible new technologies and solutions. Future research and development may identify new options for dealing with some wastes, which under application of the waste hierarchy, could reduce the amounts of waste requiring disposal. The NDA will also keep options such as Borehole Disposal of certain types of waste under review. The cost implications of the various options explored will be estimated by the NDA as part of its work programme and Government will look to CoRWM to provide independent scrutiny and advice on the NDA research programme.”

5.6 Predicting effects

Likely environmental and socio-economic effects will be determined by considering how the baseline might change if the proposed plan is implemented.

Section 5.1 considers the level of detail appropriate for the SEA, concluding that a relatively detailed, objective and quantitative approach should be adopted. In terms of predicting effects a range of technical methods is available - many of these now being accepted as “industry standard” or “good practice”. Examples include methods detailed in the Institute of Ecology and Environmental Management Guidelines on Ecological Impact Assessment33, Institute of Environmental Management and Assessment Guidelines on Landscape and Visual Impact Assessment34 and in Volume 11 of the Highways Agency’s Design Manual for Roads and Bridges35. The latter relates specifically to highway schemes but many of the methods it describes for assessing environmental effects and their underlying principles are more widely applicable.

Many of these technical methods are routinely used in EIA rather than SEA. Notwithstanding the requirement for a relatively detailed approach, care will be needed to ensure that the level of assessment is appropriate to the strategic nature of the work and that unnecessary detail is avoided.

Given the flexibility it would provide in considering various transport and site scenarios, and that the level of baseline information likely to be available for waste transport options (national scale) may be less detailed than that available for the disposal facility itself (local scale), it is proposed that the assessment of waste transport options is carried out as a semi-independent exercise. This would also tie in with the way proposed evaluation criteria for the site selection process have been structured (refer to NDA Technical Note: A Proposed Framework for Stage 4 of the MRWS Site Selection Process). However, care will be needed

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when combining the assessments of site and transport options – particularly when considering possible cumulative effects and interactions. The DfT’s SEA Guidance will be used as the basis for the transport assessment work36.

Scoping work during the early stages of the SEA will develop a proposed technical approach for each relevant environmental and socio-economic assessment topic and will indicate the likely level of assessment required (considering the requirements of both the SEA and the site selection process).

5.7 Evaluating effects

Evaluating effects involves assessing their significance. For SEA, it is common practice (although not a statutory requirement) to do this by defining “SEA objectives” and associated evaluation criteria. The objectives reflect a desired direction of change and what stakeholders see as being important. They will rarely be fully met by any given option or alternative, but assessing the degree to which they are met provides an indication of significance. They also allow the relative merits of different alternatives to be compared and a preferred option to be identified. However, assessing identified effects against SEA objectives is usually a subjective exercise heavily dependent on professional judgement and the problems associated with such an approach are outlined in Section 3.4 above.

For the following reasons, it is proposed that no SEA objectives be defined for the geological disposal implementation plan and that a purely baseline-led approach is adopted:

• The SEA will support decision making by providing information on the likely environmental and socio-economic effects of plan implementation. But, it will not be, in itself, a decision making tool. The relative merits of different alternatives will be considered as part of the assessment of potential candidate sites – not as part of the SEA. The SEA will not pre-empt the assessment of potential candidate sites by attempting to compare the relative merits of different sites or to balance beneficial and adverse effects for different topics or criteria.

• Trying to define SEA objectives and evaluation criteria could lead to considerable confusion with the development and use of site selection criteria (see section 4.2).

• In the case of the geological disposal implementation plan (unlike many other plans and programmes) a significant amount of site-specific baseline information will be available and it follows that a baseline led approach would be more appropriate. In other words, the evaluation of effects should be informed primarily by the nature of site-specific constraints and opportunities, rather than subjective judgements of performance against defined SEA objectives.

• A baseline-led approach would be more in keeping with the requirements of the SEA Directive and the expectations of stakeholders – particularly the Consultation Bodies

• A baseline–led approach would be more in keeping with the findings of recent research on the effectiveness of SEA, commissioned by DCLG (see Section 3.4 above).

Rather than using SEA objectives it is proposed that, where possible, the significance of identified effects will be assessed by considering the importance (or sensitivity) of affected resources and receptors2 and the magnitude of the effect, using an appropriate evaluation matrix. The precise details of the approach for each assessment topic will be defined as part

2 Resources in this context are defined as biophysical features or items of “environmental capital” (such as elements of ecological, landscape or heritage value, watercourses, dwellings, places of employment and community facilities). Receptors are defined as human beings, either individually or collectively, and the socio-economic systems on which they depend.

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of the SEA scoping process and during development and finalisation of the site selection methodology. An illustrative evaluation matrix is shown in Figure 5.1

Figure 5.1 Illustrative Evaluation Matrix

5.8 Mitigation and enhancement

As noted in Section 4.4 and illustrated in Figure 4.2, the iterative process of environmental assessment feeding back into design development will help to ensure that the development of proposals for the site characterisation work, disposal facility and its associated transport infrastructure takes full account of environmental and socio-economic issues.

Although a relatively high level of detail will be available for both the baseline definition and plan definition at Stage 4, the strategic nature of the work may not always allow very specific mitigation and environmental design measures to be factored into the assessment. For some topics, a certain level of mitigation and environmental design will be assumed, consistent with regulatory compliance and good practice. In other cases the assessment will highlight the need for mitigation, although its precise influence on the magnitude and significance of identified effects may not be clear – something that will be taken into account when assessing the level of uncertainty associated with identified effects (see Section 5.9 below). Some of the key assumptions relating to mitigation and enhancement will be derived from the sustainable design objectives developed for the geological disposal implementation plan.

Environmental and socio-economic assessment work is often reported using the following generic structure:

• Unmitigated proposal

• Predicted effects of unmitigated proposal

• Mitigation and enhancement measures

• Residual effects of mitigated proposal

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This structure is unwieldy, can result in very large reports containing a lot of repetition and can also lead to confusion for the casual or lay reader who is faced with two scenarios describing the effects of the proposal. Environmental and socio-economic assessments for the geological disposal programme will therefore be reported in a much simpler form:

• Mitigated proposal

• Effects of mitigated proposal

To provide an audit trail of mitigation and enhancement measures a mitigation register is being established to record issues as they arise, to track how they are dealt with and to record consequent effects on the plan and project definitions. Together with the sustainable design objectives, this register will detail how environmental and socio-economic issues have been considered and addressed and will provide the justification for any assumptions made.

To clearly demonstrate how the assessment work has influenced plan development, presentation of the mitigated proposal will explain how key mitigation measures have been identified, captured and incorporated into the plan. This will be supported by the mitigation register which is likely to be included as a technical appendix to the environmental report.

5.9 Dealing with uncertainty

Section 3.3 considers how uncertainty in predicting environmental and socio-economic effects can be dealt with in SEA, at least in a broad sense. For some assessment topics it may be possible to provide a quantitative analysis of uncertainty, but in many cases a more qualitative, subjective approach may be all that’s possible. In either case it is recognised that decision makers need to be aware of the level of confidence associated with predicting environmental and socio-economic effects. Part of this will involve clear presentation of the assumptions that underlie the baseline definition, the plan definition and the assessment work, as well as clear explanation of inherent uncertainties in the technical assessment methods used.

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6 Proposed Approach to the SEA

The SEA will be based on the stages described in the ODPM Guidance, tailored to the geological disposal implementation plan. The Guidance notes that “It is important…to treat the SEA as a flexible process, tailored to the needs of the different types of plans and programmes to which the Directive applies, while ensuring that the requirements of the Directive are met”.

The proposed stages are listed below, referenced as per the ODPM guidance, with the proposed activities outlined under each heading. The process is also illustrated in Figure 6.1 overleaf. Note that ODPM stages A4 and B1 are not shown since the SEA will adopt a baseline-led approach and will not define “SEA objectives” (see Figure 3.1 and Section 5.7).

The purpose of the SEA will be to provide information on the likely environmental and socio-economic effects of the geological disposal implementation plan, so that such effects can be taken into account during development of the plan and during the decision making process leading to its adoption. The environmental and socio-economic assessment work during MRWS Stage 4 will also be used in local decision making about whether or not to continue participation in the site selection process and in national decision making on which candidate sites to investigate further in MRWS Stage 5.

6.1 Stage A: Setting the context, establishing the initial baseline and deciding on the scope of work

A1: Identifying other relevant plans, programmes and environmental protection objectives

The geological disposal implementation plan may be influenced by other plans and programmes, and by external environmental protection objectives defined by policy or legislation. An early activity of the SEA will be to identify any significant interactions and to consider potential effects on the scope of the assessment work. Relevant plans, programmes and protection objectives have already been identified at a national scale as part of the generic environmental and socio-economic assessment work carried out during MRWS Stages 1 to 3. The SEA will update and build on this work. In particular, once a Decision to Participate has been taken by potential host communities, local plans and programmes (e.g. local development frameworks, transport plans and biodiversity action plans) will be factored into the assessment.

A2: Collecting initial baseline information and developing initial plan definition

Collecting and updating baseline information will be an on-going process throughout MRWS Stage 4. As noted in Section 5.2 most of the environmental and socio-economic baseline information will be collected from existing sources, as a desk-based exercise. However, a limited amount of (non-intrusive) field survey and monitoring work may also be necessary. Aspects of the baseline to be considered will be defined during scoping work, but an initial list of possible information requirements is included as Appendix 2. Part of this work will be to identify trends and to consider how the baseline may change over time.

Collecting baseline information will initially focus on informing the scope of the SEA (see A5) by identifying key constraints and opportunities relevant to the geological disposal implementation plan, building on the generic environmental and socio-economic assessment work carried out during MRWS Stages 1 to 3.

Following a Decision to Participate there may be relatively well defined, but possibly quite large areas within which a disposal facility might be located. Collecting baseline information

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for these areas is likely to be a desk based exercise. Once candidate sites have been identified the work will become more focused and may involve limited field survey and monitoring. The scope of the SEA will be kept under review as additional baseline information is collected.

An initial plan definition will also be developed, again to inform the scope of the SEA by identifying key characteristics of the plan that are likely to influence the environmental and socio-economic assessment work (see Appendix 1). This is likely to be based on Steps towards implementation.

A3: Identifying environmental problems

Collation of baseline information and discussion with stakeholders through the scoping process (see A5) will highlight current and potential environmental (and socio-economic) problems. Problems may also become apparent through conflicts with other plans and programmes and through tensions between environmental protection and socio-economic development objectives. Such problems may have a bearing on the scope of the SEA and on plan development – particularly the development of possible mitigation and enhancement measures.

It is also important not to lose sight of the fact that radioactive waste is an important environmental problem and one that the geological disposal implementation plan aims to address. A key component of the baseline for the SEA will be defining how higher activity radioactive waste would be managed in the absence of geological disposal and justifying the assumptions made.

A5: Consulting on the scope of the SEA

The views of candidate communities and consultation bodies will be sought on the scope of the SEA, together with the views of relevant non-statutory bodies and the wider public. The vehicle for doing this will be a scoping report, prepared early in MRWS Stage 4. This will cover the geographic, temporal and technical scope of the work, including the degree of detail to be included in the environmental report. If particular topics or issues are excluded from consideration, then a clear justification will be provided.

The scoping report will be developed with inputs from candidate communities and consultation bodies and, in draft form, will be subject to formal consultation. It will be updated in light of the feedback received and agreed with Government before substantive work on the formal SEA begins. At this stage the scope of work may be relatively generic in nature (i.e. not site-specific) since candidate sites may not be identified until some months into MRWS Stage 4. The scope of work will be kept under review and updated as required – particularly as site specific information becomes available. Any significant changes to the scope will be discussed and agreed with candidate communities, consultation bodies and with Government.

6.2 Stage B: Developing and refining alternatives and assessing effects

B2: On-going development of the draft plan definition, including alternatives

B3: Predicting the effects of the draft plan, including alternatives

B4: Evaluating the effects of the draft plan, including alternatives

B5: Developing mitigation and enhancement measures

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Plan development and assessment will be an iterative process, with outputs from the assessment work informing the development of mitigation and enhancement measures which, in turn, will influence the plan (and project) definition. The iterative process may also influence the scope of the SEA, including the collection of baseline information, which will be kept under review. The approach to developing and defining “reasonable alternatives” for assessment is described in Section 5.5 above.

Given the nature of the MRWS site selection process and as with the scoping work (see A5 above), it has been assumed that the environmental and socio-economic assessment work will be carried out in two phases. Initially, the assessment work will be based on the potential host communities and areas not screened out by the sub-surface unsuitability criteria. Once potential candidate sites have been identified then site-specific issues will be incorporated into the assessments.

As noted in Section 4.2, SEA may feed information on environmental and socio-economic issues into the process for the identification of potential candidate sites. Much of this information is likely to be in the form of baseline spatial data held within a Geographic Information System (GIS), although it could be accompanied by appropriate contextual information if needed. The precise format of any information requirements will be discussed and agreed with the Community Siting Partnership(s).

For the assessment of potential candidate sites technical reports will be available on a range of environmental and socio-economic topics relevant to the site selection process. It is anticipated that summary information sheets will also be produced on a variety of topics to facilitate easy access to key information – these will be produced in a user friendly, non-technical format. A draft of the Environmental and Sustainability Report (see 6.3 below) will also be available to support public and stakeholder engagement on the assessment of potential candidate sites.

As noted in Section 5.6, the assessment of waste transport options will initially be carried out as a semi-independent exercise to the assessment of site and concept options. They will then be combined and cumulative effects and interactions considered.

Where possible, a relatively detailed, objective and quantitative approach will be adopted for predicting effects. The significance of identified effects will be assessed by considering the importance (or sensitivity) of affected resources and receptors and the magnitude of the effect, reflecting the significance criteria listed in Annex II of the SEA Directive.

As per the requirements of the SEA Directive and if considered relevant by the scoping process, potential effects on biodiversity, population, human health, fauna, flora, soil, water, air, climate factors, material assets, cultural heritage and landscape will be considered. In addition, socio-economic factors will be included within the assessment work to reflect wider sustainability issues. Secondary, cumulative and synergistic effects will also be addressed, together with possible effects arising from interactions between the geological disposal implementation plan and other plans and programmes identified under A1.

Mitigation and enhancement measures developed through the iterative process of assessment and plan development will be tracked using a mitigation register. This will detail how significant environmental and socio-economic issues have been considered and addressed and will provide the justification for any assumptions made (see section 5.8).

The assessment will reflect the different project phases and will focus on the period up to and including facility closure. Some consideration will be given to the longer term post-closure phase although the degree of uncertainty associated with baseline forecasting over very long periods of time is such that this is likely to be at a relatively high level. The safety

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case will consider geosphere and biosphere evolution over long time periods and this work will be used to inform development of a longer term baseline for the SEA (see section 5.2).

As far as possible a standardised approach will be adopted for evaluating effects, to aid presentation and interpretation. Any uncertainties or limitations in the information underlying the work or in the technical approach adopted will be made clear so that some level of confidence can be assigned to the predictions.

Figure 6.1 Stages in the geological disposal implementation plan SEA

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B6: Proposing measures to monitor the effects of plan implementation

Following on from the assessment work, proposals will be developed for monitoring plan implementation – to identify any unforeseen effects and in order to undertake appropriate remedial action if needed. At this stage, such measures will only be outlined. They will be captured in the Disposal System Specification and will be further developed during more detailed assessment work in MRWS Stages 5 and 6.

6.3 Stage C: Preparing the Environmental and Sustainability Report

This will be prepared as a stand-alone document, but will be included as an annex to the draft implementation plan (see Appendix 1). Given that the SEA will include consideration of socio-economic, as well as environmental effects, it will be presented as an Environmental and Sustainability Report.

It will take the form of a concise main report, supported by detailed technical appendices covering the various assessment topics and related information. A non-technical summary will also be produced. The main report and non-technical summary will use simple, clear language, avoiding the use of technical terms if possible and providing clear explanations of any technical terms that are used. Maps and other illustrations will be used where appropriate.

As a minimum, the report will include all of the information required under the SEA Directive (see section 2.4).

A possible structure for the main report, based on that presented in the Strategy for Sustainability Appraisal and Environmental Assessment is given in Table 6.1. The exact content and structure will depend on the outcome of the scoping consultation.

Table 6.1 Possible structure and content of the Environmental and Sustainability Report

Structure of report Information to include

Non-technical summary

• Summary of the SEA process • Summary of the geological disposal implementation plan • Summary of the likely significant effects of the plan • Statement on the difference the process has made to-date • How to comment on the report

Methodology used • Approach and technical assessment methods adopted in the SEA • When the SEA was carried out • Who carried out the SEA • Who was consulted, when and how • Difficulties encountered in compiling information or carrying out the

assessment Background • Purpose of the SEA and the report

• Aims and objectives of the geological disposal implementation plan • Compliance with SEA Directive/Regulations

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Baseline and context

• Links to other international, national, regional and local policies, plans and programmes, and relevant sustainability / environmental protection objectives including how these have been taken into account

• Description of social, economic and environmental baseline characteristics and predicted future baseline including timescales

• Environmental and socio-economic issues and problems identified • Sources of information, limitations of the data, assumptions made,

justification of the level of detail used in the reports etc. • The SEA and the MRWS site selection process.

Identification and assessment of alternatives

• Main strategic alternatives considered and how they were identified • Other alternatives considered and why they were rejected • How stakeholder engagement has affected the proposals and their

assessment • The likely significant environmental and socio-economic effects of plan

implementation • Consideration of ancillary and/or induced developments • Assessment of cumulative effects • Mitigation and enhancement measures • Uncertainties and risks

Implementation • Links to other tiers of plans and programmes and the project level (environmental impact assessment, design guidance etc.)

• Proposals for monitoring including assessment of the success or efficiency of the plan.

Technical Appendices

Detailed assessments and related information Mitigation register

The Environmental and Sustainability report will be produced in draft form to support public and stakeholder engagement on the site assessment work, subsequent local decisions on continued participation in the MRWS site selection process and a provisional Government decision on candidate sites to carry forward for surface based investigations during MRWS Stage 5. The report will then be finalised for a formal consultation on the SEA.

6.4 Stage D: Consulting on the draft plan and the Environmental and Sustainability Report

D1: Consulting on the draft geological disposal plan and the Environmental and Sustainability Report

As required by Article 6 of the SEA Directive, the proposed implementation plan for geological disposal and the Environmental and Sustainability Report will be subject to a formal consultation process. This will involve candidate communities, consultation bodies and the wider public.

In line with the Government’s Code of Practice on Consultation37, the consultation period will last a minimum of 12 weeks.

In accordance with Article 7 of the SEA Directive, if Government considers that the implementation of the plan is likely to have significant effects on the environment in another member state, or if another member state so requests, the consultation will also involve “environmental authorities” in these states.

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In terms of the SEA, the basis of the consultation will be:

• the draft implementation plan, as defined in Section 5.3;

• the Environmental and Sustainability Report, included as an annex to the draft implementation plan;

• A separate consultation document, providing the context for the consultation, questions for consultees to consider and procedural information.

D2: Assessing significant changes

If significant changes are made to the proposed plan as a result of consultation feedback then it may be necessary to review and update the Environmental and Sustainability Report to ensure it remains consistent with the proposals. For planning purposes it has been assumed that this will not be necessary given that public and stakeholder engagement will be an on-going process throughout plan development– but it remains as a risk.

D3: Decision making and providing information

Responses to the consultation will be collated and summarised in the form of a report and the geological disposal implementation plan will then be formally adopted.

Information on this decision making process and its outcome will be made available to candidate communities, consultation bodies and the wider public through publication of a “Post Adoption Statement” together with the adopted plan. The Post Adoption Statement will explain how information from the SEA and from consultation has been taken into account during development of the plan and before the final decision on its adoption.

6.5 Stage E: Monitoring plan implementation

E1: Developing aims and methods for monitoring

E2: Responding to adverse effects

At this stage the aims and methods for monitoring will be developed in outline only, and significant issues will be highlighted for more detailed consideration of possible mitigation and enhancement measures during MRWS Stage 5. These will be discussed in the Post Adoption Statement.

During subsequent stages of the geological disposal implementation plan, more detailed environmental and socio-economic assessments will be undertaken as part of project level Environmental Impact Assessments and during development of environmental management plans for construction, operation and closure of a geological disposal facility. Further development and eventual implementation of environmental monitoring will be a key element of this work, together with the development of procedures for responding to unforseen adverse effects.

6.6 Quality Assurance checklist

The ODPM Guidance on SEA includes a Quality Assurance checklist that covers both the technical elements of SEA and the procedural steps of the SEA process. It can be used to test whether the regulatory requirements are likely to be / have been met. The checklist is

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reproduced in Table 6.2, with cross references to relevant sections / proposals in this Technical Note.

Table 6.2: Quality Assurance Checklist Requirement Section Reference

Objectives and context

• The plan’s or programme’s purpose and objectives are made clear. • Environmental issues and constraints, including international and EC environmental protection objectives, are

considered in developing objectives and targets. • SEA objectives, where used, are clearly set out and linked to indicators and targets where appropriate. • Links with other related plans, programmes and policies are identified and explained. • Conflicts that exist between SEA objectives, between SEA and plan objectives and between SEA objectives and

other plan objectives are identified and described.

6.1 (A2), 5.3 6.1 (A2, A3) SEA objectives will not be used 6.1 (A1) 6.1 (A3)

Scoping

• Consultation Bodies are consulted in appropriate ways and at appropriate times on the content and scope of the Environmental Report.

• The assessment focuses on significant issues. • Technical, procedural and other difficulties encountered are discussed; assumptions and uncertainties are made

explicit. • Reasons are given for eliminating issues from further consideration.

6.1 (A5)

6.1 (A1-A5)

6.2 (B2-B5), 5.9 6.1 (A5)

Alternatives

• Realistic alternatives are considered for key issues, and the reasons for choosing them are documented. • Alternatives include ‘do minimum’ and/or ‘business as usual’ scenarios wherever relevant. • The environmental effects (both adverse and beneficial) of each alternative are identified and compared. • Inconsistencies between the alternatives and other relevant plans, programmes or policies are identified and

explained. • Reasons are given for selection or elimination of alternatives.

Table 6.1, 5.5, 2.3 6.1 (A2), 5.2 6.2 (B2-B5), 5.5, 5.73

6.1 (A1, A3) 6.3 (Stage C & Table 6.1), 5.5

3 The relative merits of different alternatives will be considered as part of the site selection process – not as part of the SEA. The SEA will not pre-empt the site selection process by attempting to compare different sites or to balance the beneficial and adverse effects identified under different assessment topics.

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Baseline information

• Relevant aspects of the current state of the environment and their likely evolution without the plan or programme are described.

• Environmental characteristics of areas likely to be significantly affected are described, including areas wider than the physical boundary of the plan area where it is likely to be affected by the plan.

• Difficulties such as deficiencies in information or methods are explained.

6.1 (A2), 5.2

6.1 (A2), 5.2, Appendix 2

6.1 (A2), 5.9

Prediction and evaluation of likely significant environmental effects

• Effects identified include the types listed in the Directive (biodiversity, population, human health, fauna, flora, soil, water, air, climate factors, material assets, cultural heritage and landscape), as relevant; other likely environmental effects are also covered, as appropriate.

• Both positive and negative effects are considered, and the duration of effects (short, medium or long-term) is addressed.

• Likely secondary, cumulative and synergistic effects are identified where practicable. • Inter-relationships between effects are considered where practicable. • The prediction and evaluation of effects makes use of relevant accepted standards, regulations, and thresholds. • Methods used to evaluate the effects are described.

6.2 (B2-B5) Note; the SEA will also include consideration of socio-economic effects. 6.2 (B2-B5)

6.2 (B2-B5) 6.2 (B2-B5)

6.2 (B2-B5), 5.6 6.2 (B2-B5), 5.7

Mitigation measures

• Measures envisaged to prevent, reduce and offset any significant adverse effects of implementing the plan or programme are indicated.

• Issues to be taken into account in project consents are identified.

6.2 (B2-B5), 5.8 6.2 (B2-B5), 5.8

The Environmental Report

• Is clear and concise in its layout and presentation. • Uses simple, clear language and avoids or explains technical terms. • Uses maps and other illustrations where appropriate. • Explains the methodology used. • Explains who was consulted and what methods of consultation were used. • Identifies sources of information, including expert judgement and matters of opinion. • Contains a non-technical summary covering the overall approach to the SEA, the objectives of the plan, the main

options considered, and any changes to the plan resulting from the SEA

6.3 (C) 6.3 (C) 6.3 (C) Table 6.1 Table 6.1 Table 6.1 6.3 (C)

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Consultation

• The SEA is consulted on as an integral part of the plan-making process. • Consultation Bodies and the public likely to be affected by, or having an interest in, the plan or programme are

consulted in ways and at times which give them an early and effective opportunity within appropriate time frames to express their opinions on the draft plan and Environmental Report.

6.4 (D1) 6.4 (D1)

Decision-making and information on the decision

• The environmental report and the opinions of those consulted are taken into account in finalising and adopting the plan or programme.

• An explanation is given of how they have been taken into account. • Reasons are given for choosing the plan or programme as adopted, in the light of other alternatives considered.

6.4 (D2, D3) 6.4 (D3) 6.4 (D3) and 4.2 which highlights the relationship between the SEA and site selection process.

Monitoring measures

• Measures proposed for monitoring are clear, practicable and linked to the indicators and objectives used in the SEA.

• Monitoring is used, where appropriate, during implementation of the plan or programme to make good deficiencies in baseline information in the SEA.

• Monitoring enables unforeseen adverse effects to be identified at an early stage. (These effects may include predictions which prove to be incorrect.)

• Proposals are made for action in response to significant adverse effects.

6.5 (E1, E2) SEA Objectives and indicators not used 6.5 (E1, E2) 6.5 (E2) 6.5 (E2)

7 Recommendations and Next Steps

The key recommendations for the SEA are:

• it will be based on the procedural stages described in ODPM Guidance on SEA, suitably tailored to the geological disposal implementation plan;

• it will be baseline-led, with no requirement to define SEA objectives or to evaluate the implementation plan against such objectives;

• it will adopt a relatively detailed, objective and quantitative approach, reflecting the level of baseline information likely to be available, a well defined plan (and project) definition and the requirement to support the site selection process;

• where possible, the significance of potential effects will be assessed by considering the importance (or sensitivity) of affected resources and receptors, and the magnitude of the effect;

• “reasonable alternatives” to be considered by the SEA will be defined as the candidate sites for implementing geological disposal offered by / agreed with potential host communities, together with the alternative approaches to site investigation, alternative concept designs and alternative waste transport options relevant to those sites. The baseline definition, i.e. what would happen if geological disposal was not implemented, will also be considered;

• alternatives to geological disposal will be kept under review, as required by the MRWS White Paper. These alternatives will not be subject to assessment as part of the SEA, but the review findings will provide essential context for both the SEA and development of the implementation plan;

• the relative merits of alternative sites will be considered within the MRWS site selection process. The environmental and socio-economic assessment work undertaken for the SEA will feed relevant information into the site selection process as required;

• consultation on the SEA and on a draft implementation plan for geological disposal will be carried out as part of the decision making process at the end of MRWS Stage 4;

• the draft plan will propose a series of co-ordinated activities to implement geological disposal of higher activity radioactive waste, based on a voluntarism/partnership approach to site selection. Implementation of the plan will start with surface based investigations at one or more candidate site(s)before moving on to subsequent underground investigation at the preferred site to confirm it’s suitability; the draft plan will also include construction, operation, closure and post closure phases of the proposed disposal facility and its associated infrastructure;

• a mitigation register will be used to track environmental and socio-economic issues and to provide an audit trail for decisions made on proposed mitigation and enhancement measures;

• a Health Impact Assessment will be carried out as part of the SEA;

• a Habitats Regulations Assessment will be carried out in parallel with the SEA, but using common baseline data and providing inputs as required to the SEA biodiversity assessment.

Following review, finalisation and agreement of the proposals in this Technical Note, a “generic” scoping report for the SEA will be drafted in preparation for the start of MRWS Stage 4. Following a decision by one or more candidate communities to participate in the

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e

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18 Department for Communities and Local Government, (March 2010) Towards a more efficient and effective use of Strategic Environmental Assessment and Sustainability Appraisal in spatial planning. HMSO, ISBN 978 1 4098 2373 5

19 Environment Agency (2010) Strategic Environmental Assessment http://www.environment-agency.gov.uk/research/policy/32901.aspx

20 NDA, (September 2010) Draft Strategy – Published September 2010 for Consultation, ISBN 978-1-90598–517-3 http://www.nda.gov.uk/strategy/developing-strategy.cfm

21 NDA-RWMD (June 2008) A Proposed Framework for Stage 4 of the MRWS Site Selection Process. (RWMD Technical Note: NDA/RWMD/8150715)

22 T. Baldwin, N. Chapman and F. Neall (January 2008) Geological Disposal Options for High Level Waste and Spent Fuel. Contractor Report to NDA.

23 T. Hicks, T. Baldwin, P. Hooker, P. Richardson, N. Chapman, I. Mckinley and F. Neall (April 2008) Concepts for the Geological Disposal of Intermediate-Level Radioactive Waste. Galson Sciences Report to NDA 0736-1.

24 NDA-RWMD, (March 2010) Geological Disposal: Sustainable Design Objectives for a Geological Disposal Facility. (RWMD Technical Note NDA/RWMD/13835210).

25 DfT, (March 2007) Guidance on Transport Assessment http://www.dft.gov.uk/pgr/regional/transportassessments/guidanceonta

26 NDA-RWMD (November 2009) The interface between transport work and sustainability assessment for the geological disposal facility. (RWMD Technical Note: NDA/RWMD/13772509).

27 European Parliament and Council of the European Union (May, 1992) Directive on the conservation of natural habitats and of wild flora and fauna (Official Journal of the European Union – OJ L 206, 22.7.1992, p. 7)

28 The Conservation of Habitats and Species Regulations 2010 (SI 2010/490)

29 NDA-RWMD (March 2010) Geological Disposal: Steps Towards Implementation, ISBN 978-1-84029-397-5 (NDA-RWMD Report: NDA/RWMD/013)

30 http://www.gos.gov.uk/goeast/planning/regional_planning/837825/

31 DECC (2010) Severn Tidal Power Phase 1 – Consultation Documents http://www.decc.gov.uk/en/content/cms/consultations/stp_phase1/stp_phase1.aspx

32 CoRWM (July, 2006) Managing Radioactive Waste Safely – CoRWM’s recommendations to Government (CoRWM Document 700) http://corwm.decc.gov.uk/documentstore

33 IEEM (2006) Guidelines for Ecological Impact Assessment http://www.ieem.net/ecia/

34 Landscape Institute and Institute of Environmental Assessment, (2002) Guidelines for Landscape and Visual Impact Assessment: Second Edition. E & FN Spon, London.

42

35 DfT (2010) Design Manual for Roads and Bridges – Volume 11 http://www.standardsforhighways.co.uk/dmrb/vol11/section3.htm

36 Department for Transport, (April 2009) Strategic Environmental Assessment for Transport Plans and Programmes – TAG Unit 2.11 – “in-draft” Guidance. http://www.dft.gov.uk/webtag/documents/project-manager/unit2.11.php

37 HM Government (2008) Code of Practice on Consultation (Department for Business, Enterprise and Regulatory Reform – URN 08/1097)

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APPENDIX A

Proposed outline of the “draft plan” for implementing geological disposal

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Executive summary

1. Introduction 1.1 Government policy

1.2 Waste Inventory

1.3 Overview of the geological disposal implementation plan

Statement of policy, overview of the waste inventory for disposal and geological disposal implementation plan - plus a summary of the structure and content of the document.

2. Approach to defining reasonable alternatives Will describe the process leading to the identification of “reasonable alternatives” (i.e. sites + associated site characterisation proposals and concept designs) and explanation as to why other alternatives were eliminated from further consideration.

Will also summarise the process of keeping alternatives to geological disposal under review and the conclusions reached to date.

3. Preparatory studies carried out to date 3.1 Stage 1 – Expression of interest

3.2 Stage 2 – Sub-surface screening

3.3 Stage 3 – Decision to participate

3.4 Stage 4 – Desk based studies

• Identification of potential candidate sites • Development of site characterisation proposals • Development of conceptual designs • Preliminary safety assessment • SEA • HRA • TA

l candidate sites • Assessment of potentia• PSE on site selection • Community decision to proceed to MRWS Stage 5 • ion on candidate sites Provisional Government decis

Summary of preparatory studies leading to “current” position (i.e. position as at the end of MRWS Stage 4).

4. Plan for implementation 4.1 Surface based investigation

4.2 Further development of conceptual designs

pment

d to MRWS Stage 6

f preferred site

n

4.9 Closure

ng n points. Will be site

oject definition” will be given as an nnex.

4.3 Safety case develo

4.4 EIA, HRA and TA

4.5 Community decision to procee

4.6 Identification o

4.7 Constructio

4.8 Operation

Proposed plan for implementation, explainikey steps and decisiospecific at this point.

A detailed “prA

5. Timetable Proposed implementation timetable

6. Regulatory requirements Key regulatory requirements / milestones

45

7. Public and stakeholder engagement Commitment to continuing engagement

8. Cost Updated cost estimates

9. Next steps Immediate next steps (ref. Section 3)

Annex I: Identification of Potential Candidate Sites

Annex II: Assessment of Potential Candidate Sites

Annex III Project definition

Annex IV: Environment and Sustainability Report

Annex V: Habitats Regulations Assessment (Plan Level)

Annex VI: Transport Assessment (Strategic Level)

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47

APPENDIX B

Indicative list of baseline information requirements

Baseline information needed for environmental and socio-economic assessment work during MRWS Stage 4 (indicative only)

Parameter / Information Need Method of measurement Information used for:

Geology and Soils

Ground contamination Interpretation of historic mapping. Inspection of Local Authority and Environment Agency records on waste management facilities and landfill, Environmental Permitting, pollution incidents to Controlled Waters, Notification of Installations Handling Hazardous Substances, Control of Major Accident Hazards (COMAH) sites, Hazardous Substance planning consents.

Assessing the potential for contaminant mobilisation and related health and environmental effects.

Soil types and properties Interpretation of LandIS4 data sets. Assessing potential effects on the national soil resource.

Important geological conservation sites Inspection of Local Authority and Natural England / Countryside Council for Wales records on Regionally Important Geological Sites (RIGS) and Geological Sites of Special Scientific Interest (SSSIs).

Assessing potential effects on important geological (and geomorphological) sites in terms of their educational and amenity value.

Drainage and Water Quality

Surface water drainage (catchments, surface water features and their characteristics)

Inspection of surface mapping, aerial photography, Environment Agency records on river flows, water levels and areas at risk from flooding.

Assessing potential effects on drainage and flood risk.

Chemical and biological water quality, surface Inspection of Environment Agency records on Assessing potential effects on surface water

4 Land Information System - www.landis.org.uk

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Parameter / Information Need Method of measurement Information used for: waters chemical / biological surface water quality, inc.

Water Framework Directive classifications. quality.

Groundwater features and their characteristics Inspection of Environment Agency records on major / minor aquifers, their Source Protection Zones (SPZs) and licensed abstractions.

Assessing potential effects on groundwater quality and abstractions.

Landscape (and Townscape)

Landscape character Inspection of National Landscape Character Database5, aerial and surface photography.

Inspection of Local Authority, Natural England / Countryside Council for Wales records on protected landscape areas (National Parks, Areas of Outstanding Natural Beauty, Historic Landscapes etc)

Assessing potential effects on landscape character and quality

Visual Amenity

Landform and topography Interpretation of digital Ordnance Survey mapping and height data.

Defining visual envelopes for candidate sites and assessing potential effects on visual amenity.

Biodiversity

Habitat Types Inspection and interpretation of Phase 1 Habitat Survey6 records held by Local Authorities, Wildlife Trusts and other conservation organisations.

Assessing potential effects on biodiversity.

5 www.landscapecharacter.org.uk6 www.jncc.gov.uk/page-4258

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Parameter / Information Need Method of measurement Information used for:

Inspection and Interpretation of the Ancient Woodland Inventory7

Inspection of Local Authority, Natural England / Countryside Council for Wales records for protected areas (non-statutory nature conservation sites, Natura 2000 sites, Biological SSSIs, National Nature Reserves, Marine Nature Reserves, etc)

Protected Species Inspection of protected species records held by Local Authorities, Wildlife Trusts and other conservation organisations.

Assessing potential effects on biodiversity.

Air Quality, Weather and Climate

Local and regional air quality

(Dust, particulates, nitrogen oxides, carbon monoxide, sulphur dioxide, PAHs, etc.)

Inspection of UK Air Quality Archive data8 and Local Authority air quality records.

Inspection of Local Authority records for Air Quality Management Areas (AQMAs).

Assessing potential effects on local and regional air quality – particularly with regard to statutory air quality objectives.

Weather and Climate

(Temperature, precipitation, humidity, sunshine hours, wind speed and direction, trends in climate change etc.)

Inspection and interpretation of data from existing meteorological stations.

Inspection and interpretation of UKCP099.

Provides essential context for a number of assessment topics.

7 www.magic.gov.uk/info/awreadme.html8 www.airquality.co.uk9 UK Climate Projections 2009 (ukclimateprojections.defra.gov.uk/)

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Parameter / Information Need Method of measurement Information used for:

Noise and Vibration

Ambient noise and vibration levels Inspection of Local Authority Environmental Health Department records.

Assessing potential effects on ambient noise and vibration levels.

Land Use and Material Assets

Including existing land use and planned change as identified in Regional Spatial Strategies and Local Development Frameworks.

Inspection of Local Authority Development Plan Documents, Ordnance Survey mapping, aerial photography and the National Land Use Database10

Identifying potential receptors and assessing potential effects on land use and land-use change.

Cultural Heritage

Archaeological sites and features

Inspection of the National Monuments Record11, Local Authority archaeological records, historic mapping and aerial photography.

Identification of designated archaeological sites, e.g. World Heritage Sites, Ancient Monuments, Areas of Archaeological Importance, Registered Historic Battlefields.

Assessment of potential effects on the archaeological resource.

Built heritage Inspection of the National Monuments Record, Local Authority listed building records, historic mapping, aerial and surface photography. Identification of designated sites, e.g. World Heritage Sites, Ancient Monuments (with standing remains), Listed Buildings, Conservation Areas,

Assessment of potential effects on the built heritage resource.

10 www.nlud.org.uk11 www.english-heritage.org.uk/server/show/nav.19915

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Parameter / Information Need Method of measurement Information used for: registered Historic Parks and Gardens.

Socio-economics

Population and employment statistics Inspection of ONS12 data by Output Area13.

Income and deprivation statistics Inspection of ONS data by Output Area.

Property prices Inspection of Land Registry data by Local Authority Area.

Public health ONS and Department for Health data by Output Area.

Crime rates Home office data by Local Authority area.

Assessment of potential socio-economic effects.

Transport

Public transport provision Inspection of bus and train service schedules (for routing and frequency)

Road traffic flows Inspection of Highways Agency and Highway Authority records for Average Annual Daily Traffic (AADT) and peak traffic flow data.

Traffic accidents Inspection of Highways Agency, Highway Authority and police records for accident data, including rates, locations and severity.

Assessment of transport related environmental and socio-economic effects.

Assessment of potential effects on public access to recreational areas.

12 Office of National Statistics (www.statistics.gov.uk) 13 Output Areas are geographic units used for grouping census and other data. They are based on postcode areas and, in England, have a minimum

defined size of 40 resident households. Some census data are grouped into larger “Super Output Areas”.

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Parameter / Information Need Method of measurement Information used for:

Non-vehicular users Inspection of Ordnance Survey mapping and Local Authority Definitive Maps to identify the rights of way network.

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+44 (0)1925 802820

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