It is important that everyone – especially those most affected – should be able to express their views regarding the possible siting of a GDF between Kirksanton and Haverigg.
South Copeland GDF Community Partnership brings together the Geological Disposal Facility developer, i.e. Nuclear Waste Services (NWS), the Local Authority and community members. The role of the Partnership is to ensure the local community is fully involved and has accurate and balanced information so that each of us can make an informed decision about the siting of a GDF in our area.
Below is a paper by ex-member John Sutton, who previously represented Sustainable Duddon on the Partnership. It is entitled “Ethical Problems Concerning Nuclear Waste Services’ GDF Related Engagement with Communities.” The paper shares concerns expressed not only by other ex-members of the Community Partnership but also members of the public.
Executive Summary
This note sets out the many ways in which NWS’ actions have fallen below ethical standards expected from a tax payer funded body engaging with a local community. It begins by considering how NWS’ instrumentally driven (i.e. to deliver a Geological Disposal Facility (GDF)) engagement has led them to consistently undermine the rights of communities as set out in the UK Policy Framework.
NWS’ have used their control of Community Partnership (CP) communications and public engagement to press their own agenda rather than to reflect the views of CP members. In this, the note identifies four key issues;
- NWS have been so keen to press their own agenda that they have repeatedly abandoned the UK Policy Framework which defines how the community engagement process should work. Much of what is supposed to be CP communications amounts to little more than slick NWS publicity. The NWS approach, far from helping a community to come together, is in danger of leaving a divisive legacy.
- By repeatedly overriding community members, they have denied the community a key empowering policy benefit, i.e. our right to be in charge of our own, inclusive, conversation about our nuclear future. The CP has effectively become a Potemkin Partnership, i.e. NWS cultivate the image of functioning Partnership largely for external consumption.
- In addition, there is consideration of just how uncomfortable working with NWS has been. The result is that many people have resigned from the Partnership, including both NGOs. Many members of the public no longer attend.
- Finally, it describes how NWS have acted to exclude reasonable external scrutiny of the engagement methods they have employed within CPs.
In all these respects, it is argued that NWS’ approach to working with the community has fallen below reasonable ethical standards, and specifically below the Nolan Principles that all CP members committed to adhere to.
NWS’ instrumentally driven engagement has resulted in them undermining community rights set out in the UK Policy Framework
The UK Policy Framework sets out that a CP decides collectively how to conduct public engagement within their own community. As such, the goal is to empower the community itself to manage the process of considering what the implications of hosting a GDF might be and whether they are right for our community. In 2024 the CP made a positive start to fulfil this Policy role. NWS stepped back to permit community members of the CP to run community forums to ask local people what they thought. Additionally, we began to explore topics in greater depths, held an ‘ask the experts’ evening and our regular monthly meetings always attracted an audience who asked engaged questions.
NWS is, in policy terms, just one member of the CP. However, unlike other members who commit to acting as a neutral party, NWS’ role as an organization is to actively seek to secure the agreement of communities to take nuclear waste. Unfortunately, in contravention of the UK Policy Framework, they increasingly used their control of CP secretariat, funding and broader engagement as an instrument to achieve this aim. Throughout 2024 NWS increasingly objected to the work of CP members. In early 2024, a community member drafted a number of relevant articles as well as a bibliography of sources other than NWS, for possible inclusion on the CP website. Community members were in favour, but NWS vetoed these, even though they have no right to do so under the UK Policy Framework. In doing so they exploited their control of what should be the CP website to act unilaterally. The extent of NWS’ desire to prevent anyone else contributing to the discussion is indicated by the fact that even requests for the website to include CoRWM’s documents were rejected by NWS. (CoRWM are the Government’s own expert advisors.)
In November 2024 NWS suspended the CP (though they have no right to do so under the UK Policy Framework) and there was no formal meeting until June 2025. NWS’ ostensible reason was the departure of Millom Town Council. However, NWS may well also have been concerned about processes for the appointment of a new chair of the Partnership and an impending visit of CoRWM. (In contrast to the corporate PR material published by NWS, CoRWM meetings and publications are often fascinating and informative, and could be of great interest to a nuclear community such as our own.)
When NWS suspended CP meetings, they commissioned Mary Bradley to conduct a review. Though all but one of the CP members were interviewed, the report includes very little of what we said. Rather, it reflects NWS’ concerns, criticizing the parish councillors and others in our community who had all volunteered our time to take part. In particular, it records NWS’ considerable resentment when community members of the CP had sought to challenge them. The report even implied that community members were working against the siting of a GDF. It should be emphasized that there is no evidence that community members were in any way opposed to the concept of a GDF. CoRWM’s work in particular was convincing of the need to find a suitable site. Rather, members concern has been with an overbearing NWS and how they chose to wield their considerable power.
NWS have long complained that their minutes of CP meetings were being queried. The background to this is that minutes of meetings would usually appear several weeks after the event. When asked why this was, it was said that the NWS legal team needed time to review before they were released to CP members. The minutes certainly consistently reflect what NWS wish to have been said, often to such an extent that it appeared community members of the CP had contributed little. Reading the minutes could feel like one was being ‘gaslighted’, as if NWS was attempting to convince us that proceedings were other than as we recalled them. On one occasion NWS simply never provided a note of the November 2024 meeting of the Operations subgroup, presumably because they didn’t like the conclusions of the meeting.
The CP could have been empowering to our community, not least because of the community’s familiarity with what is a key local industry. The topic of nuclear waste is fascinating and crucial to our community. But when CP members brought ideas that might enable a more inclusive process, such as the exploring the use of innovative consensus building software such as Pol.is, NWS repeatedly ignored these suggestions.
NWS’ insistence on owning the narrative to secure their own ends meant there was little space for either community or personal narratives. CP meetings increasingly consisted entirely of NWS’ own papers, and subsequent minutes recorded NWS’ points but little from community members of the CP. Similarly, NWS prepared Newsletters that communicated their narrative, with no space for others (apart from the Chair) to contribute. Unfortunately the UK Policy Framework does not provide for a whistle blowing function to assist when NWS acts in this overbearing manner.
NWS’ engagement has had a divisive impact in the community
It should be stated that the financial benefit to the local community from the nuclear industry is considerable. Well paid jobs and grants to local good causes are significant plus points in our relatively remote area. In the context of grants, it is not unreasonable that councilors might take the view that it is worth allowing NWS their control of the narrative if it means that funding for local good causes is retained. Given that nuclear engagement exercises come and go with regularity here in West Cumbria, there might be some justification for any members of the community to take a cynical view of this latest approach from the nuclear industry, rather than engage in the information gathering and engagement exercises envisaged in the Policy. But if we, as a community, continue to allow NWS to speak in our name, we are to a degree infantised; we miss the opportunity that UK Policy Framework gives us to manage our own community’s on-going and in depth debate concerning our continuing relationship with nuclear waste.
The ethical issue here is that, to a large degree, we are left with a Potemkin Partnership, i.e. an image presented to the outside that is something quite other than what is experienced in our community.
Tellingly, when the CP was suspended from November 2024 to June 2025, NWS continued to deliver throughout our Newsletter in the CP’s name, without mentioning that it was actually suspended.
The position therefore is that a community member of the CP who is keen to question NWS and to call out their breaches of the UK Policy Framework may well be regarded with suspicion by NWS and even some in the local community. Every individual in the community is entitled to take a view on whether it is worth their while personally to engage with the questions around a GDF generally, and the Developer’s role specifically. Many will wish to stand back or even believe that we can entirely leave our future in NWS’ hands. However, when those who are concerned to question NWS as the Developer receive the kind of negative publicity given in Mary Bradley’s report and its subsequent Cumbria Crack appearance, without any recourse, the objective of an inclusive local debate is manifestly lost. Through their close management of the CP process, NWS bear the responsibility for this loss of community voices.
The Community Investment Fund (CIF) should, in Policy terms, be a subgroup operating under the responsibility of the CP. With its remit to distribute £1 million per year, it should have been central to the CP’s role. It is clearly an ethical concern therefore that a full picture of where money has been spent has not been made available, either to community members of the CP or the public. In the interests of openness and transparency, audits have been requested. But no such audit has been made available.
A further ethical question raised by NWS’ operation of the CIF is that while the UK Policy Framework states that CIF should be administered by a third party (so as to provide transparency and independence from NWS) there appears to have been no such third party in South Copeland. It should be noted that the funds received under the CIF are but a small proportion of the total funding provided by NWS’ parent body, the Nuclear Decommissioning Authority (NDA). Millom and the surrounding area deserve this money, but the direct funding mechanism necessarily compromises the voluntarist approach set out in the UK Policy Framework.
NWS has particularly focused on the role of the Chair of the CP. As regards whether the Chair should be a paid position, community members early on took the view that, to ensure it was anchored in the community, the Chair should be an unpaid volunteer rather than an NWS employee. A comprehensive travel and subsistence claim system was already in place to ensure the position holder was recompensed for expenses incurred. However, in the latter half of 2024 the Chair pushed for an honorarium of an undisclosed amount. (It was later discovered from the Theddlethorpe CP website that the payment there was £10,000.) Much time and good feeling were lost in repeated and heated discussions of this topic, discussions which we were told had to take place outside of the public meeting. This loss of good feeling is important locally; none of the NWS staff live locally, but for those of us who do, we are left a legacy of discord and distrust, with an urgent need to rebuild bridges. NWS need to be more cognisant of this negative impact on our small community.
NWS’ actions contribute to an uncomfortable conversation
One of the most notable factors of the CP was just how difficult meetings became. It is clear from Mary Bradley’s report that NWS felt it inappropriate that CP members sought to challenge their minutes, proposals etc. What Mary does not refer to however is just how uncomfortable some people found working with NWS generally and CP meetings in particular.
The first recorded complaint of bullying was made at a meeting held in July 2024. It may be that behaviors of some and the temperature in meetings were regarded as acceptable by some. There may be elements of behaviors of corporate bodies, or perhaps the cut and thrust on local councils, that intimidate some but feel reasonable to others. However, NWS did not take any action to investigate, and the meeting notes were not published on the website.
Poor communication within the CP was undoubtedly a problem that increased during 2024. Far from seeking to create a space conducive to team work, NWS have repeatedly ignored statements that people felt uncomfortable. Requests for confidence building conversations were repeatedly ignored. It appears therefore that NWS have preferred that people become disheartened and leave the CP, rather than work to find accommodations.
NWS acts to avoid external scrutiny of their engagement with local communities
There are many ethical questions concerning the production and management of nuclear waste, ranging from international, national, and local. In June 2025, the NGO NWS Exchange Group held a webinar on the theme of The Ethics of Radioactive Waste Management. One of the most notable takes from the webinar was that NWS actively excluded questions regarding the ethical implications of their engagement as a local level, specifically within the CPs.
One of the papers presented was ‘Intergenerational justice and radioactive waste management’; this was authored by Lee Towers and Matthew Cotton and records how they were prevented from conducting some of the engagement work they intended. In their paper the authors explain that they sought to “conduct workshops with a community group in an area of the proposed GDF site”. However, their report highlighted “problems with …. access to NWS’ nuclear communities”, and when NWS did not facilitate this, complained that “limited access to community participants…. stymies the process of social research… [so that] in practice the project had to be restructured ‘on the fly’ from its original focus”. Though this clearly raises ethical questions, typically, at the webinar NWS did not even acknowledge they had done anything wrong in failing to facilitate this element of the research.
More alarming still, at the webinar, NWS actively prevented any consideration of their actions in this respect, or indeed other ethical implications of their local engagement. Two members of our CP attended the Exchange webinar. Webinar attendees were only permitted to raise questions via a ‘moderated’ chat function. Both members raised questions relating to the ethical implications to potential GDF communities. However, NWS used their moderator control to exclude all questions relating to NWS’ impact on local communities. The only questions allowed were those relating to higher level issues e.g. relating to the inter-generational nature of dealing with nuclear waste.
Conclusion
In summary, the key ethical issues concerning NWS’ control of South Copeland CP include:
- NWS has made it so uncomfortable for some existing members who they saw as challenging NWS that a further four have left. We now have an engagement exercise that is entirely led by NWS instead of by the community itself.
- NWS use their control of what is nominally CP media to deliver their own messages and to prevent voices of volunteers from the community being heard.
- NWS use their control of minutes, newsletters etc to present a false picture of a CP to the outside world: a Potemkin Partnership.
- NWS and the wider NDA have been insufficiently distanced from the allocation of community funds to give confidence that our compliance with their corporate narratives is not a prerequisite.
- Many locals who have tried to engage with the CP have felt frustrated and uncomfortable in the process. NWS’ management of the CP, far from bringing the community together, has been a divisive exercise.
- NWS has limited the academic enquiry of researchers so that they could not complete their intended work with nuclear communities such as our own and also used their control of the moderation function of the webinar so that it appeared no questions had been asked regarding the ethics of NWS’ impact on local communities.
- NWS has used its power to prevent the UK Policy Framework operating to benefit our community as the Government intended.
John Sutton
