A d v ic e Pa p er (10-05)

APRIL 2010

SCOTLANDS HIGHER ACTIVITY RADIOACTIVE WASTE POLICY:

a response to the Scottish Government

Summary Whereas Government should set objectives, it should refrain from over prescribing the technical means by which
such objectives should be achieved.We suggest that the policy objectives in relation to the management of higher activity radioactive wastes should be very simple: to produce a strategy that optimizes between minimising human and environmental health impacts, in both the short and long term, and minimising costs. The decisions taken now will set the trajectory of a long term strategy. It must not burden future generations with risks to health or of excessive costs.

It is inefficient to develop a policy for higher activity radioactive waste that does not cover High LevelWaste.
The Scottish Government should ensure that there is a thorough consideration of the entire waste inventory within the Policy. All waste streams should be embedded in a broad framework of policy.The potential costs of not doing so could be very large.

It is crucial that the Scottish Government apprises itself of international developments and fully considers how the
policy developments within Scotland are positioned in the UK and international context, including issues of nuclear proliferation and security.These are significant omissions from the current policy documents.

Given the nature of the industry and the need to ensure continued good governance and collaboration, it is logical
for Scotland to be considered within the UK context. In particular, it must develop a more rigorous view of long term costs and responsibilities and where these will lie.We are concerned that the present Policy does not set out adequate coordination mechanisms for an implementation structure.This could be a material impediment to stakeholders taking the Policy forward.

The consultation documents do not present the rationale for the Scottish Governments refusal to endorse CoRWMs
recommendation that geological disposal represents the best available long-term approach compared to other forms of management.Whereas it is important for government to express views about values, costs and principles, it should not reject out of hand a technical solution from a formal advisory body without expressing a clear rationale for doing so.

It is unfortunate that the proximity principle is not enunciated with greater clarity, and that an arbitrary depth limit
on any facility is to be imposed.We do not regard such arbitrary constraints as helpful criteria for the location, character and management of wastes. Such issues should be the outcome of a rigorous safety case, not as prior constraints on it.

There is no mention as to whether communities would be invited to volunteer to host a facility or other mechanisms
would be adopted to select a site. Irrespective of what process is adopted, it would be helpful if the Policy stated whether communities would be entitled to benefits for contributing a national good.

We are seriously concerned that the public acceptability of the Scottish Policy is not discussed at any significant length
in the documents.Although the Policy includes the aim of inspiring public and stakeholder confidence, this must not degenerate into decide and tell. We would prefer that the aim of the Policy should be to develop a strategy that is consistent with public values, and that this is ensured through a legitimising process of public engagement, not only with those living and working at existing nuclear sites and in surrounding communities but including individuals and groups wishing to express a view. It is imperative that public engagement and dialogue starts very soon. Running the process of public engagement will be an important task in itself, if it is to be usefully linked to the policy development process.

For effective implementation of the Policy, thorough consideration must be given to invigorating the skills base.There is
a major concern, particularly in the longer term, as Scotland's nuclear industry is being run down, that there will be a deficit of technically-skilled people, to implement the Policy. Preservation of the skills in this area would be valuable and only prompt action will prevent further loss of expertise. Once lost, such expertise will be difficult and expensive to recreate.
1

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Background
1 The Royal Society of Edinburgh (RSE), Scotlands National Academy, is pleased to respond to the Scottish Governments invitation to submit views on the Detailed Statement of Policy for Scotlands Higher Activity Radioactive Waste.The RSE is well placed to respond because of the multi-disciplinary breadth of its Fellowship which permits it readily to draw upon advice from experts in environmental research, management and protection, engineering, nuclear decommissioning, geosciences and resource management, in preparing this paper.Whilst we appreciate that there are many technical issues subsumed in the detailed questions posed by the consultation, the questions themselves are derived from underlying assertions and assumptions that need to be set out and addressed.We believe that it would be useful for us to concentrate on these prior strategic issues before addressing the consultations detailed questions in the appendix to this paper.Where appropriate, we have cross-referenced these comments to the Policy document and the Environmental Report.We have also drawn upon international experiences to illustrate some points.We would be pleased to discuss further any of the issues raised in this paper with the Scottish Governments Radioactive Waste Team. 3 We draw from this a crucial lesson, that whereas Government should set objectives, it should refrain from over-prescribing the technical means by which such objectives are to be achieved. Given the long lead-time for full implementation of a strategy, closing-off options by such over-prescription can be unnecessarily costly and technologically sub-optimal. We suggest that the policy objectives in relation to the management of higher activity radioactive wastes should be very simple: to produce a strategy that optimizes between minimising human and environmental health impacts, in both the short and long term, and minimising costs. The decisions taken now will set the trajectory of a long term strategy. It must not burden future generations with risks to health or of excessive costs. Because of the above considerations, we suggest that pre-determined technical constraints such as restrictions on the depth of burial of any managed site or the application of a proximity principle should be relaxed. Such issues should be the outcome of a rigorous safety case, not as prior constraints on it. Given the long time period over which a strategy will be implemented, and the inevitability of new technical developments that provide hitherto unanticipated options, it is crucially important that the strategy is developed and decisions are made in such a way as not to close off options. For example, the Canadian Governments Nuclear Waste Management Organisation has developed a process that it terms Adaptive Phased Management, which takes both technical and societal factors into account, builds in sequential decision-making, preserves flexibility during implementation, and utilizes the best features of a variety of initial options by implementing them in a staged and integrated strategy.

Principles Derived from History and International Examples

2 The hitherto unrecognized urgency to develop a strategy for the management and ultimate disposal of radioactive waste in Britain was first set out by the Royal Commission on Environmental Pollution in 1976, which stated that: it would be morally wrong to commit future generations to the consequences of fission power on a massive scale unless it has been demonstrated beyond reasonable doubt that at least one method exists for the safe isolation of these wastes for the indefinite future. [para 181, p 81]1.The succeeding thirty years were characterized by a series of initiatives to develop new policies and to find new sites for deep disposal, each new effort being characterized by a short lead-time for the establishment of a long-term strategy.These efforts made very little progress. Elsewhere, efforts to develop policy on a more measured basis were more successful, for example in Sweden, which adopted a more deliberate policy based on initial, politically determined objectives followed by careful scientific analysis of options and public and community engagement that took place long before the crucial step of site selection. The UK approach illustrated that more haste was less speed, and, by default, demonstrated the importance of not foreclosing options by reaching premature technical conclusions.

Basis of the Proposed Policy for Scotlands Higher Activity Radioactive Waste
6 As indicated in paragraph 3, whilst it is proper for Government to set the high level objectives of policy, it is crucially important that the framework which is developed is capable of being sustained for the long-term, that it provides scope for a holistic consideration of the policy landscape and that it does not impose arbitrary restrictions from the outset. With these provisos in mind we agree with the broad aim of the Policy (section 1.04.02 of consultation) which focuses on the protection of the health and interests of people and the integrity of the environment, acknowledges the risk of foreclosing future options, takes into account cost and affordability, and public and stakeholder confidence. It also aligns with the fundamental policy objectives that we have suggested in paragraph 3.

1 The 6th report on Nuclear Power and the Environment;The Royal Commission on Environmental Pollution; 1976. http://www.rcep.org.uk/reports/index.htm

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7 However, we are concerned that the current consultation documents do not provide a comprehensive basis for developing a policy which meets the objectives referred to in the preceding paragraph.They make too many a priori assumptions which, in turn, reduce the range of options available, with the potential to increase risk and cost.We address these points in the following sections. The consultation documents do not present the rationale for the Scottish Governments refusal to endorse CoR WMs2 recommendation that geological disposal represents the best available long-term approach compared to other forms of management. Whereas it is important for government to express views about values, costs and principles, it should not reject out of hand a technical solution from a formal advisory body without expressing a clear rationale for doing so. Decision-making which arbitrarily closes-off options is likely to increase the risk of system inefficiency and unnecessary cost.The Scottish Government should relax this constraint on the disposal of waste. In terms of reasonableness and robustness of process, the scientific and technical case for and against deep geological disposal should be openly considered as one of a number of options to be evaluated before deciding whether or not it is to be retained as an option. It is more effective and more efficient to define a simple overarching policy objective that provides the frame for an optimal technical strategy in response to the policy imperatives. 10 In relation to potential High Level Waste in particular, it is important that Scotland is aware of and involved in current discussions about proliferation resistance taking place at UK and international levels.The document currently makes no mention of the issue. 11 Similarly, it is also important to account clearly for those Intermediate Level Waste streams that are not covered by the Policy and those that cannot be designated for near surface disposal because of their properties.The Intermediate Level Waste and Low Level Waste streams not covered by the Policy should be described and possible disposal routes indicated.The Scottish Government should therefore ensure that there is a thorough consideration of the entire waste inventory within the Policy and all waste streams should be embedded in a broad framework of policy.The potential costs of not doing so could be very large.

Closing-off Options
8

Policy Optimisation
12 Section 3.03.15 of the consultation states that the definition of near site for the Policy is based on the proximity principle.We note that the Policy requires compliance with the appropriate regulatory requirements and planning consent procedures. However, the proximity principle is not enunciated with the clarity that characterises the rest of the Policy document. It appears as a vague and imprecise concept. Although there are useful illustrations of how the near site concept might work, there is a pressing need for a clear explanation of the proximity principle, of proximity scenarios and how proximity would take account of other variables that would influence the siting of a storage or disposal facility. 13 We are strongly of the view that the Policy should be formulated in terms of optimisation. For example, there is a distinct risk that the proximity principle could act as an arbitrary barrier to an optimal solution. Having optimisation as a key driver of policy would include optimising for the treatment, storage and disposal of different waste streams, take account of the protection of human health and the environment, and cost and affordability.Thinking in these terms would be an efficient and effective way of ensuring that all options are considered and appropriate technical responses to policy priorities can be developed within a frame of optimisation. Such an approach would also mean that options would not be prematurely or arbitrarily closed-off, which is a serious problem for the current Policy.

The Need to Ensure that the Policy considers all Waste Streams
9 Closely aligned to the comments we have made in paragraphs 6 8, we believe that it is inefficient to develop a policy that does not also cover High Level Waste (section 2.01.04 of consultation).Although there is currently no High Level Waste in Scotland, it seems to be clear from section 2.01.05 of the consultation that if radioactive substances and material which are not currently classified as radioactive waste, were to be classified as waste in the future, it is probable that most of them would be deemed to be High Level Waste and as such, not covered by the Policy.Although it is stated that the Scottish Government would need to review its Policy to consider the impact of any such classification changes, for completeness and in order to provide stakeholders with a degree of confidence and certainty, it is important that such waste, radioactive substances and materials are considered and included in the Policy. Failure to anticipate this in a developing technical strategy could considerably increase costs.

2 Managing Our Radioactive Waste Safely, CoRWMs recommendations to Government; July 2006. http://www.corwm.org.uk/Pages/Lnk_pages/key_issues.aspx

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Defining Terms
14 In this section we make further comment on some of the terms as defined in the Policy document. Long-Term 15 The consultation document (section 3.03.05) appears to misrepresent the detail of the timescale of institutional control. It states that,it is now generally accepted, as a matter of custom and practice, that 300 years is an acceptable period for institutional control... However, as we understand the situation, 300 years is accepted as a maximum period over which one could claim to have institutional control. 16 Furthermore, at sections 3.03.06 to 3.03.08, the consultation states that long-term, when applied to a storage facility, would be at least 100 years. Disposal facilities would be required for much longer time periods. However, in optimisation terms, the ultimate disposal route would need to be determined at an early stage in order that the most efficient interim management route is taken. Near Surface 17 At section 3.03.11 of the consultation, it refers to at depths down to several tens of metres below the surface.At present, this concept is too vague and must be clarified. Our preference would be for it to be removed entirely, and for it to be replaced by the optimal route that is consistent with a strong safety case. Similarly, in the same section there is reference to the role of rock structure as a barrier.Again, this needs to be clarified as it is not clear how this would differ from true geological disposal if the rock is given an environmental safety function. Furthermore, the nature of the safety function requires further explanation, for instance would the rock be part of a multi-barrier arrangement? 19 Given the nature of the industry and the need to ensure continued good governance and collaboration, it is logical for Scotland to be considered within the UK context.The NDA is a very broad-based agent with considerable responsibility and capacity for implementation of the programmes for interim storage and geological disposal for higher activity waste arising in the UK. However, there is concern that the NDA could not be entirely responsible for the implementation of Scotland's Policy as it does not have control over commercial and other nuclear activity in Scotland (e.g. BE, MoD).The Scottish Government would need to make arrangements for a competent authority to develop a strategy for implementing the Policy. 20 In these respects, whilst we recognise that work is ongoing, we are concerned that the present Policy does not set out adequate coordination mechanisms for an implementation structure.This could be a material impediment to stakeholders taking the Policy forward.

Full Engagement with Citizens

21 Historically, governments have found it difficult to implement policies that involve complex issues of science and technology, primarily because of their failure to identify and engage effectively with public concerns. As indicated in paragraph 2, public trust in government in the UK has been damaged by its previous handling of the disposal of nuclear wastes, which has led to a perennial failure to create acceptable and effective public policy.Against this backdrop we note that one of the largest public consultation exercises ever conducted in the UK was undertaken by CoR WM as part of the process that reached the conclusion that the most suitable, publicly acceptable option for the long-term management of high activity radioactive waste is deep geological disposal. 22 We are seriously concerned that the public acceptability of the Scottish Policy is not discussed at any significant length in the documents. It is an error that has accompanied the early stage development of many technologies, only to find that dawning public awareness and objections to what is being proposed jeopardise implementation. Although the Policy includes the aim of inspiring public and stakeholder confidence, we are concerned that this might deteriorate into an operational policy of decide and tell.We would prefer that the aim of the Policy should be to develop a strategy that is consistent with public values, and that this is ensured through a legitimising process of public engagement.This must include the public outwith existing nuclear sites and communities.Whilst engagement with site stakeholder groups and other stakeholders has, to date, been good in terms of communication and discussion, it is not clear how this has been used to develop the Policy.

Scotland within the UK and International Context

18 Internationally, a great deal of consideration has been given to the need to develop processes for the management of radioactive waste, including appropriate means for scoping key technical issues.There are opportunities for integrated nuclear production and waste processes that take account of safety, security, proliferation and cost implications. It is clear that in global nuclear industry terms, Scotland is a very small participant and must be prepared to learn from the expertise and experience of others. It is crucial that the Scottish Government apprises itself of these developments and fully considers how policy developments within Scotland are positioned with respect to the UK and international context, including issues of nuclear proliferation and security.These are significant omissions from the current policy documents. 4

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At 4.05.04 of the consultation document it appears that meaningful engagement with local communities will not take place until plans for treatment, storage or disposal facilities are actually being developed.To-date, engagement with people outside the immediate stakeholders appears to have been minimal, and needs to be given greater prominence if the Policy process is to be seen as legitimate. 23 These difficulties for governments have been compounded by enhanced public expectations of involvement in decision-making on complex technical issues with, so far, no commensurate procedures for managing the conflicts and vociferous minority opinions that often emerge in such situations. In view of the likelihood of a complex array of public responses, it is imperative that public engagement and dialogue starts very soon, with the intention of creating a degree of public consensus prior to the implementation of the Policy. Running the process of public engagement will thus be an important task in itself, if it is to be usefully linked to the policy development process. For major issues of considerable public concern, processes of public dialogue need to be far deeper than the conventional consultation exercises routinely carried out by government. Deliberative dialogue is a means whereby such difficult issues can be addressed. 24 In the Policy consultation and Environmental Report there is no mention as to whether communities would be invited to volunteer to host a facility or other mechanisms would be adopted to select a site. Irrespective of what process is adopted, it would be helpful if the Policy stated whether communities would be entitled to benefits for contributing a national good.We note that the UK Government has published a White Paper3 setting out the framework for implementing geological disposal, and an invitation to communities to discuss hosting a geological disposal facility.An approach based on voluntarism and partnership as part of the process for the siting of disposal facilities has been developed in a number of countries. For example, in Belgium there are opportunities for communities to derive socio-economic benefits from hosting a waste facility. add to the progressive loss of the existing skills base. Once lost, such expertise will be difficult and expensive to recreate.Although the Policy document refers to Skills (section 4.05.02 of consultation), it places the onus on waste owners, producers and facility operators, rather than ensuring the public interest through consideration of a skills strategy. It is important that those guarding the public interest are able to be intelligent consumers. Appendix: Responses to Specific Questions in the Consultation Document Question CD1 Have we explained what Waste we have in Scotland and how it is managed? 1 Yes, but the explanation and coverage is only partial. Please see paragraphs 9 to 11 of our response which set out in more detail the importance of ensuring that there is a thorough consideration of the entire waste inventory within the Policy and all waste streams should be embedded in a broad framework of policy. Question CD2 Have we explained why we need to define the terms used in the Policy? 2 Yes, but the explanation has limited scope.As we have set out in paragraph 8 of our response, the Policy documents do not present the rationale for the Scottish Governments refusal to endorse CoR WMs recommendation that geological disposal represents the best available long-term approach compared to other forms of management. It should not reject out of hand a technical solution from a formal advisory body without expressing a clear rationale for doing so. Decision-making which arbitrarily closes-off options is likely to increase the risk of system inefficiency and unnecessary cost. 3 We suggest that the policy objectives in relation to higher activity radioactive wastes should be very simple: to produce a strategy that optimizes between minimising human and environmental health impacts, in both the short and long term, and minimising costs.As set out in paragraph 13 of our response, we are strongly of the view that the Policy should be formulated in terms of optimisation. Thinking in these terms would be an efficient and effective way of ensuring that all options are considered and appropriate technical responses to policy priorities can be developed within a frame of optimisation. Such an approach would also mean that options would not be prematurely or arbitrarily closed-off, which is a serious problem for the current Policy.

National Capability and Skills Base

25 For effective implementation of the Policy, thorough consideration must be given to invigorating the skills base.There is a major concern, particularly in the longer term, as Scotland's nuclear industry is being run down, that there will be a deficit of technically-skilled people to implement the Policy. Furthermore, competition for skills outwith Scotland, and in particular from companies involved in new build elsewhere, may lead to a considerable skills, capacity and capability gap to

3 A Framework for Implementing Geological Disposal;A White Paper by Defra, BERR and the devolved administrations for Wales and Northern Ireland; June 2008 http://mrws.decc.gov.uk/en/mrws/cms/home/What_is_the_Go/What_is_the_Go.aspx

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4 We suggest that pre-determined technical constraints such as restrictions on the depth of burial of any managed site or the application of a proximity principle should be relaxed. Such issues should be the outcome of a rigorous safety case, not as prior constraints on it. We provide further comment on the definition of the terms used in the Policy in response to questions CD3 to CD11. 11 Given the long time period over which a strategy will be implemented, and the inevitability of new technical developments that provide hitherto unanticipated options, it is crucially important that the strategy is developed and decisions are made in such a way as not to close off options. Question CD8 Do you agree with the definition of monitorable? 12 This definition would benefit from further explanation. It remains unclear as to what would be monitored, how it would be undertaken and assured.The Policy could usefully direct the regulators to ensure appropriate monitoring mechanisms are put in place. Question CD9 Do you agree with the definition of retrievable? 13 If retrievability is to be built into the disposal option, it is not clear to us how this would differ from storage over the timescale of institutional control.We understand that there are regulatory differences, especially in terms of permitting, but it remains unclear how this would play out in practice. Question CD10 Do you agree with the definition of the need for transport over long distances is minimal? 14 We are strongly of the view that the Policy should be formulated in terms of optimisation. Please see paragraphs 12 and 13 of our response for more information. Question CD11 Do you wish to propose any other definitions? 15 At this point we would wish to reiterate that whereas Government should set objectives, it should refrain from over prescribing the technical means by which such objectives should be achieved.We suggest that the policy objectives in relation to higher activity radioactive wastes should be very simple: to produce a strategy that optimizes between minimising human and environmental health impacts, in both the short and long term, and minimising costs. 16 Please refer to paragraphs 3 and 8 to 13 of our response for more information. Question CD12 Have we explained the implications of the Policy? 17 Yes, to a certain extent, but there are significant omissions.

Question CD3 Do you agree with the definition of long-term? 6 Please see paragraphs 15 and 16 of our response.

Question CD4 Do you agree with the definition of near surface? 7 No.This concept is too vague and should either be removed entirely or clarified. Please refer to paragraph 17 of our response for further explanation.

Question CD5 Do you agree with the definition of near site? 8 No.The definition of near site for the Policy is based on the proximity principle. However, the proximity principle is not enunciated with the clarity that characterises the rest of the Policy document. It appears as a vague and imprecise concept.Although there are useful illustrations of how the near site concept might work, there is a pressing need for a clear explanation of the proximity principle, of proximity scenarios and how proximity would take account of other variables that would influence the siting of a storage or disposal facility. Please refer to paragraphs 12 and 13 of our response for further information.

Question CD6 Do you agree with the definition of storage? Question CD7 Do you agree with the definition of disposal? 10 In response to these two questions, whereas Government should set objectives, it should refrain from over-prescribing the technical means by which such objectives are to be achieved. Given the long lead-time for full implementation of a strategy, closing-off options by such over-prescription can be unnecessarily costly and technologically sub-optimal. We suggest that the policy objectives in relation to the management of higher activity radioactive wastes should be very simple: to produce a strategy that optimizes between minimising human and environmental health impacts, in both the short and long term, and minimising costs. The decisions taken now will set the trajectory of a long term strategy. It must not burden future generations with risks to health or of excessive costs. 6

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18 We are seriously concerned that the public acceptability of the Policy is not discussed at any significant length in the documents.Although the aim of the Policy includes inspiring public and stakeholder confidence, the key point must be to ensure that there is a process of legitimate engagement.This must include the public outwith existing nuclear sites and communities. It is imperative that public engagement and dialogue starts very soon. Managing the process of public engagement will be an important task in itself, requiring a carefully constructed strategy to link it to the policy development process. 19 Furthermore, effective implementation of the Policy will require thorough consideration to be given to invigorating the skills base.There is a major concern, particularly in the longer term, as Scotland's nuclear industry is being run down, that there will be a deficit of technically-skilled people, to implement the Policy. Preservation of the skills in this area would be valuable and only prompt action will prevent further loss of expertise. Once lost, such expertise will be difficult and expensive to recreate. 20 Please see paragraphs 21 to 25 of our response for further details. Question CD13 Do you agree with the application of the Waste Hierarchy? 21 Yes, but further clarification and explanation are required. 22 We note that there is a national policy supporting metals recycling, even if some discharges result. Therefore it is essential that the regulations in relation to this are effective in protecting public health even in the light of the professed imperative to balance health risk against net benefit of recycling for waste minimisation. 23 The destiny of recycled waste also needs further explanation as it is more acceptable for the waste to be re-used in the nuclear industry than for it to be used on other sectors. Question CD14 Do you agree with transport of the Waste for treatment? 24 We are strongly of the view that the Policy should be formulated in terms of optimisation. Please see paragraphs 12 and 13 of our response for more information. Question CD15 Do you agree with export of the Waste for treatment? 25 We are strongly of the view that the Policy should be formulated in terms of optimisation. Please see paragraphs 12 and 13 of our response for more information. 7 Question CD16 Do you agree with the need to develop a Strategy to implement the Policy? 26 Yes.Whilst we recognise that work is ongoing, we are concerned that the present Policy does not set out adequate coordination mechanisms for an implementation structure.This could be a material impediment to stakeholders taking the Policy forward. 27 It is imperative that implementation of the Policy is associated with legitimate processes of public engagement and dialogue. Please refer to paragraphs 21 to 24 of our response. Question CD17 Do you agree that the Nuclear Decommissioning Authority (NDA) should be responsible for developing the Strategy to implement the Policy? 28 Given the nature of the industry and the need to ensure continued good governance and collaboration, it is logical for Scotland to be considered within the UK context.The NDA is a very broad-based agent with considerable responsibility and capacity for implementation of the programmes for interim storage and geological disposal for higher activity waste arising in the UK. However, there is concern that the NDA could not be entirely responsible for the implementation of Scotland's Policy as it does not have control over commercial and other nuclear activity in Scotland (e.g. BE, MoD).The Scottish Government would need to make arrangements for a competent authority to develop a strategy for implementing the Policy. Question CD18 Do you agree with the proposal to review the application of the Detailed Statement of Policy 10 years after it is published? 29 Yes. Given the long time period over which a strategy will be implemented, and the inevitability of new technical developments that provide hitherto unanticipated options, it is crucially important that the strategy is developed and decisions are made in such a way as not to close off options. 30 However, it is important that there is a thorough consideration of the entire waste inventory within the Policy from the outset and all waste streams should be embedded in a broad framework of policy.The potential costs of not doing so could be very large. 31 Please refer to paragraphs 9 to 11 of our response for further details.

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Question CD19 Have we adequately explained the Regulatory Framework for managing the Waste in Scotland? 32 Yes, we note that the Policy requires compliance with the appropriate regulatory requirements and planning consent procedures. 33 However, it appears to us that engagement with people outside the immediate stakeholders appears to have been minimal, and needs to be given greater prominence if the Policy process is to be seen as legitimate. Please refer to paragraphs 21 to 24 of our response. Question CD20 Does the Proposed Detailed Statement of Policy include all relevant issues? Question CD21 Should the Proposed Detailed Statement of Policy include anything else? 34 In response to these two questions please refer to our full response which raises key strategic issues which require to be considered.

Additional Information This response has been produced by an expert group on behalf of the Society. It has been signed off by the General Secretary on behalf of Council. Any enquiries about this submission and others should be addressed to the RSEs Consultations Officer, MrWilliam Hardie (evidenceadvice@royalsoced.org.uk). Responses are published on the RSE website (www.royalsoced.org.uk).
Advice paper (Royal Society of Edinburgh) ISSN 2040-2694

The Royal Society of Edinburgh (RSE) is Scotlands National Academy. It is an independent body with a multidisciplinary fellowship of men and women of international standing which makes it uniquely placed to offer informed, independent comment on matters of national interest. The Royal Society of Edinburgh, Scotland's National Academy, is Scottish Charity No. SC000470