Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Memorandum submitted by Professor Judith Petts, Head of School of Geography and Environmental Sciences, University of Birmingham

  1.  This evidence refers specifically to the discussion of "A Public Debate" in DEFRA's 2001 Consultation Document "Managing Radioactive Waste Effectively". It draws upon my experience over 18 years of public response to risk issues and research work for government departments and local authorities looking at how to optimise discussion at the interface between science and society in decision-making. Particularly over the last decade I have been involved in developing and evaluating new approaches to public engagement in decisions relating to municipal waste management.

  2.  The latter is similar to radioactive waste management in a number of respects: people are often lacking in information about waste issues and the organisations and decision responsibilities involved; significant risk issues arise; technical and complete information has to be discussed; there is scientific uncertainty surrounding some environmental and health impacts; specific facilities and proposed locations raise concerns in local communities, and rarely are there simple solutions to choice of method and location. The primary difference between municipal and radioactive waste management, are that the former is familiar and perceived to be controllable and the latter raises issues of equity that have national implications—ie potentially just one facility in one location for the whole country but with impacts beyond that community.

  3.  DEFRA's consultation places considerable emphasis on the need to provide more opportunities for public participation in decisions relating to radioactive waste management. This is an important and welcome policy statement.

  4.  However, in common with many official discussions on public participation there is an immediate focus on the techniques of participation. Duplicating many other reports and recent guidance DEFRA's consultation lists a number of methods ranging from those that aim merely to provide information to those that seek to provide for extended involvement. Correctly DEFRA suggests that any strategy for engaging people will need to combine techniques by which small numbers of people are engaged in intense deliberation and those whereby larger numbers of people may be able to express an opinion but not take part in discussion.

  5.  Multiple Methods: All experience of public participation exercises shows that integration of multiple methods is essential to ensure that the number of people who can contribute is extended and that the full range of potential views on the subject is identified. However, it is also shown that basic information provision is essential—people cannot take part in any form of activity (passive or active) unless they have information. In deliberative processes the evidence is that it can take several sessions before people feel able to contribute to the discussion when new and complex material has to be dealt with.

  6.  Representation: DEFRA's document has incorrectly referred to Community Advisory Committees and Citizens' juries consisting of people who represent a particular community. This is to confuse issues of representation and being representative of interests. Both of the particular techniques as used in Britain tend to focus on the latter. Here the aim is to recruit people who are thought to be representative of the range of interests and activities that exist in a community (eg business, education, health, community, environmental, religion), but these people are not asked to represent any particular view—for example a person who is recruited because they have environmental interests as a member of a local conservation group, does not take part as a representative of that group, speaking on its behalf. This difference is important, not least because it enables engagement with people who may not normally have an opportunity to participate and who are more likely to be indicative of broader societal views and interests.

  7.  Defining Objectives: This discussion serves to raise my primary criticism of the consultation document and that is that there is no detailed discussion of the objectives of engaging the public, other than "to earn support". All of my experience of public participation, and certainly all of the literature on the subject stresses the importance of (i) defining the objectives of participation relevant to the specific decision context, (ii) identifying the appropriate methods to fit the objectives and (iii) identifying the participants' objectives and if necessary amending the process/method to ensure that their objectives can be met.

  8.  The decision context—ie what decision has to be made at the point in time—is important. The UKCEED consensus conference attracted some criticism from participants because it was not clear how the conference's conclusions and recommendations were to be taken on-board in any decision. Evaluations of public participation show that people want to be able to influence decisions and want to see how their views have been dealt with. If this does not happen then there is the potential for suspicion that the participation exercise was just a PR exercise.

  9.  Objectives will vary at different stages of a decision process—particularly one where we may have to move from policy decisions relating to need and the options for disposal through to selection of sites and the siting decision itself. This means that any programme of participation will need to be developed with different methods for different stages. Different participants will also be relevant, although it is essential to understand that it is very difficult to separate identification of the best option from identification of the best site—the two are intrinsically linked (not least in terms of environmental impact). Unfortunately our legislative systems are poorly structured for dealing with this linkage.

  10.  Engagement in the Assessment: Processes of public participation are often more focused on asking people for their views than actually engaging them in processes of data collection, and risk and environmental assessments. Site selection is often a technocratic process done behind closed doors. There is much focus now on how to engage people in the assessment process itself—what in the US is termed the "analytic-deliberative" process.

  11.  Participation that engages people in the technical debate including the choice of scenarios and assumptions, the identification of data sources, the criteria of acceptability that should underpin the decision, and in understanding of the complexities, and sources of uncertainty, provides for quality assurance and also greater understanding of the difficulties inherent in decisions of this nature. This is the area of greatest development need in terms of public participation but it is not one that appears to be recognised in the consultation. There is some developing experience in municipal waste management of the engagement of people in environmental assessments and in the process of defining siting criteria.

  12.  Participation in the assessment process of course places new pressures on experts in terms of having their science cross-examined and hence on their training needs. It can lengthen a decision process.

  13.  Participation in the assessment itself may involve subsets of a broader public. Experience in Europe is that it is important that the broader public can identify who will take part in the assessment process on their behalf, and the reporting mechanisms that will be needed to cascade findings to the wider community.

  14.  Dealing with Activists: Radioactive waste management is an issue with defined and organised interest groups some fundamentally opposed to the generation of the material, others who will oppose solutions in their locations. Vocal activists play an important role in often mobilising public questioning. The latter may be uncomfortable for decision-makers and the organised activist can be a difficult element to manage. Local authorities who have experienced the problems first-hand are adopting proactive strategies for responding to the "difficult objector".

  15.  However, activists are also "managed" by members of the public when they come into direct contact. When "ordinary" members of the public are engaged in the debate and have an opportunity to understand the issues there is direct evidence that they can regard the activist as not representing their views. The public are often seen to become concerned about the "loud voice" and to respond against this once they themselves are given the opportunity to engage and debate. If the general public are left out, this opportunity for "social management" of the activist is lost.

  16.  At this point it seems important to stress that organised interest groups should not be considered to represent the public view. They are important to engage with but different methods may be appropriate.

  17.  Which expertise?: The public are acutely aware of the uncertainties of scientific knowledge and that there is divergence of expert views (not only between official and counter expert groups but within them). The DEFRA consultation seems to suggest that an objective should be to ensure that "the right decision is being made". If this is to hint that there is a right decision and hence scientific view at the start then this will make engagement difficult. The public will often seek out opportunities to listen to, or read about, divergent views. In evaluations of waste management processes they have often requested that divergent views/information/data should be made available for them so that they can make up their own minds. There is evidence that people can balance contradictory information and can appreciate the need to weigh costs and benefits. Therefore, participation methods should ensure that opportunities are afforded for divergent views to be heard. This is hinted at by the DEFRA consultation when it summarises the results of research that suggests information needs to be provided in a neutral form outlining different opinions. However, this should not be read as suggesting that it is possible to anonymise information. People will always want to know the source and will respond to it depending on their views of the credibility of that source.

  18.  Is participation effective?: There is direct evidence that public participation raises issues and questions which are important in the decision; promotes better environmental assessment as the public identify elements missing from the assessment; brings local knowledge to decisions (for example about local environmental conditions) which may not be available from elsewhere; often correctly broadens the issues considered which institutional and statutory priorities may miss; acts as a quality assurance mechanism for technical and risk assessments, and promotes confidence amongst decision makers that they have heard different views and also have gained understanding of public concerns themselves.

  19.  Process not outcome: this summary emphasises that the process of participation is important. An effective process is one that[59]:

    —  Ensures that the participants are representative of the full range of people potentially affected and that barriers that may bias representation are minimised.

    —  Allows participants to contribute to the agenda and agree and influence the procedures and moderation method.

    —  Enables participants to engage in dialogue, and promote mutual understanding of values and concerns.

    —  Ensures that dissent and differences are engaged and understood.

    —  Ensures that experts are challenged and that participants have access to the information and knowledge to enable them to do this critically.

    —  Reduces misunderstanding and ensures that the authenticity of claims is discussed and examined.

    —  Makes a difference to participants—eg allows for development of ideas, learning and new ways of looking at a problem.

    —  Enables consensus about recommendations and/or preferred decisions to be achieved.

    —  Makes a difference to decisions and provides outcomes which are of public benefit.

    —  Ensures that the process is transparent and open to those not directly involved but potentially affected.

  20.  The DEFRA consultation asks how to build on existing initiatives that have largely asked people for their views about radioactive waste, they have not been asked to take part in any element of a decision. The fact that we do have a good understanding from such initiatives of what people think and what information they might need should provide a good basis for designing an effective process. However, what is needed now is a clear characterisation of the decisions that have to be made, by whom and over what timescale and for what purpose. Only then is it possible to design an engagement process based on the objectives to be met during any of the stages of the decision. This process will undoubtedly be unique—drawing on different generic methods but being fundamentally appropriate to these decisions.

Professor Judith Petts
University of Birmingham

November 2001

59   Petts J (2001) Evaluating the effectiveness of Deliberative Processes. J of Environmental Planning and Management, 44(2), 207-226. Back

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