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
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 implicationsie 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 essentialpeople 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 viewfor
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
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 contextie what decision
has to be made at the point in timeis 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 processparticularly 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 sitethe
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
itselfwhat in the US is termed the "analytic-deliberative"
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
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:
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
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 participantseg
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 uniquedrawing on different generic
methods but being fundamentally appropriate to these decisions.
Professor Judith Petts
University of Birmingham
59 Petts J (2001) Evaluating the effectiveness of
Deliberative Processes. J of Environmental Planning and Management,
44(2), 207-226. Back