Multi-level hybrid approach to implementation
It can be seen that the implementation actors are operating at multiple levels. Central actors are responsible for establishing the framework for implementation (Part A) and for driving the process forward, whilst local actors are necessary for the “volunteerism” process to have effect (Part B). This is perhaps critical for a policy that is intended to deliver a piece of critical national infrastructure, whilst being inherently dependent on local decision making.
The implementation strategy follows similar lines, with “top down” and “bottom up” approaches (summarised in Sabatier, 1986) combined to form a hybrid model. Part A is being delivered by NWS and NDA, working directly for Government. NWS has the sole mission of managing the UK’s radioactive waste, with implementation of this policy comprising over half of its expenditure (NDA, 2022[1]). Therefore, there is very strong alignment between the goals of NWS and this policy. Indeed, the policy defines NWS’s role making it a legal requirement, aligning with a key aspect of the top-down approach as described in Sabatier (1986, p23).
This contrasts with Part B, with implementation delivered at the local level and entirely dependent on a group of people within a community coming together of their own free will, to express an interest in participating in the process. If this group decide to enter into the process they form a Community Partnership to represent a locality. The Government has no direct control over this process, instead simply asking communities whether they are interested or not. Given the controversial nature of radioactive waste management, the goals of any given community could be in direct conflict with the intention of the policy, which aligns more with bottom-up approaches (see Sabatier, 1986, P32). Whilst this may at first appear doomed to failure, many nuclear countries around the world have adopted this approach believing that it is the most likely route to local consent for a facility (IAEA, 2022).
The policy recognises the need for flexibility at the local level to achieve success, another aspect of bottom-up approaches. This accommodates different administrative structures and local interests in communities that might express an interest (BEIS, 2018 Ch. 6). For example, areas with a history of nuclear industry activity may wish to maintain the industry in their areas, whilst other, non-nuclear, communities may be interested in bringing a project to their area with a significant amount of investment and long term jobs.
Matland’s Conflict Ambiguity Model
Implementation aspects A and B also differ when considered under the lens of Matland’s Conflict Ambiguity Model (Matland, 1995). Part A is firmly in the Administrative Implementation category: the goals of the policy are very clear (low ambiguity) and, as noted above, the mission of NWS is directly aligned to the goals of the policy (low conflict). Additionally, the UK Government is providing significant resources to support delivery of the policy.
For Part B, the goals of the policy are clear and the expectations on the partnerships are also clear (low ambiguity). What differs is that the actors involved in implementing Part B, particularly the public, may have very different perspectives on the best outcome. Central actors will be supportive and Community Partnerships are clearly open to the idea; however, the public will hold numerous perspectives on the benefits and disadvantages of hosting a GDF and consequently whether or not the development should go ahead. There is therefore the potential for high conflict, placing Part B in the Political Implementation category.
The public in an area of interest will have the opportunity to engage with the process through dialogue with the various central actors involved in the development of a GDF (mostly NWS and Regulators). Dialogue is facilitated by the Community Partnership, who will be provided with suitable resources to enable these discussions and to undertake research to respond to questions from the public. However, the community holds significant power until late in the process, when the Test of Public Support will be undertaken, which presents a significant risk to policy implementation. A consideration of the Government's approach to managing this risk is provided below, by reference to Hudson et al’s (2019) concept of a Policy Support Programme.
Managing risk through policy support
In addition to the risk associated with the Test of Public Support, Community Partnerships retain a right to withdraw from the process until the Test of Public Support. A decision to exercise the right of withdrawal may be driven by any number of factors, including: public opinion; a lack of transparency; unclear benefits; or as a response to a nuclear incident elsewhere in the world.
NWS’s role has been described above as setting up the framework for decision-making, suggestive of a neutral and administrative position. However, in practice, NWS has a critical role in managing the risk associated with the right of withdrawal and the Test of Public Support. NWS’s role can be considered against the key elements of a Hudson et al’s “policy support programme” concept, as shown in Table 2.