Submission Impossible: SA Royal Commission into nuclear fuel cycle

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The SA Royal Commission into the nuclear fuel cycle is calling for submissions but the mechanics involved have made it Submission Impossible, writes Noel Wauchope.

THE SOUTH AUSTRALIAN Labor government has ordered a Royal Commission, to inquire into the Nuclear Fuel Cycle: ‘Investigating opportunities and risks for South Australia’. This fast moving Royal Commission will receive submissions on this topic

All sounds good, doesn't it? And who is supposed to send these submissions in? Well, any person or organisation in South Australia. As the Royal Commission (RC) has received little or no publicity outside South Australia, then it is likely that submissions will not be appreciated nor forthcoming from the other States.

However, the RC has invited nuclear technology companies from overseas, to put in submissions.

The RC has published four Issues Papers, with points for discussion. I could digress here, into the wording of these points, which are very much geared to receive input from nuclear companies.  But my interest here is not so much in the content of submissions, but rather in the mechanics of actually writing, and sending in a submission. Submissions are due by 24 the July (for two Issues Paper topics) and by 3rd August (for the other two) 

(Cartoon by Noel Wauchope)

This is what is required:

  • First, go to the RC's website, Click on ISSUES PAPERS, and read the papers for each Issue.
  • Note the question points for each paper, e.g. for Paper 1  (Exploration, Extraction and Milling) - 1.1 to 1.13.
  • Then on that page, click on Submissions Guidelines.
  • You are required to write only about the questions stated, and are not to write about anything outside those questions (but you may write on other topics, separately, as an appendix) 
  • Submissions should be typed with the question numbering as set out in each ISSUES PAPER.
  • Find on the website the SUBMISSION COVERSHEET.
  • Print out this Coversheet. (it will be required for your details, and for witnessing by a Justice of the Peace). 
  • Print out all pages of your Submission with page numbering.
  • Take all pages and your Cover Sheet to a Justice of the Peace or a Commissioner for Affidavits.
  • In front of the JP or Commissioner, swear an oath or make an affirmation. You must sign each page of your submission, and the JP must witness your signature and sign. These two    signatures must be on the Cover Sheet, and on each page of your Submission.
  • Make sure that your contact details on the cover sheet are correct.
  • Scan your pages into the computer.
  • Transfer them to PDF format, and in a text searchable form (OCR) . The Commission prefers to receive submissions electronically.
  • They can be sent either by email (submissions@nuclearrc.gov.au), or by directly uploaded through the RC's website. (the method for the latter is not explained}.
  • Submissions can be sent by post, though this is not the RC's preference.

Well, I'm thinking that the mechanics of this exercise pretty well trumps the content.

Imagine the scene ... scenario 1: 

You're an executive of the French nuclear company AREVA, or of the Canadian nuclear company, SNC-Lavalin. (AREVA is in desperate financial straits and SNC-Lavalin in strife for corrupt practices). See report in the Financial Times 4 June 2015 ‘AREVA loses its reactor heart to EDF under French state plan’. Both companies are absolutely dependent on selling their nuclear technology overseas. 

You have access to highly paid top lawyers, nuclear lobbyists and strategists, and access to top electronic equipment and computer skills. Indeed, this sort of thing is their job, and the company is well pleased to give them time to do this submission very thoroughly.

Submissions from a nuclear company do not need to be published. The Royal Commission deems that they can be kept private.

Imagine the scene ... scenario 2:

You're an ordinary citizen of South Australia, perhaps living in a rural area.  Do you have access to the Internet, for a start? Well, you could make the effort, using a town library's facilities.  Then there's the printing off of the ISSUES PAPERS, with those required question points. Then there's the typing and printing of your Submission ....   the JP .... the scanning ... the PDF .... and so on. Your Submission  will be published  on the Internet, with your name.

What if you're an Aboriginal, and your command of English is not great?   No problem. The RC will send an officer to guide you.  Mmmm ... is there a problem in this?

I haven't even touched on the content. I wonder ... do I really need to?

Q. How much will the RC cost taxpayers? A. Errrh ... we don't know ... maybe $ tens of millions!

Most of the questions appear to me to be squarely aimed at the nuclear companies.

For example:

Question 3.1  What might be necessary to encourage further exploration for uranium and thorium? What might be done to promote viability? Are existing government plans sufficient? Could support be provided in other ways and, if so, how could that be done most effectively?

Question 2.13  What financial or economic model or method ought be used to estimate the economic benefits from South Australia’s establishment and operation of facilities for the conversion, enrichment, fuel fabrication or reprocessing of, or the manufacture of materials containing, radioactive and nuclear substances

Some people have criticised the plentiful graphs and diagrams in the Issues Papers as sometimes inappropriate. I don't know. It hardly matters. Many ordinary people, who are worried about the prospect of the entire nuclear fuel chain being established in South Australia will be sufficiently intimidated by the whole process anyway — never mind the graphs, or even the written content.

Perhaps that was the Royal Commission's intention?

You can follow Noel on Twitter @ChristinaMac1.

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