Thanks to all who have signed the petition. Despite the thousands of signatures already, Cumberland Council continue to ignore our calls for a full debate and vote on the nuclear dump. Now they are writing a Local Plan to accommodate the dump.
Cumberland are asking for comments on their draft local plan before 31st October . Here is ours below.
You don’t have to answer their whole consultation document - the nuclear issue which pervades Cumberland and the wider Cumbria region touching all within the vicinity either directly or indirectly is barely mentioned and left until the second to the last question (of 172!)
Image: Trick or Treat? Or the double whammy of Trick and Trick? “heh heh you are already irreversibly blighted with nuclear waste so you might as well have an experimental nuclear dump for the worst of it and as a “Treat” you will be bribed with your own money from the public purse”.
People can write to the Council at: planningpolicy@cumberland.gov.uk
There is no need to fill in the whole consultation which can be found here, https://www.cumberland.gov.uk/planning-and-building-control/planning-policy/cumberland-local-plan
You may send a letter outlining the points you want to make.
Here is the reply to the consultation from Radiation Free Lakeland and Nuclear Free Local Authorities - please do feel free to use this as inspiration for your own letter.
Local Plan
Response by
Marianne Birkby on behalf of Radiation Free Lakeland
and Richard Outram on behalf Nuclear Free Local Authorities to Cumberland Council
Issues and Options Consultation - September 2025
The consultation document “identifies the key issues within Cumberland that we consider the Local Plan should address.” (1.14).
Question 1: Do you agree with the proposed Vision for the Cumberland Local Plan?
Answer: The rhetoric of the proposed Vision does not take into account the reality of Cumberland’s lived experience of hosting the Sellafield site. Due to the increasingly novel routes of nuclear wastes to the environment, the growth of an increasing number of nuclear licensed sites outside of the Sellafield site is not acknowledged. The “Vision” airbrushes out the environmental and public safety implications of Cumberland Council’s partnership with the developer for the biggest development ever in the UK – a Geological Disposal Facility for heat generating high level nuclear wastes.
Question 2: If not, please explain why and what changes should be made.
See answers to questions 76, 99, 100, 112, 114, 171
9. HEALTH AND QUALITY OF LIFE
Question 75
Should the Local Plan include a policy that requires a Health Impact Assessment to be submitted as part of planning applications? If yes, what would be the appropriate thresholds to apply for the requirement of Health Impact Assessment in terms of types and scale of development?
Answer: Health Impact Assessments should be carried out before planning consent is awarded to any developments encouraging people to engage in water sports or water based activities on the coast near Sellafield - this should be reassessed routinely and operations should be conditional. If it comes to light that health impacts are likely after consent is given and development is completed there should be a moratorium on continued operations.
CASE STUDY: The Edge, Whitehaven awarded planning consent without a Health Impact Assessment. Whitehaven Harbour is the scene of an ongoing pollution event with acid mine pollution continuing to pour into the harbour (since 2022). This metals pollution then combines with and enhances the impact of the existing radioactive burden including AM-241 in the harbour silt. The cumulative impacts on public health have not been assessed. Thresholds should include cumulative impacts over a period of time rather than a “snapshot.”
9.8 POLLUTION
Question 76
Are there any particular issues and areas of concern relating to the following issues that should be reflected in the Local Plan:
• Air Quality?
• Water Quality?
• Noise?
• Light Pollution?
• Odours?
Please give details of the issues and how they might be addressed in the Local Plan.
Answer: The section on Pollution makes no mention of the ongoing radioactive and chemical pollution from the nuclear industry. It is conspicuous by its absence. Sellafield can currently be found on multiple lists online of one of the top ten most radioactive zones in the world (here, here, here, here, here, here, and here) with several commenting on the wisdom of visiting such an area.
With decommissioning, this pollution is increasing, rather than decreasing. New nuclear sites and waste streams are increasingly handled away from the Sellafield site despite opposition from local businesses and campaigners in areas of conurbation such as Workington (e.g. Cyclife at Lillyhall, Energy Coast Laundry, Cyclife at Port of Workington).
CASE STUDY: Sellafield radioactive particle finds: “A total of 42 particles and 9 larger objects were detected and recovered” in 2024 (EM/2025/11)
Sellafield Particles in the Environment Update (End of Year 2024). These included a rock pool “stone” from Sellafield beach on 11/06/24 which at nearly one million becquerels (0.84MBq) was the “second-highest Cesium-137 activity measured in any find since the programme began”.
If this was in Scotland, the beaches in the vicinity would have been closed to public access as has happened at Dounreay, but instead children are actively encouraged to dig for hours in “beach events” near Sellafield. Increasing storm surges mean that historic (and new) radioactive particles in the seabed silts will continue to wash up on the beaches. This could however be mitigated by a ban on subsidence causing or earthquake inducing developments near, on or under the seabed in the vicinity of Sellafield. Nuclear wastes from Dounreay, Scotland have been transported to Cumbria.
Question 99
How can the Local Plan ensure that the most efficient use is made of land?
Answer: The Local Plan makes no mention of existing regulations in relation to developments in the vicinity of nuclear installations. These are regulations that Cumberland Council must adhere to.
Current assessments of the radiological hazards indicate that areas between 6.1km & 8km from the centre of the Sellafield Site would be the most likely areas to be directly affected during and following a radiation emergency, this area is the Detailed Emergency Planning Zone (DEPZ).
The Office for Nuclear Regulation has placed limits on developments within this zone: “The impact of any proposed development on an emergency plan depends on multiple factors including its size in terms of the population involved, the type of development (e.g. nursery or care home), transport infrastructure and any other special features that might affect protective actions required to be taken in the event of a radiation emergency. ANY proposed industrial and commercial developments in the vicinity of a nuclear site that have the potential to constitute an external hazard are of particular additional concern.”
Question 100
If the Local Plan does include a policy on housing density, should it:
Be one single standard across the whole of Cumberland? Or
Provide different densities in urban, suburban and rural areas?
What should the minimum density standards be?
Answer: Despite the desire to be ‘efficient’ in land use, the regulations require Cumberland Council to ensure that developments within a DEPZ remain limited, so a single standard would be inappropriate; and how urban or rural an area is cannot be the only way of determining appropriate housing density.
In Barrow, nearly 1000 new homes are built annually, which accommodates incoming workers to BAE. The anticipated Geological Disposal Facility (GDF) if it goes ahead, would very likely require an influx of new specialist workers. However, this situation would only last for as long as the GDF remained open, which means that housing developments created to accommodate them could potentially lose their value and become unfilled and run-down over time.
Question 112
Should the Council seek to define a “Developed Coast” and an “Undeveloped Coast”?
Answer: Besides the problems inherent with the idea that we can continue to develop sensitive, damaged coastlines with some ‘sensitively designed’ development, the Office for Nuclear Regulation (ONR) already places limits on developments within the vicinity of nuclear installations.
This should be reinforced in the Local Plan with a dedicated buffer zone of at least 6.1 km from the centre of the Sellafield site in the coastal area and coastal plain around Sellafield. This effectively bans any new developments (including nuclear developments) to afford some protection and peace of mind for those living within the vicinity of Europe’s (possibly the world’s) most dangerous nuclear waste site.
Question 114
Are there any issues relating to climate change which you think that the Local Plan needs to address that have not been identified in this chapter?
Answer: The council should be aware that risks related to climate change do not fall only under the headings of flood / water management and carbon emissions.
Although the full council has been denied a debate and vote, Cumberland Council are in Partnership with Nuclear Waste Services to use the sub-sea area of the Lake District coast and sub-sea geology as a giant heat sink.
This bypasses entirely the carbon emissions issue and goes straight to the heart of the matter - the production of insane amounts of heat which cannot be turned off, ever. Heat generating nuclear wastes are currently cooled at Sellafield with R1 (top quality) water from Wastwater, and the rivers Calder and Ehen.
If these wastes are abandoned in the proposed 36km square sub-sea mine, enormous heat would continue to be generated, peaking (it is thought) at around 200 degrees c. Leading geologists have warned that burying heat generating nuclear wastes has very poor implications for the environment: “material which may heat to 100-200C is a huge disruption and will undoubtedly change the pathways of groundwater flow. This is like having an electric kettle containing stable stationary water and then turning on the electricity to add heat – the water soon circulates and if heating continues, the water boils.” Professor Stuart Haszeldine.
Question 171
What should our policies on radioactive waste management include, taking into account the planned decommissioning of Sellafield and other nuclear sites in the UK, as well as proposals for Near Surface Disposal sites and a Geological Disposal Facility?
Answer: This question rolls many diverse nuclear issues together. Not only the risk of novel routes into the environment of low level nuclear wastes, but also the Near Surface Disposal of intermediate level wastes, which is likely to co-locate mining groundworks with the proposed GDF. This might save costs in the short term, but the long term may suffer as a result.
The largest proposed development in the UK ever, a geological disposal facility for high level nuclear wastes is relegated to the second to last question, and given minimal and highly misleading context. The Near Surface Disposal plan is described (16.10) as being for “sites to dispose of less hazardous radioactive waste within a shorter timescale”.
The “less hazardous” components of Intermediate Level Wastes are nuclear reactor components, e.g. graphite from reactor cores, and sludges from the treatment of radioactive liquid effluents - all of which need to be shielded from the biosphere for at least many hundreds of years.
Some High Level Wastes need to be shielded for up to millions of years. The wastes proposed for Near Surface Disposal, tens of metres below ground, are the same as those rejected by the NIREX Inquiry in 1997 as being likely to percolate to the surface sooner than expected from deep burial and irreversibly harm people and the environment. Near surface disposal would considerably decrease the timescales on this.
“On the Level” March 2021 Newsletter for the Low Level (Nuclear) Waste Repository at Drigg says: “The NDA is exploring the benefits of developing Near Surface (NSD) – for disposing of a proportion of Intermediate Level Waste (ILW), but no decision has been taken on whether UK Government will pursue this option or whether LLWR, will in time, host a NSD facility.”
The Government is now not only pursuing the option of NSD but also of co-location of NSD groundworks (mining entrances) for the transport of high level nuclear wastes to the proposed sub sea geological disposal facility.
The NIREX proposal for Intermediate Level Wastes was rejected in the 1990s because the nuclear industry had no idea how much and how fast the planned dump would leak. They still do not know.
For a shallow dump, the leaks would be even faster. In a letter to “The Guardian” of June 28, 2007 the NIREX Inquiry Inspector stated:
‘The relevant geology in west Cumbria is apparently now claimed to be “stable, although imperfect” … [T]he imperfection consists of simply failing to meet the internationally agreed criteria on the suitability of rocks for nuclear waste deposit. The site should be in a region of low groundwater flow, and the geology should be readily characterisable and predictable, whereas the rocks there are actually of a complex volcanic nature, with significant faulting. Also, the industry was relying on an overlying layer of sedimentary strata to dilute and disperse any groundwater leakage, when the international criteria require such a layer to act instead as a barrier … The site is not suitable and investigations should be moved elsewhere…’.
And: ‘The site selection process was flawed, not treating safety as the most important factor, and irrationally affected by a strong desire to locate close to Sellafield’.
‘Disposal’ is being promoted by industry as the most expedient way to deal with nuclear waste, rather than the safer and more ethical intergenerational monitoring and repackaging (Rolling Stewardship).
It is highly likely that the nuclear industry will seek to reduce costs further by co-locating a Near SurfaceDisposal facility for Intermediate Level Wastes (ILW) inside or alongside a GDF for High Level Wastes (HLW).
Although the GDF proposal is now a Nationally Significant Infrastructure Project (NSIP), Cumberland Council also notes that Government will take into account the Local Plan. It is therefore beholden upon Cumberland that the Local Plan regarding the GDF should be guided by a full debate and full vote of the Council on the biggest development ever to be proposed not only in Cumberland or Cumbria but in the whole of the UK.