Grusha Leeman: Submission to Senate – Australia is much too hot for safe nuclear power – let’s not dither with the nuclear distraction

Grusha Leeman. Environment and Other Legislation Amendment (Removing Nuclear Energy Prohibitions) Bill 2022 Submission 136
Retain the ban on nuclear energy.
It is heartwarming to know there is serious consideration being given to replacing the climate destroying fossil fuel power methods, but going back to old failed methods is not the best answer for this sunny windy country.
Australia is much too hot for safe nuclear power
We are in a time of climate crisis. Extreme weather events are inevitable and increasing. We know there will be more heatwaves and droughts and some will be more intense. As nuclear power plants consume a lot of water for cooling, the Australian climate is simply not conducive for safe nuclear power. Nuclear power plants are vulnerable to water stress, the warming of rivers, and rising temperatures, which weaken the cooling of power plants and equipment. Nuclear reactors in an increasing number of countries 1 are being shut down during heatwaves, or see their activity drastically slowed. Overheating can present a major safety risk. We can’t be spraying water on the walls of our nuclear power plants to cool the insides during a heatwave when we are also deep into a drought. As the lakes and rivers that typically supply cooling water become hotter thanks to climate change — and as droughts dry up some water bodies — nuclear power plants aren’t viable. We cannot thermally pollute our seas either. Hotter seas kill the plankton, the seagrasses and the mangroves. Sea Level rise and higher intensity storms mean situating vulnerable nuclear power plants on the coast is becoming less attractive.
We need power that is stable to function during heatwaves. Coal, gas and nuclear are notorious for failing that requirement.
Nuclear is much too expensive.
To protect the climate, we must abate the most carbon at the least cost and in the least time. We must quickly
replace our climate destroying fossil fuel plants with clean electricity. To produce stable affordable electricity we must recognise that the economic factors relating to nuclear rule it out as an option.
Not only is nuclear power greatly more expensive compared with other forms of power, it is essentially
uninsurable. Nuclear power plants depend on large government subsidies to be built, and never has nuclear
energy been profitable. On top of the initial capital costs, the cost of maintaining and decommissioning the plant, there’s the endless safe storage of the radioactive waste. Safe disposal facilities don’t come cheap and nowhere in the country are they wanted.
It is feasible that if we finally got a carbon price, nuclear powered electricity could be better able to compete, butmthe insurance risks would need to be borne by the public as none of Australia’s major insurance agencies are willing to provide cover for nuclear disasters. Indeed, if nuclear power operators were to adequately insure against the risk of nuclear accidents, the insurance premiums would make nuclear power completely uneconomic.
As the CSIRO’s GenCost 2021-22 report points out, solar and wind are the lowest cost way of producing electricity in Australia even when factoring in storage. In addition, whilst renewables are getting cheaper all the time, the costs of building and operating nuclear power plants are increasing.
We would still need to import the fuel rods.
There are currently only a few countries that are allowed to process the yellowcake into nuclear fuel rods and
Australia is likely to continue to be excluded. This would mean we would need to export our raw uranium and then import it once processed into fuel rods at an exorbitant price hike. Just because we have a resource doesn’t mean it will be economic to utilise it.
Nuclear energy is too slow
Stabilising the climate is an urgent emergency. Given the urgency of climate change, we need effective solutions now. It takes only a few years to set up a major wind or solar project, whilst nuclear power is slow. Setting up new plants takes about a decade, but some time blowouts have been extraordinary.
Also we are still waiting for long ago promised new technologies. We can’t afford to wait any longer.
Hypothetical new nuclear power technologies have been promised to be the next big thing for the last forty years, but in spite of massive public subsidies, that prospect has never panned out. That is also true for Small Modular Reactors (SMRs).
Uranium is finite and will run out……………………..
The nuclear fuel cycle produces greenhouse gases
While minimal greenhouse gases are created in the operation of a nuclear reactor, the mining, processing and
transport of uranium and the generation of nuclear waste all produce large amounts of carbon dioxide.
Nuclear power is unhealthy
Uranium mining causes lung cancer in large numbers of miners because uranium mines contain natural radon gas, some of whose decay products are carcinogenic. Uranium miners die of lung cancer at six times the expected rate. Clean, renewable energy does not have this risk because (a) it does not require the continuous mining of any material, only one-time mining to produce the energy generators; and (b) the mining does not carry the same lung cancer risk that uranium mining does.
The nuclear industry already has an immense radioactive waste legacy.
The storage and disposal of nuclear waste pose a serious risk. Waste from nuclear power plants is highly
radioactive and very difficult to dispose of safely. It can take up to 100,000 years for it to become safer. There is currently no agreed international solution for the long-term storage of high-level nuclear waste. Already there are hundreds of radioactive waste sites in other countries that must be maintained and funded for at least 200,000 years.. The more nuclear waste that accumulates, the greater the risk of radioactive leaks, which can damage water supply, crops, animals, and humans.
Nowhere in Australia is a nuclear waste dump wanted and it is unconscionable to inflict such a burden on unborn future generations along with our climate legacy.
Nuclear brings a scary weapons proliferation risk………………….
Meltdown risk is unacceptable.……………………………….
Conclusion: leave the uranium in the ground.
Australia has abundant safe and cheap renewable resources like solar and wind. As we face an increasingly urgent need to take action on climate change, we must focus on solutions that are scalable, cost-effective, and safe.
According to the Climate Council, Australia is one of the sunniest and windiest countries on earth, with enough renewable energy to power resources to power our country 500 times over. Compared to nuclear power plants, we can build large-scale wind and solar farms in Australia cheap and fast.
Frankly, pursuing nuclear power is just a waste of time and resources in Australia’s race against climate change. We need to focus on renewable energy if we’re going to make a dent in our emissions.
Let’s not get distracted by the nuclear debate. There is a very real risk that the delay and distraction posed by
dithering with old failed technologies like nuclear will mean a failure to advance a just energy transition. https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communications/Nuclearprohibitions/Submissions
‘Stupidly dangerous’: AUKUS won’t cause a Chernobyl but experts are still worried
The Greens dubbed them ‘floating Chernobyls’. Hyperbole, perhaps, but experts say there are real reasons to fear the nuclear submarines.
It’s the $368 billion friendship bracelet that the Greens suggested would lead to “floating Chernobyls” off the coast of our major cities, and marks the first transfer in history between a nuclear-weapon state of nuclear-powered submarines to a non-nuclear state.
So just how dangerous are the three AUKUS-born nuclear submarines we’re getting from the US, and the eight we plan to build by 2055? And is there enough nuclear material onboard or around for us to be afraid of a meltdown or malfunction?
Following the announcement of the deal in September 2021, Greens Leader Adam Bandt told the ABC it was a “dangerous decision that will make Australia less safe by putting floating Chernobyls in the heart of our major cities”………………..(Subscribers only)
Greens support Barngarla people’s opposition to Kimba radioactive waste dump set to open after 2030

ABC North and West SA / By Nicholas Ward https://www.abc.net.au/news/2023-04-21/greens-affirm-nuclear-dump-opposition-at-kimba-visit/102252440
Greens senators travelled to Kimba on South Australia’s Eyre Peninsula this week to hear from farmers and First Nations groups opposed to the national radioactive waste management facility proposed at Napandee.
Key points:
- Calls are growing for the federal government to drop court action against a First Nations group opposing a nuclear dump
- The local Native Title chair says the government is “not being truthful” about listening to Aboriginal voices
- Greens senators say intermediate-level waste must stay at Lucas Heights until a permanent storage solution is found
SA senator Barbara Pocock said the federal government’s process to determine the site for permanent low-level and temporary intermediate-level waste storage was flawed.
“It didn’t listen to First Nations people, it hasn’t listened to local farmers in the community, and it’s not an appropriate site for intermediate-level waste coming out of Lucas Heights [in Sydney],” Senator Pocock said.
“It results in the double-handling of highly toxic intermediate-level waste, which will be temporarily stored at Kimba, and future generations are going to have to find a long-term solution.
“Bearing in mind the history of nuclear testing in our state, it’s especially important that we … can find a safe long-term solution, not a temporary solution.”
Calls to listen to Aboriginal voices
Jason Bilney is chair of Barngarla Determination Aboriginal Corporation (BDAC), which is fighting the federal government in court to block the current proposal.
He said the government’s continued legal action showed a lack of commitment to listening to Aboriginal voices.
“They’re breaking First Nations hearts by continuing down this path of the Liberals and outspending us 4: 1 in court to put a nuclear waste dump on our country,” Mr Bilney said.
“What does that say about the Statement from the Heart, let alone constitutional recognition?
“It’s about truth-telling and yet they’re not being truthful about listening to our voice.”
Mr Bilney welcomed the senators’ visit to Kimba and said proponents of the waste dump needed to speak honestly about its impact on Barngarla culture.
“It’s always good to come out on country and actually see for themselves where the site is and meet us on country. It’s a very positive step,” he said.
‘Don’t need a court to tell us’
BDAC holds native title over large areas of the Upper Spencer Gulf and Eyre Peninsula, including around Kimba, but not at the specific location of the proposed radioactive storage site at Napandee.
The Greens’ spokesperson for First Nations, Science and Resources, Senator Dorinda Cox, said that did not delegitimise Aboriginal concerns about its placement.
“The Barngarla people have stories, know the songlines, know the importance of birthing places, know the importance of country and practice of their culture in a very strong and traditional way still,” Senator Cox said.
“I don’t think we need a court to tell us that, and unfortunately that is a process they are pushed into.
“There was no free, prior, informed consent.”
Waste at Kimba ‘not expected before 2030’
The Australian Radioactive Waste Agency (ARWA) is overseeing site preparation works at Napandee, while awaiting final approvals to begin construction of the waste facility.
“Construction of the facility can only commence after all necessary siting, construction, nuclear, and environmental regulatory approvals are received,” an ARWA spokesperson said.
“The facility is not expected to be operational before 2030.”
Nuclear power too costly for Australia’s net zero future

Nuclear power plant costs need sharp fall to help Australia reach net zero target, a study finds. By NICK EVANS, RESOURCE WRITER 19 Apr 23 more https://www.theaustralian.com.au/business/renewable-energy-economy/nuclear-power-plant-costs-need-sharp-fall-to-help-australia-reach-net-zero-target-a-study-finds/news-story/d62e6d66e4fa17fba73fd794bf4c37ea 19 Apr 23
The price of building nuclear power plants would need to fall dramatically for it to find a place in Australia’s decarbonisation strategy, and carbon capture will need to play a major role in the nation’s net-zero economy alongside a staggering increase in the rate of renewable energy generation.
Those are among the findings of final modelling in a major expert study of Australia’s path to net zero carbon emissions, conducted by interdisciplinary teams from the University of Melbourne, The University of Queensland, Princeton University’s Andlinger Centre for Energy and Environment, and Nous Group.
The expert group, Net Zero Australia, will release its final modelling on Wednesday, saying the country needs to triple the capacity of the National Electricity Market by the end of the decade to be on track to reach the commitment of being net zero by 2050.
Net Zero Australia released its interim modelling in August last year, after a multi-year effort to model Australia’s possible paths to a near-zero carbon economy, which suggested the country will require wind and solar capacity worth 40 times the capacity of the current NEM to achieve the goal.
Robin Batterham, emeritus professor of engineering at the University of Melbourne – and Australia’s former chief scientist – chaired the steering committee and told The Australian the new figures incorporated the potential use of nuclear power, as well as forecast changes in the cost of installing wind and power generation, to reach its new conclusions.
Among those are the conclusion that nuclear power will have little or no role to play unless costs of building and operating plants fall by at least 30 per cent from current “international best practice”, and the build out of renewable energy generation is significantly constrained – by any one of a range of factors, including policy settings, supply chain issues, or simply the time taken to win environmental and other permits.
“Even if you took the lowest costs that are currently being built in the world now, which is the Korean (reactors) in the Middle East, and then knock 30 per cent off them, nuclear only just gets a look in if you really constrain the renewables build,” he said.
The South Korean-led construction of the Barakah nuclear power plant in Abu Dhabi built four reactors, collectively with a nameplate generation capacity of about 5400MW. Initially tipped to cost $US20bn ($30bn) and be fully operational by 2020, its full cost is now estimated at about $US24bn – and the plant did not have its first unit supplying power until 2021.
Professor Batterham said the updated modelling – intended to be updated on an ongoing basis – also factored in substantial cost inflation in the Pilbara and other parts of northern Australia, downgrading the likely size of solar energy installations, and increasing the proportion of energy expected to be generated by offshore wind farms, particularly in the nation’s southern waters.
“This is quite a message to the states because it says you don’t have to change the numbers much to shift the opportunities around quite a bit,” he said.
But the size of the task in front of the country is still staggering, according to Net Zero Australia’s modelling.
Australian projects will need to attract up $7 trillion-$9 trillion worth of investment to decarbonise the nation’s own electricity market and replace existing export products, and grow renewable energy generation by about 40 times the current NEM generation capacity.
Under the most aggressive renewable energy scenario modelled by Net Zero Australia, the country’s total domestic energy costs would fall from just under 9 per cent of GDP to about 7 per cent by 2050.
And the skilled workforce needed to install and run new generation assets, transmission lines, and associated decarbonisation efforts will need to double to at least 200,000 people by 2030 and reach 700,000-850,000 – most with technical skills – by 2060.
Continue readingOpposition grows to nuclear submarines in Port Kembla
by Owen Marsden-Readford https://redflag.org.au/article/opposition-grows-nuclear-submarines-port-kembla, Wednesday, 19 April 2023

Last year, as part of the AUKUS pact, Liberal Prime Minister Scott Morrison announced plans for a new submarine base on Australia’s east coast. The Labor government that succeeded Morrison’s has said it will stick with this plan.
There is increasing speculation that the site for the base will be Port Kembla, a southern suburb of Wollongong in the Illawarra region of the NSW south coast. While Labor insiders have claimed a final decision won’t be made until after the next federal election, the ABC recently reported that, according to “defence, government and industry figures”, Port Kembla “is now the strongly favoured option” for its deep port and proximity to other military bases and Australia’s lone nuclear reactor at Lucas Heights.

The plan has received support from some local business figures, and the University of Wollongong is deepening its already extensive ties with the military-industrial complex in anticipation. Among the wider community, however, opposition is growing.
Several unions have already come out against the proposed base. The New South Wales Teachers Federation passed a motion at its March council meeting:
“Continuing reports that Port Kembla is being considered as the site for a nuclear submarine base is of deep concern for our public education communities. While governments appear ever ready to commit huge amounts of public revenue on military expenditure there remains a serious underfunding of public pre-schools, public schools, TAFE and higher education, and other areas of the public sector.”
The Kiama council also passed a motion opposing a submarine base at Port Kembla. Even the Dapto and Port Kembla branches of the Labor Party have passed oppositional motions. Socialist students in the Wollongong Undergraduate Students’ Association have passed motions opposing the nuclear submarines, the AUKUS pact and the Australian government’s war drive.
Importantly, the South Coast Labour Council has called for this year’s May Day rally to be held in Port Kembla on Saturday, 6 May, to oppose the planned base. Council secretary Arthur Rorris told the Sydney Morning Herald, “If they want to turn our harbour into a nuclear parking lot, we will fight them tooth and nail”. There will even be a solidarity action held in San Francisco outside the Australian consulate.
Wollongong Against War and Nukes (WAWAN)—a campaign group formed last year—has held a series of protests against AUKUS. The most recent, on 4 April, drew more than 80 people in opposition to the Illawarra Defence Industry Conference—a gathering of war hawks and military profiteers.
Socialist and WAWAN activist Luke Hocking said in a speech at the protest, “If we are all committed to building this movement … then we can make something that can physically get in the way of their plans. And the more of us there are, the better we will be able to do that”. WAWAN will be holding a community forum in Port Kembla on Saturday, 29 April, and is planning further protests.
The Illawarra has a proud history of working-class anti-imperialism. We should look to these traditions as we set out to build resistance to the planned submarine base, the AUKUS pact and the militarism of the Australian ruling class and its US and British allies.
Penny Wong’s World View: AUKUS All The Way

Australian Independent Media, April 19, 2023, Dr Binoy Kampmark
If anyone was expecting a new tilt, a shine of novelty, a flash of independence from Australian Foreign Minister Penny Wong’s address to the National Press Club on April 17, they were bound to be disappointed. The anti-China hawks, talons polished, got their fill. The US State Department would not be disturbed. The Pentagon could rest easy. The toadyish musings of the Canberra establishment would continue to circulate in reliable staleness.
In reading (and hearing) Wong’s speech, one must always assume the opposite, or something close to it. Whatever is said about strategic balance, don’t believe a word of it; such views are always uttered in the shadow of US power. From that vantage point, Occam’s Razor becomes a delicious blessing: nothing said by any Australian official in foreign policy should ever be taken as independently relevant. Best gaze across the Pacific for confirmation.
………….. Like a lecture losing steam early, she finally gets to the point of her address: “how we avert war and maintain peace – and more than that, how we shape a region that reflects our national interests and our shared regional interests.” It does not take long to realise what this entails: talk about “rules, standards and norms – where a larger country does not determine the fate of the smaller country, where each country can pursue its own aspirations, its own prosperity.”
That the United States has determined the fate of Australia since the Second World War, manipulating, interfering and guiding its politics and its policies, makes this statement risible, but no less significant. We are on bullying terrain, and Wong is trying to pick the most preferable bully.
She can’t quite put it in those terms, so speaks about “the regional balance of power” instead, with Australia performing the role of handmaiden. ……..
It takes one, obviously, to know another, and Senator Wong, along with Prime Minister Anthony Albanese, have shown little resistance to the very binary concept they supposedly repudiate. Far from opposing it, we might even go so far as to see their seduction by US power as a move towards the unitary: there is only one choice for the Canberra cocktail set.
……… Wong is keen to point the finger to one great power’s behaviour: unstainable lending, political interference, disinformation, reshaping international rules and standards.
Finally, the dastardly feline is out of the bag – and it is not the United States. “China continues to modernise its military at a pace and scale not seen in the world for nearly a century with little transparency or assurance about its strategic intent.”
….
Assange imprisonment has gone on for too long: Foreign Minister Penny Wong
Bendigo Advertiser, By Andrew Brown, April 17 2023
Foreign Minister Penny Wong has called for the extradition case against Julian Assange to come to an end.
Senator Wong said the legal case and imprisonment of the WikiLeaks co-founder has been going on for too long.
Mr Assange has been imprisoned in the UK for more than four years and faces extradition to the US on espionage charges.
Appeals to stop his extradition are currently before the UK courts.
Speaking at the National Press Club, Senator Wong said the government would continue to press for Mr Assange’s release…………………………………
Last week, almost 50 Australian MPs and senators signed a letter to US Attorney-General Merrick Garland urging him to end the pursuit of the WikiLeaks co-founder.
Advocates have urged for Prime Minister Anthony Albanese to raise the issue of Mr Assange during upcoming meetings with US President Joe Biden and UK Prime Minister Rishi Sunak. https://www.bendigoadvertiser.com.au/story/8161607/assange-imprisonment-has-gone-on-for-too-long-wong/?src=rss
The dangerous one is the U.S. -not China

As for Taiwan, let’s remember that the international community recognises Taiwan as part of China and Taiwan has no seat by itself in the United Nations.
By Colin Mackerras, Apr 16, 2023 https://johnmenadue.com/the-dangerous-one-is-the-u-s/
The implication of AUKUS is that China constitutes a danger to Australian security. It borders on official Australian policy that China is an aggressive power bent on domination. But the history of the People’s Republic suggests its military is for defence, not aggression and that the cases where it has used external military force are very few. Under Xi Jinping it may be assertive and keen to extend influence, especially economic, but it shows no signs of political/military aggression. On the contrary, it is the U.S. that constantly uses external military force and is bent on maintaining domination at all costs.
It was less than a year after the birth of the People’s Republic of China (PRC) on 1 October 1949 that the Korean War broke out. Korean history of the first years after World War II is too complex to pursue here. But essentially no sooner was Korea independent of a defeated Japan in 1945 than a divided country emerged, with the U.S. setting up the Republic of Korea (South Korea) on 15 August 1948 and the Democratic People’s Republic (North Korea) following on 9 September. Under U.S. dominance, it was the south that moved first formally to divide the country.
When the north attacked the south in June 1950, the U.S. got the United Nations to intervene under its own American leadership. China became involved only in October 1950, after the U.S. actively threatened to move north to invade the fledgling PRC. Yet, at U.S. behest, China was condemned for aggression.
Let’s be very clear: the U.S. was the first foreign power to be involved in this war, not China. After a truce reached in 1953, Chinese troops withdrew fully from the north by 1958, while American troops remain in the south to this day. The dangerous one is the U.S., which assumes its God-given right to control the world, not China. There is no peace treaty covering Korea to this day.
Following the Korean War, China has only rarely been involved in wars outside its own borders. In 1962, it fought a brief border war with India, but it is important to note that the rights and wrongs of this are extremely controversial. Although the Western media reported almost entirely India’s version of events, scholars such as the late Neville Maxwell (1926-2019) and Gregory Clark have shown convincingly that China had a perfectly respectable case.
The most recent time China sent troops to attack another country was in Vietnam in February and March 1979 in response to Vietnam’s invasion of Cambodia. During this very brief war, China made no attempt to take the capital or to change the Vietnamese government. It withdrew unilaterally.
In short, the longest war since 1949 to see Chinese troops fight outside their borders is still the Korean war. It was unfairly condemned of aggression by the first foreign power to participate in the war, with the U.S. version of events sticking for decades because of its world power.
Since the Korean War, the U.S. continues to be involved in numerous wars, Vietnam, Iraq, Afghanistan, among others, with Australia simply taking part to follow the boss. What’s striking is that the U.S. has lost these wars and ended up withdrawing humiliated. The U.S. has attempted to invent an ideological justification but frequently been attacked by protests from within its own borders. It has also been involved in proxy wars, some such as the present Ukraine war large in scale.
In contrast to China, the U.S. has hundreds of military bases outside its own borders and has installed numerous governments in foreign countries replacing those that don’t conform to its ideology it calls “democracy”.
Many in the West assume that under Xi Jinping China has become an aggressive nation, even if it was not before. It is true China is much more assertive in world affairs. But I see no sign that China has become aggressive. It shows no sign of wanting to use its armed forces outside its own territory.
As for Taiwan, let’s remember that the international community recognises Taiwan as part of China and Taiwan has no seat by itself in the United Nations. The U.S. may be goading China to retake Taiwan with violence, but has not succeeded up to now. China’s policy is now, and has always been, that it wants to reunify the country by retaking Taiwan, but it wants peaceful reunification, using force only as a last resort.
China extends its influence through trade and investment. We know that its Belt and Road Initiative has expanded China’s economic and to some extent political influence throughout Central Asia, Africa and Latin America, and even the South Pacific. We even hear increasing reports of China’s replacing the U.S. dollar as the reserve currency by trading in the Chinese yuan and other currencies.
Western countries, especially the U.S., express alarm at the increase of Chinese influence and have taken increasingly severe measures to thwart it. However, what the Chinese have not done is establish military bases, overthrow local regimes or even try to spread their ideology to those countries with which they trade. In this sense they are far less dangerous than the U.S.
Xi Jinping talks of a common shared future of humanity, not of dominance. Western commentators tend to assume that’s just words, and really he hides deception and conquest in his heart. I don’t see the evidence for that.
What China wants, and what seems to me in China’s interests, are two things. One is to protect China against external attack. The other is a multipolar world, in which China is one of the important poles. It does not want or aim for a Chinese-dominated unipolar world. True, it is becoming involved in the Middle East and in peace processes to an unprecedented extent, at the same time as the U.S. is in decline relative to China (and other countries). Personally, I can’t see why it should not. As a great civilisation, it has a right to extensive influence. Influence is quite different from dominance.
The U.S. currently assumes it is number 1. Its main aim is to retain that position. Its policies are geared to that end, to keep China down. What alarms the U.S. is China’s success. How can a country so recently impoverished and backward actually be prosperous enough to enjoy a life expectancy at birth longer than the U.S.? (World Bank data for 2020 have China at 78, and the U.S. at 77).
The way Australia has submitted itself to this dangerous and untrustworthy country, the U.S., is shameful. Our track-record of blindly following allies into wars that don’t concern us is unworthy of the independent country we should be and aspire to be.
Australia’s 9 news papers gave Navy chief a platform for a resounding attack the doubters on AUKUS nuclear submarine
‘Hand-wringers’ under attack as Navy chief and Nine round on AUKUS doubters
Australia’s chief of Navy believes AUKUS is one of the country’s greatest nation-building projects. And Nine papers were happy to give him a rooftop to shout from.
Crikey, DAVID HARDAKER, APR 17, 2023
The Nine mastheads have continued their full-throated backing of all things AUKUS, allotting prime weekend front-page space to Australia’s chief of Navy Mark Hammond, who — blow me down — laid out why the nation must get behind the Navy’s submarine project.
In a tour de force of military reasoning, the 37-year Australian Defence Force veteran also picked up some of the talking points advanced by the political class to defend the $368 billion decision sprung on the nation just a few weeks ago.
Hammond lamented that AUKUS was not being hailed as one of the great nation-building projects, such as the Snowy Mountains Hydro-Electric scheme. ……………. (registered readers only)
Western Australian company to build low-level radioactive waste facility – Kimba dump a decade away – now irrelevant?

GREEN LIGHT FOR FIRST NUCLEAR WASTE STORAGE
Tellus, March 16, 2023
Australia’s first purpose-built low-level radioactive waste facility has been granted final approval in Western Australia ……
The Australian has confirmed that the WA government has granted a final approval licence to Australian firm Tellus Holdings to store low-level radioactive waste at a repository in Sandy Ridge, 240km northwest of Kalgoorlie, which could take hundreds of thousands of tonnes of stored waste from around the country.
………….The Sandy Ridge repository will be the country’s first commercial facility to be licensed in Australia to take low-level radiological waste and store it in a stable geological repository, and is one of only a handful of its types in the world.
It is also licensed to take low level radioactive waste from the Lucas Heights reactor in Sydney, as well as from defence facilities.
The commonwealth’s own proposed radioactive waste facility, Kimba in South Australia, is estimated to be at least a decade away from being constructed.
The licence approval, following agreement with traditional owners, will see it remediate contaminated oil and gas infrastructure, end-of-life mines and also deal with Australia’s massive stockpile of low-level radioactive waste from nuclear medicine, including diagnostic, treatment, research and other industries.
The near-surface geological repository will also be licensed to take low-level radioactive waste generated in the processing of critical minerals, which is estimated to eventually generate millions of tonnes of waste every year, as well as radioactive waste from the dismantling of offshore oil and gas rigs, which is estimated to cost more than $40bn.
The site is located in one of the most geologically stable zones in the world with the company claiming it was one of the “safest places” in Australia to store hazardous and low-level radioactive waste.
It is not licensed to take the high-level nuclear waste that would be produced by the need to one day dispose of nuclear reactors from submarines. However, the company said it could contribute its geological expertise and knowledge as the commonwealth begins a search for a geologically safe location for this purpose.
According to the Australian Radioactive Waste Agency, the country’s stockpile of radioactive waste is spread across more than 100 locations around Australia, including science facilities, universities and hospital basements – and is increasing.
Tellus chief executive Nate Smith told The Australian the site would provide a critical link in developing Australia’s first multibillion-dollar hazardous waste industry………………..
Sandy Ridge was granted approval in 2021 to take class V hazardous waste.
However, the McGowan government only granted final approval in January this year for the facility to take low-level radioactive waste as well, following a review by WA’s Radiological Council which advises the minister for health. – https://tellusholdings.com/green-light-for-first-nuclear-waste-storage/?fbclid=IwAR3P1lFgTT4rlThFKGWfB9yd-U8bFu6wrsrRTkBUNk4E7oNfzVW9J3p33Iw
The Australian
By Simon Benson
16 March 2023
Rex Patrick on AUKUS submarines: “an astonishingly bad deal”

by Rex Patrick | Apr 14, 2023 https://michaelwest.com.au/rue-britannia-britannia-and-rue-aukus-subs/
The Defence Department has outdone itself with the AUKUS submarine project. In Paul Keating’s words, “it’s the worst deal in all history”. That’s not just because of the staggering $386 billion price tag, but because of the form the program is to take. Former submariner Rex Patrick looks at the most astonishingly irrational part of the announcement.
Our senior Defence bureaucrats, both uniformed and civilian, have a remarkable but unexplainable knack when it comes to acquiring new equipment. When simplicity confronts them, they always find some way to make it complex. In the face of something manageable, they’ll always find a way to make it unmanageable. SNAFU is the order of the day.
But, for Defence, it’s all OK – the admirals, air marshals, generals and top level public servants are immune from the consequences of failed procurement – no matter how big the disaster. No-one’s ever been fired from Defence for stuffing up an equipment purchase; after all, the wasted money is not theirs, it’s mine and yours.
Looking at the AUKUS plan, which some are now labelling USUKA [pronounced “you sucker”] after Paul Keating called it “the worst deal in all history,” Australia will initially acquire three second-hand but proven and highly capable Virginia Class submarines, but then jump off that safe pathway to a high-risk program involving a country that has a track record of being late, and over budget, on its past and current submarine programs.
It’s just reckless.
Virginia submarines, what we could do
The Virginia Class nuclear attack submarine is sea proven but also an evolving design. It’s even fitted with the combat system and weapons that we already have on our Collins Class submarines, or will acquire.
AUKUS is a bad deal. It comes at eye-watering cost, has huge opportunity costs and effectively puts all our Defence eggs in one basket.
It’s not going to deliver a capability within an even remotely sensible time frame either to help deter, let alone fight in, the very conflict Defence purports we need it for.
But if I put that aside and just went along with the whole thing, I’d advise that we could, and should, buy three US built Virginia Class submarines and then build our own, effectively providing the third Virginia shipyard (there are two shipyards in the US, both struggling with capacity).
That’s of benefit to us, and to the US, who would enjoy a surge build capability through us.”
But instead, we will pay to increase US industrial capability and then turn to the British.
Not a shadow of its old self
“Rule Britannia, Britannia rules the waves. Britons never, never, never shall be slaves.” It’s a song derived from a 1730s poem.
But like the billowing gowns and petticoats that were worn over dome-shaped panniers by women of the 1730s, “Rule Britannia” is no longer in fashion.
The Royal Navy is not even a shadow of its old self. The French Navy and Spanish Armada outnumber Royal Navy frigates and destroyers 32 to 18. Admiral Horatio Nelson would be turning in his grave.
And to make matters worse, the “great” left “Great Britain” soon after Brexit.
(Not so) Astute submarines
Back to the topic at hand, Britain’s recent submarine projects have been project management cluster fiascos.
The Royal Navy’s current Astute class nuclear-powered attack submarine program was approved by the British Government in 1997. Three boats were to be built for £2.6 billion, with the first boat to be in service in 2005. The first boat went in the water five years late, in 2010, and the first three boats blew out in cost by £1.9 billion. And by the way, the UK contracted the US submarine company, General Dynamics Electric Boat, to help them sort out some ‘issues’ within the Astute project in 2004.
Starting with approval for a fourth boat in 2007, the program has grown to seven boats all up. The last four “Batch II” boats were supposed to cost £5.7B but are now expected to total £6.7 billion. The latest boat, HMS Anson, was delivered 25 months late.
Dreadnought submarines
The parallel Dreadnought nuclear ballistic missile submarine is on track. On track to be late and over budget.
The Ministry of Defence established its Future Submarine Integrated Project Team in October 2007. The initial approval of the program was in May 2011, with an estimated cost for four submarines of between £11 and £14 billion. The first submarine was intended to be in service in 2028.
The most recent cost estimate for the four ballistic missile platforms is £31 billion. Bizarrely, as the program has advanced, less seems to be known about the in-service date. No-one is saying when the first boat will arrive, other than “some time in the 2030s.”
Refits and retirements
The first of the Royal Navy’s current nuclear ballistic missile submarines, HMS Vanguard, has just come out of refit. The refit was programmed for three years and was to cost around £200 million. It took seven long years and around £500 million. Nearly one quarter of Vanguard’s service life will have been spent in dock undergoing repairs and maintenance.
Earlier this year, a public scandal erupted when it was revealed that the lead contractor had concealed broken bolts in the submarine’s reactor compartment.
In terms of programmatic failure, even more disturbing is the state of dismantling retired Royal Navy nuclear submarines.
The first ever British nuclear-powered submarine, HMS Dreadnought, entered service 60 years ago and served for 17 years. For the last 43 years, it’s been sitting alongside a wharf in the UK. It’s not been dismantled. But neither have any of the other 21 retired Royal Navy nuclear-powered submarines.
It’s a national disgrace. The National Audit Office examined the issue in 2019 and estimated that the cost of maintaining these retired submarines alongside various docks had exceeded £500 million, and the total cost of dismantling the retired and in-service submarines would likely exceed £7.5 billion. Perhaps this will be covered by the AUKUS overheads.
Nuclear disaster
The state of Britain’s submarine enterprise is nothing short of a disaster. And yet the Australian Department of Defence thinks that for the next fifty years, maybe longer, we should hitch ourselves to the clapped out wagon that is Britain’s submarine construction industrial base.
Paul Keating had it right about the AUKUS strategic architecture. Instead of moving forward with focus on a relevant local team like the QUAD (Australian, India, Japan and the United States), we’re committing to a subordinate role with our US ally and an Anglosphere arrangement that’s a hangover from the former, now almost forgotten, British empire.
Yet it’s all “keep calm and carry on” in the Australian Department of Defence. They have no need to worry because all the bigwigs will have retired and moved onto highly paid consultancies and ‘think tanks’ before the proverbial hits the fan.
Pretty much the same goes for the few, timid, politicians who’ve signed off on all this, a gargantuan splurge of taxpayers’ dollars, because they’re all fearful they might be accused of being “weak on defence” if they don’t swallow the Department’s nuclear Kool Aid.
I guess I’ll just keep going to bed each night worrying about the Defence of Australia. Not about some country invading us, but by how much of my money, and your money, the Department’s going to waste tomorrow, next week, next year and for decades to come.
Weapons-makers set to gain more influence in defence operations

Global weapons companies could be more deeply integrated into Australian military operations after legislative reforms. This comes on top of public unease about Australia’s independence under AUKUS.
MICHELLE FAHY, APR 14, 2023 https://undueinfluence.substack.com/p/weapons-makers-set-to-gain-more-influence?utm_source=post-email-title&publication_id=297295&post_id=114686170&isFreemail=true&utm_medium=email
Activity in the defence domain has reached peak overload. On top of AUKUS and the submarines, the high-level nuclear waste dump, the Defence Strategic Review, and a slew of multi-billion-dollar arms procurements, the Defence Department is also undertaking consequential reform of the Defence Act 1903 and related legislation. In March, Defence published a consultation paper on the reforms calling for public feedback. The deadline for submissions is Friday 21 April.
Among other things, the reform initiatives foreshadow a more deeply integrated involvement by the globally dominant US arms industry in Australia’s defence and national security establishment, including military operations, especially in the modern ‘warfighting’ domains of cyber and space. This is a profoundly consequential proposition that demands careful consideration.
Notice of the intended reforms was quietly released by the defence portfolio’s junior minister, Matt Thistlethwaite, just days before the Albanese-Biden-Sunak AUKUS extravaganza in San Diego. Saturation media coverage and ongoing analysis of that event has kept the intended reform of Australia’s defence legislation out of the spotlight. This confluence in timing was likely intentional. As a result, much of the limited time granted to the public to consider and prepare submissions has already elapsed.
The public needs to pay attention now because the bipartisan-lockstep nature of defence ‘debate’ in Australia makes it probable that once the legislative amendments hit parliament they will zip through both houses into legislative reality with far less scrutiny than they demand.
The government says legislative reform is necessary to ‘better position the Australian Defence Force (ADF) as an agile, integrated, warfighting enterprise’. The reforms are also intended to create a ‘technology-neutral’ legislative framework.
The consultation paper outlines three key initiatives:
- support the full range of military activities and capabilities required to defend Australia and its national interests
- design the law for seamless interoperability with international allies and partners
- improve the security of Australia’s military capabilities, tangible and intangible.
The terms ‘integrated’, ‘seamless interoperability’, and ‘interchangeability’ appear throughout. The word ‘partner’ is used frequently and is undefined. It is often unclear to which type of entity it refers: foreign governments, foreign militaries, foreign intelligence services, or local or foreign arms industry entities. These distinctions are important, especially in a public consultation document, and the fact that they often aren’t clear creates considerable ambiguity.
Defence poses ten consultation questions for consideration. An important one is hinted at and needs to be made plain: What does the public think about the deeper integration of profit-making multinational weapons companies into Australian military operations across the breadth of operational domains, including cyber and space?
The AUKUS agreement is causing significant public unease about Australia’s ability to act independently of our major allies, and the loss of sovereignty this entails. Two former prime ministers have also expressed publicly their concerns about this. The shape of the proposed legislative reforms, the ambiguities in the consultation paper, and the muted manner of the document’s release add further cause for concern.
Worth adding in this futuristic context is the rapid development and significant funding of lethal autonomous weapons, occurring largely out of public view. (For the uninitiated, lethal autonomous weapons, known colloquially as ‘killer robots’, require no meaningful human involvement in the ‘kill chain’.) As yet, there is no international legal framework regulating their development or use. Such is the future we face.
If the above is not warning enough, we need only reflect on the US government’s outsourcing to defence contractors (and here) of parts of its morally bankrupt drone assassination program which has killed large numbers of civilians, including children, and instilled an abiding fear of clear skies in the populations of multiple countries. Pine Gap, part of the United States’ global surveillance network, has played a facilitative role in these killings.
This surely provides all the evidence we need that more time – and a vastly more transparent and genuine process of engagement – is needed from Defence for the public to consider and respond to its proposed initiatives for reform.
Download Defence’s consultation paper. Lodge your submission by 21 April.
This piece first appeared at John Menadue’s Pearl & Irritations on 14.4.23.
Monica Leggett, in a powerful Submission, calls on all Australian MPs to reject nuclear power

Environment and Other Legislation Amendment (Removing Nuclear Energy Prohibitions) Bill 2022 Submission 134
My first employment, after completing my PhD in surface physics from Southampton
University, was to work as a research officer at Berkeley Nuclear Research Laboratories.
These were located adjacent to the Berkeley Nuclear Power Station. This gave me a lifelong interest in the industry and the controversies associated with it.
I find it hard to believe that the issue of Nuclear Power in Australia has come back to the
Senate. From an energy point of view it is unbelievable that a country with such
abundant sources of renewable energy should even contemplate using nuclear energy.
Nuclear power is the most expensive, inflexible, complex and socially problematic source
of energy. All that massive infrastructure with its associated safety and security
measures built just to boil water.
Re-engineering a nuclear bomb to generate heat in a controlled and safe manner may
have been an extraordinary feat of engineering and optimism in the 1950s, but technology
has moved on. Nuclear Power is an inappropriate, unnecessary and potentially
dangerous choice for Australia for the reasons outlined below.
1 Too slow and too expensive
Nuclear power has never been cheap despite the initial vision of nuclear energy as “too
cheap to meter”. It has very large upfront costs, is plagued by delays and cost over-runs.
While the costs of renewables are decreasing, the cost of nuclear is increasing.
The high profile and controversial nature of nuclear power would divert attention, funds
and focus from renewables to nuclear. The world cannot afford any more delays in
reducing carbon dioxide emissions.
2 Lessons from recent world-wide extreme weather events
The impacts of global warming can no longer be dismissed as a future problem. Records
are now being broken on a regular basis. The last two years have been particularly brutal
with extreme temperatures, intense wild fires, droughts and floods across the world.
Using only historic data to predict future weather is no longer sufficient. This would have
a very major impact on site selection, the safe operation and emergency planning for any
nuclear power plant.
3 Unacknowledged social impacts
The presence of a nuclear power station in an area would alter the risk profile of the area
for those in the vicinity and pose an additional psychological stress on residents. In
addition to bush fire and flood preparedness plans, residents would need to have nuclear
accident preparedness plans. These are not necessarily compatible. Local authorities
would need response plans for minor and major nuclear accidents.
If the power plant site is in a country area, which is likely, then there is an additional
problem. Country areas, in WA for example, rely on a large volunteer component in fire
and ambulance services. Will volunteers wish to serve in an area which includes a
Nuclear Power Station? How will they be protected? How will they be trained?
4a Adverse environmental impacts – normal operation
The environmental case for nuclear power appears to be based on its low carbon dioxide
emissions while operating without incident, compared to the carbon dioxide emissions
from a fossil fuel plant. This is correct but incomplete. It compares one yet-to-be-built
working nuclear power plant with an operating fossil fuel power plant. But their life cycles
are very different. The public relations material ignores some or all of the emissions from
the following:
- Site preparation
- Construction
- Water supply
- Storage of spent fuel rods
- Decommissioning including the treatment of the highly radioactive pressure vessel
and shielding (while the reactor is operating, the fuel vessel and shielding are
constantly under neutron bombardment from the core, hence becoming highly
radioactive). - Long term storage and monitoring of radioactive waste.
4b Adverse environmental impacts – accidents
In the case of a major nuclear accidents (e.g. Chernobyl and Fukushima) all energy
benefits while operating became insignificant compared to the energy used to deal with
the aftermath of the accident. These include the energy costs of making the reactor safe
and monitoring it for an innumerable years, site and area rehabilitation, relocating
residents and broader health costs.
The probability of a weather related nuclear accident has been made greater by the
changes in climate with extreme weather events more likely.
Accidents release radioactive isotopes into the environment. These can expose plants
and animals to external radiation. If ingested, then they can be absorbed into body tissue
and irradiate the body from inside.
Our environment is under enormous threat from human impact and climate change. It
does not need another threat.
5 Security issues
The war in Ukraine has brought into sharp focus, the reality of having a nuclear power
station in a country when under attack . It is not an asset that adds to a country’s
security, so why would we choose to have nuclear power stations that we do not need?
In addition, the presence of enriched uranium in the country broadens the range of
possible terrorism threats. Extra security then becomes an added expense for the
taxpayer.
6 Ethical issues – intergenerational equity and resource sharing
Should a nuclear power station be built and assuming the station is accident free, then
the current population would get the advantage of the power generated. Future
generations would be bequeathed the costs. They would inherit responsibility for decommissioning (if not already done) looking after the waste, maintaining its security
from terrorists and monitoring containment, all the while living with the impacts of climate
change. This lacks intergenerational equity and is not acceptable.
Uranium is a finite resource. As world citizens with an abundant supply of renewables,
we should not be using Uranium for our power. Uranium should be reserved for countries
that have few or no alternatives.
If we with our enormous renewable resources choose to use nuclear, what message
about renewables are we sending to our Pacific neighbours? What message does it send
about our concern for their wellbeing if they could be down-wind from a possible nuclear
accident?
7 Conclusion
Nuclear Power is an inappropriate and unnecessary choice for Australia. It fails on
economic, social, and environmental grounds and is ethically indefensible. I call upon all
politicians to reject nuclear power https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communications/Nuclearprohibitions/Submissio
Professor George W Burns Submission to Senate – Keep the Nuclear Prohibitions, in the immediate and long-term interests of all Australians… and of the planet

Environment and Other Legislation Amendment (Removing Nuclear Energy Prohibitions) Bill 2022 Submission 127
I am deeply concerned about the proposed Removing Nuclear Energy Prohibitions Bill
Australia needs effective climate action but nuclear power would slow the transition to a low-carbon
economy. It would increase electricity costs and unnecessarily introduce the challenges and risks
associated with high-level nuclear waste management and the potential for catastrophic accidents,
with profound intergenerational implications for Australians.
My concerns as an Australian citizen are that:
Nuclear is the most expensive energy option.
Nuclear is slow. It can take decades to build and would require a decade or more to develop the
legislative framework.
Nuclear is dangerous. Either through human error, disaster, or as a military target the catastrophic
consequences of a nuclear disaster would permanently pollute.
Nuclear is unwanted. There is long standing popular opposition to nuclear power in Australia
because of the issues above as well as the unsolved problem of nuclear waste and the link to nuclear
weapons
Alternatives like renewables, storage and energy efficiency are faster, cheaper, more deployable and
enjoy much more public support
I trust the Inquiry will act in the immediate and long-term interests of all Australians…and of the
planet. https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communications/Nuclearprohibitions/Submissio
Friends of the Earth comments accuse the Australian Government Industry Department of blatant racism in its Kimba nuclear waste dump plan.

Comments on: Guidelines for the content of a Draft EIS National Radioactive Waste Management Facility, SA EPBC 2021/9128 April 2023
RIGHTS OF TRADITIONAL OWNERS
Recommendation #1: The Guidelines must require the proponent (the Australian Government Department of Industry, Science and Resources) to explain how the nuclear dump/store proposal complies with the United Nations Declaration on the Rights of Indigenous Peoples, in particular Article 29.2:
“States shall take effective measures to ensure that no storage or disposal of hazardous materials shall take place in the lands or territories of indigenous peoples without their free, prior and informed consent.”
Of course it is common knowledge that the proposal is a gross violation of Article 29.2 and that the nuclear dump/store is unanimously opposed by Barngarla Traditional Owners. Nevertheless, the proponent must be asked to explain its position and its crude racism.
Recommendation #2: The list of documents in section 3.5.1 of the Guidelines should also include the United Nations Declaration on the Rights of Indigenous Peoples.
Recommendation #3: The Guidelines mention a “process for ongoing consultation with FirstNations people”. The proponent should be required to declare whether or not it reservesthe right to ignore the rights, interests and recommendations of the Barngarla Traditional Owners in future just as it has ignored and overridden unanimous Barngarla opposition to the nuclear dump/store proposal.
Recommendation #4: The proponent should be required to discuss the adequacy of the
National Radioactive Waste Management Act (NRWMA) and in particular to provide
justifications for each of the following provisions of the Act:
- The nomination of a site for a radioactive waste facility is valid even if Aboriginal
Traditional Owners were not consulted and did not give consent. The NRWMA states that
consultation should be conducted with Traditional Owners and consent should be secured ‒
but that the nomination of a site for a radioactive waste facility is valid even in the absence
of consultation or consent. - The NRWMA has sections which nullify State or Territory laws that protect the
archaeological or heritage values of land or objects, including those which relate to
Indigenous traditions. - The Act curtails the application of Commonwealth laws including the Aboriginal and Torres
Strait Islander Heritage Protection Act 1984 and the Native Title Act 1993 in the important
site-selection stage. The Native Title Act 1993 is expressly overridden in relation to land
acquisition for a radioactive waste facility.
Recommendation #5. The proponent should be required to explain why it rejects the SA
Government’s policy that Traditional Owners should have a right of veto of nuclear waste
sites. SA Labor’s Deputy Leader (and now Deputy Premier) Susan Close noted in September
2020 that: “South Australian Labor is calling on the Federal Government to halt its plans to
dump nuclear waste at Kimba. … SA Labor has consistently expressed its concerns about the
site selection process and the lack of consultation with native title holders. … This was a
dreadful process from start to finish, resulting in fractures within the local community over
the dump. The SA ALP has committed to traditional owners having a right of veto over any
nuclear waste sites, yet the federal government has shown no respect to the local
Aboriginal people.”
FEASIBLE ALTERNATIVES
Recommendation #6. The Guidelines should require discussion on the ‘feasible alternative’
of targeting states/territories which do not have legislation prohibiting a nuclear
dump/store such as the one proposed. The current proposal requires the Commonwealth to
override the SA Nuclear Waste Storage (Prohibition) Act 2000.
Recommendation #7. The Guidelines state that the no-action alternative should be
discussed “if relevant”. The term “if relevant” should be removed and the proponent should
be required to discuss the no-action alternative since it is in fact a viable alternative.
Recommendation #8. The Guidelines should explicitly require the proponent to consider the
option of abandoning the plan to store intermediate-level waste (ILW) and Kimba since an
overwhelming majority of ILW is currently store at ANSTO’s Lucas Heights site with no
practical or legal obstacles to ongoing storage. The plan to move ILW to Kimba is absurd: it necessarily entails double-handling; and it entails moving waste from a site with strong
security and an abundance of nuclear experts to a site with weaker security and a dearth of
nuclear experts … for no reason whatsoever let alone a good, compelling reason.
It should be noted here that ARPANSA plans separate assessments of the proponent’s plans
for disposal of lower-level wastes and storage of ILW. Further, in its March 2022 Regulatory
Assessment Report approving ANSTO’s new ILW Storage Facility at Lucas Heights to 2037,
the ARPANSA CEO states that a “clear net benefit must be provided by the licence applicant
to support a licence application”. It is implausible that the proposal to move ILW from Lucas
Heights to Kimba would meet this net-benefit criterion. Thus DCCEEW must be alert to the
misinformation and obfuscation that the proponent may present to justify ILW storage at
Kimba instead of Lucas Heights, and DCCEEW must ensure a full evaluation of alternatives to
ILW storage at Kimba.
Recommendation #9. Further to the above recommendation, the proponent should be
required to consider the option of abandoning plans for ILW storage at ANSTO and instead
working on a consolidated plan for deep underground disposal (or deep borehole disposal)
of both ILW as well as high-level nuclear waste from nuclear submarines.
TRANSPORT OF SPENT FUEL REPROCESSING WASTES
Recommendation #10. The proponent should be required to thoroughly consider
transportation of waste products arising from reprocessing of spent research reactor fuel.
There is no logical reason or justification for this omission
