Australian Greens' dissenting report

1.1The Australian Naval Nuclear Power Safety Bill 2023 (the Bill or ANNPS) is deeply flawed legislation that is only being progressed because of the deeply flawed trilateral agreement that is AUKUS.

1.2The Bill proposes a seriously flawed regulatory model for the dangers of naval nuclear reactors and associated waste.

1.3The proposed regulator lacks genuine independence, the process for dealing with nuclear waste is recklessly indifferent to community or First Nations interests and the level of secrecy is a threat to both the environment and the public interest.

1.4Any amendments proposed to improve the many deficiencies of this legislation should not be interpreted as support for the Bill itself or for the AUKUS deal.

1.5This Bill establishes a new defence naval nuclear regulator that will oversee all aspects of the nuclear production and waste cycle associated with Australian nuclear-powered submarines (and with regard to waste but not the operational activities of UK and US submarines) that operate, are constructed or decommissioned in Australia and Australian territorial waters.

1.6This regulator will be entirely separate from the existing and long-standing nuclear regulation framework in Australia, which currently sits under the Australian Radiation Protection and Nuclear Safety Act 1998 (ARPANS Act).

Independence

1.7This Bill fails to meet the fundamental international principles of regulatory independence for safely addressing the inherent risks of nuclear power and nuclear waste.

1.8In this Bill, the proposed Australian Naval Nuclear Power Safety Regulator reports directly to the Minister of Defence. The Defence Minister is also responsible, through the Australian Defence Force, for the operation of those same nuclear submarines.

1.9This is widely out of step with international standards of legal and functional independence for nuclear safety and is contrary to current practice on civil nuclear regulation in Australia.

1.10This is also in direct opposition to the International Atomic Energy Agency in its Fundamental Safety Principles that state:

An effective legal and governmental framework for safety, including an independent regulatory body, must be established and sustained.[1]

1.11It is also not in line with the current regulation of nuclear waste in Australia. The regulator, called the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) sits in the Ministry of Health whereas the Australian Nuclear Science and Technology Organisation (ANSTO) (which operates the Lucas Heights reactor) sits in the Ministry of Industry and Science. This is to ensure the regulator is independent of the industry it oversees.

1.12As the majority report notes in some detail, the proposed model under this Bill is distinct from either the UK or US naval nuclear regulators.

1.13In the UK, while the main naval nuclear regulator does report through the Ministry of Defence, there is a significant ongoing role for the independent civilian Office for Nuclear Regulation (ONR) in overseeing defence nuclear activities. This is formalised in the General Agreement between the Ministry of Defence and the Office for Nuclear Regulation. This agreement clearly delineates the relationship between the Ministry of Defence and the ONR in discharging their respective roles and responsibilities for the UK’s defence nuclear operations. There is no equivalent role for ARPANSA in this Bill.

1.14In the US, the regulator is known as the Naval Nuclear Propulsion Program (NNPP). This is not run solely by Defense but rather is jointly managed and self-regulated by the civilian National Nuclear Security Administration (NNSA) that reports to the Department of Energy, and the Department of the Navy. By contrast, under this Bill the regulator will be entirely within the Department of Defence and the Defence Minister will have sole ministerial responsibility.

1.15The importance of regulatory independence was outlined in a letter to the CEO of ARPANSA from the Radiation Health and Safety Advisory Council in October 2022 that stated:

Independence of the regulator is a critical part of its effectiveness. The regulator should be independent of the operators and departments overseeing any aspect of purchase, manufacture, maintenance, and operation of the program. It is noted that some of the more significant global nuclear and radiation incidents have arisen from inadequate separation of responsibilities from regulatory capture. More than functional separation, it is important that the independent regulator can operate without influence, and with a strong voice. If a regulatory body cannot provide information on safety and incidents at licensed facilities without the approval of another organisation, issues of independence and transparency will arise. Reporting arrangements should therefore enable the regulatory body to be able to provide safety related information to the Government and the public with the maximum amount of transparency.[2]

1.16During a committee hearing, these concerns were put to the Royal Institution of Naval Architects (RINA), concerning the importance of independence in ‘social licence’:

Senator SHOEBRIDGE: We have good examples, though, of independence. ANSTO is an operator. The regulator of ANSTO reports to a different minister, and that is part of how ANSTO gets social licence. That's a good example, isn't it, of structural independence?

…

Dr Williams: I agree with the senator with regard to keeping them independent. Reporting to the same body is going to be a conflict in some way, shape or form. If there are any issues, a decision would need to be made at that level. That begs the question: which side of the fence would that fall down on? There does need to be that independence. Certainly from the Defence side we have the regulators reporting in to the secretary of state for defence and we have the nuclear sites reporting in to the Minister for Defence. There are two separate routes for the regulatory side from that perspective. So, while you can see that's the overarching government level and that is the top of the tree, so to speak, with the regulatory side and how you manage that independence, I think the senator is correct that it does need to report in some way to different bodies.[3]

1.17ARPANSA also acknowledged that the key to their social licences was independence through reporting to a minister not associated with the industry they are regulating, in the following exchange:

Senator SHOEBRIDGE: One of the criticisms that's made in a series of submissions about this bill is that the operator and the regulator report to the same minister. And they point out that's a significant conflict of interest. If I could firstly start with the current system under ARPANS, the operator and the regulator report to different ministers?

Dr Hirth: Yes.

Senator SHOEBRIDGE: I put to ANSTO, and they agreed, that's really important for social licence. You would agree in your system that's important, social licence?

Dr Hirth: Yes, I would agree.[4]

1.18In further questioning concerning how this independence can be achieved with the Defence Minister having both the regulator and the body it’s regulating reporting to them, ARPANSA stated:

Senator SHOEBRIDGE: Do you agree it's a weakness in this bill to have the operator and the regulator both report to the same minister? Or if you don't want to adopt my phrase, tell me how you would respond to the fact that the regulator and the operator both report to the same minister, given the fundamental importance of independence?

Dr Hirth: I think it's important to go back to the IAEA, and I think the comments made by RINA in your questions to them this morning around undue influence. Establishing reporting arrangements in order that there isn't undue influence of interested parties does present a challenge for the Minister for Defence. However, it has been a decision of government to pursue that pathway. But it also is one of the reasons why in our submission, and in my opening statement, we noted that independence could be further strengthened and provide other mechanisms if that arrangement is to remain in place, for advisory bodies to inform key decisions to be made under the legislation.[5]

1.19Furthermore, there were concerns raised about the development of a new regulatory body, with all the concerns of independence with the ANNPS Bill, which may also lack the expertise needed. As Dr Tilman Ruff, Board Member, International Campaign to Abolish Nuclear Weapons explained:

People with nuclear expertise don't grow on trees; they take a long time to develop. Australia doesn't have a lot of them. We're going to be scraping and scratching and trying to get people back from overseas to manage the nuclear submarine enterprise. All of that will be exacerbated by trying to establish a new agency and essentially duplicate functions that I think could be more efficiently, effectively and independently managed through strengthening the existing regulator. I think, for most of us on the call—and I think I've heard this very consistently from the organisations engaging in this process and making submissions—that there's a pretty strong view that ARPANSA should be the independent regulator, with its mandate specifically expanded to include the management of this project, indeed, as you would've assumed it already did.[6]

1.20The ability of the Minister through proposed section 105 to issue directions to the regulator further blurs the independence of the new regulator. This was a concern for the Australian Shipbuilding Federation of Unions (ASFU), which in its submission said:

The ASFU believes that national security should not be allowed to override the safety of the Australian public, weaken regulatory authority or independence, or inhibit transparency.[7]

1.21Another aspect of the lack of independence concerns the staffing and leadership of the new regulator. It is true that neither the Director-General nor Deputy Director-General can be an active member of the ADF (Australian Defence Force) as specified in proposed section 109.

1.22However, there is nothing stopping someone from immediately stepping out of the ADF and the next day becoming the Director-General or Deputy Director-General, as this exchange with Defence made clear:

Senator SHOEBRIDGE: Yes, but there's nothing that prevents somebody working for Defence on day one, resigning, and then taking a job as director-general on day two, is there?

Mr Moy: There's no specification on what you—

Senator SHOEBRIDGE: They can't be a current member of the Defence Force, is that right?

Mr Moy: They cannot be a current member of the ADF.

Senator SHOEBRIDGE: But they could've been the day before they got appointed?

Mr Moy: There's no limitation on that.[8]

1.23Furthermore, there are no such restrictions on the staff of the regulator, which may all be drawn from active ADF personnel.

1.24This means the supposed independent regulator of Defence can be run by someone who, the day before was in the Defence, staffed by the Defence and report to the Minister of Defence.

1.25It is recommended that the Bill be amended to ensure a genuinely independent regulator and that the regulator reports to the Minister of Health rather than the Minister of Defence.

1.26Alternatively, that the regulator more closely reflects the arrangements in the United States and jointly reports to both the Minister of Health and the Minister for Defence, with these Ministers jointly holding Ministerial responsibility under the Bill.

1.27It is recommended that for transparency any direction issued under section 105 be tabled in Parliament within three days where the direction may, or will, negatively impact public health or safety.

1.28It is recommended that section 109 be amended to:

prohibit the Director General from being a current or former member of the ADF or Department of Defence, and;

that the Deputy Director General not be a current member of the ADF or Department of Defence or have been a member of the ADF or Department of Defence for at least two years prior to any appointment.

No public or First Nations consultation

1.29This Bill allows the Minister of Defence to establish ‘designated zones’ for the storage, management and disposal of low, medium and high-level nuclear waste in any part of Australia the Minister chooses by regulation.

1.30This Bill establishes an initial two zones, one at HMAS Stirling at Garden Island in Western Australia and another at the Osborne Naval Shipyard in South Australia. Both zones are close to major metropolitan centres.

1.31Concerning future nuclear waste dumps, the Minister for Defence has indicated that they will only be on Defence land, however, that includes large parcels of land within every major population centre in the country. The Minister also said this can include ‘future’ Defence land.[9]

1.32However, the Bill does not provide even this limitation on where nuclear waste can be located. In fact, the Bill says in bold terms the waste can be on defence land or ‘any other area in Australia’ identified in the regulations. This means, with the flick of the Minister’s pen, any location in Australia can be made into a high-level nuclear waste dump.

1.33This completely excludes any consultation with the local impacted community or with First Nations people whose land and water will be targeted by Defence. With this Bill, neighbours to large defence sites like Holsworthy in Sydney or Greenbank in Brisbane are right to be concerned that they may wake up one morning, with no notice, to find they back onto a high-level nuclear waste dump.

1.34We have seen from decades of failed attempts to set up nuclear waste sites across the country, most recently at Kimba, that Federal governments have routinely sought to override First Nations people’s claims to the land on this issue. The United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) specifies the importance of free, prior and informed consent before any such action is taken. This Bill does not even pretend to engage with these principles.

1.35As the submission from Friends of the Earth stated:

First Nations communities have repeatedly defeated thuggish, racist governments in relation to radioactive waste facilities but that has come at a huge cost in terms of physical and mental health.[10]

1.36The few protections that the law currently gives to First Nations people over their land are removed by this Bill. The Independent and Peaceful Australia Network raised this during a hearing, stating:

There doesn't seem to have been any notice taken of the United Nations Declaration on the Rights of Indigenous Peoples. They should have the right to prior informed consent on this issue and have full consultation before any designations are made for nuclear waste.[11]

1.37Multiple submissions also raised the comments by Dr Marcos Orellana, UN Special Rapporteur on Toxics and Human Rights, in 2023 on this issue, saying:

It is instructive that all siting initiatives by the Government for a radioactive waste repository have failed, leaving a legacy of division and acrimony in the communities. The loss of lives and songlines resulting from exposure of Indigenous peoples to hazardous pesticides in the Kimberley region, from asbestos exposure in Wittenoom in Western Australia, and from the radioactive contamination following nuclear weapons testing in South Australia, are all open wounds. Alignment of regulations with the UN Declaration on the Rights of Indigenous Peoples is a critical step in the path towards healing open wounds of past environmental injustices.[12]

1.38Concerning the proposed nuclear ‘designated zone’ in Perth, Nuclear Free WA and Stop AUKUS WA noted the importance of the areas around HMAS Stirling, stating in their submission:

Cockburn Sound and Garden Island have significant cultural value for First Nations Peoples … The ecological values of Garden Island, the proximity to Cockburn Sound make radioactive waste disposal here incompatible.[13]

1.39It is remarkable that on an issue so vital to communities, the potential location of a nuclear waste dump, there is zero public consultation required under this Bill. Compare this to existing laws such as the National Radioactive Waste Management Act 2012, where a site must be voluntarily nominated, evaluated against technical, economic, social and environmental criteria, and offered for public consultation.

1.40This, together with the express inclusion of the UNDRIP principles, is the minimum standard that should be expected under this Bill for public and First Nations consultation.

1.41It is recommended that the Bill must ensure that there is free, prior and informed consent from First Nations people and the communities impacted before any designated zone is established for low, medium or high-level naval nuclear waste.

1.42It is recommended that the Bill should expressly include reference to, and compliance with, Australia’s international obligations including the United Nations Declaration on the Rights of Indigenous Peoples.

1.43It is recommended that the Bill should adopt the requirements for public consultation and site identification for designated nuclear zones found in the National Radioactive Waste Management Act 2012.

Transparency and collaboration

1.44The ARPANS Act has key elements to ensure the management of nuclear waste is done in collaboration with other experts and bodies, as well as openly with the public. This Bill fails on both of these fronts.

1.45The proposed naval nuclear regulator sits apart from the entire nuclear regulatory apparatus in Australia. When ARPANSA was asked about the need for express collaboration requirements with existing regulators they responded as follows:

Senator SHOEBRIDGE: Surely that should be included in the bill? You've got decades of experience, which is widely admired and acknowledged. Surely at a minimum the bill should say there should be some structural engagement between the two of you? That would surely enhance the bill, wouldn't it?

Dr Hirth: Yes.

Senator SHOEBRIDGE: You shouldn't have to beg for a meeting?

Dr Hirth: No.

Senator SHOEBRIDGE: And also to the extent to which civil and military regulation can be consistent and that they can draw on your experience, that seems to me to be such a fundamental that I find it surprising it's not in the bill. I don't know what your view on that is. It's almost as though they want to permit the naval regulator to go off on its own choose your own adventure without having any regard to your experience? That's what the bill allows, isn't it?

Mr Reynolds: The bill does provide fairly strict demarcation of the jurisdiction of the defence regulator. In practical terms, there is the intersection of the jurisdiction of the defence regulator and the jurisdiction of ARPANSA that will require structural interfaces. While the detail of that is not expressly provided for in the bill—

Senator SHOEBRIDGE: It doesn't even include a vibe in the bill, let alone the detail. The vibe isn't even in the bill. There's no reference to it, Mr Reynolds.

Mr Reynolds: No. The jurisdiction is clearly marked out; what's not in the jurisdiction then is what forces that structural connection, and we would see the overall statutory framework would be the bill and the regulations together. We would expect that the regulations would cover that element of how that worked.[14]

1.46This was also an issue raised by the Radiation Health and Safety Advisory Council in its October 2023 letter that said:

Separate and unaligned nuclear and radiation regulatory frameworks, for example a Commonwealth nuclear powered submarine regulator apart from existing jurisdictional radiation regulators, could present a risk to public safety.[15]

1.47By creating a legally and functionally separate naval nuclear regulator this Bill ignores decades of experience in both the UK and the US where there is a co-regulatory civil and defence regime. This not only ignores international experience, it also ignores the decades of experience held in Australia’s civilian nuclear regulators and advisers. This is a reckless proposal that will leave Defence to be both the nuclear operator and the nuclear regulator without having ongoing advice from an independent body.

1.48It is recommended that the Bill should require close co-operation and consultation between the proposed naval nuclear regulator and the civilian regulator ARPANSA.

1.49It is recommended that the Bill should be amended to ensure that the Director General receives advice from the relevant nuclear safety advisory groups including the Radiation Health and Safety Advisory Council, Radiation Health Committee and the Nuclear Safety Committee.

UK and US nuclear waste dumping ground

1.50As noted above the Bill is drafted to allow the UK and US to dump nuclear waste, including high-level nuclear waste, from their existing and decommissioned nuclear submarines in Australia.

1.51Despite Minister Marles rejecting this as ‘fear-mongering’ when first raised, this fact was admitted by multiple witnesses, including Defence officials and BAE Systems Australia. It also flows from any even moderately close reading of the Bill.[16]

1.52It turned out to be significantly more than this with numerous organisations confirming that this Bill indeed does allow for the dumpling of nuclear waste in Australia from UK and US submarines.

1.53Mr Peter Quinlivian, Senior Legal Counsel, BAE Systems Australia admitted the law would permit the dumping of nuclear waste from UK nuclear submarines in the following exchange:

Senator SHOEBRIDGE: So when you informed BAE, your counterparts in the UK, that this legislation proposed by Australia enabled a pathway for the disposal of UK high-level nuclear waste into Australia, what was their response?

Mr Lockhart: I'm not familiar with that, I have to say.

SenatorSHOEBRIDGE: The legislation?

Mr Lockhart: Correct. Senator

SHOEBRIDGE: You're not familiar with the fact that the legislation permits the UK nuclear waste stream from AUKUS submarines as defined under the bill—

Mr Quinlivian: If I might—

Senator SHOEBRIDGE: You're not aware of that? That's taken you by surprise?

Mr Quinlivian: I can take that on. I think your question was: what was the reaction of the UK when we informed them of that legislative possibility?

Senator SHOEBRIDGE: Assuming you did.

Mr Quinlivian: The answer to that question is that we did not inform them of that legislative possibility, because it didn't immediately strike us. What you say, I think, is true: the legislation, as drafted, is in language that would accommodate that scenario.[17] [emphasis added]

1.54Mr Adam Beeson, General Counsel, Australian Conservation Foundation, further corroborated this information said:

Senator SHOEBRIDGE: Thank you all for your submissions and assistance today and for your work around the clock in this space. First of all, just on the plain reading of the bill it seems to permit the storage of high-level nuclear waste from US and UK submarines in designated facilities in Australia. That would include potentially the hundreds and hundreds of kilograms of highly enriched uranium that's floating around on decommissioned UK submarines. That seems to be a plain reading of the bill—Mr Beeson?

Mr Beeson: I have no doubt that, in the current form, it permits that.[18]

1.55Mr Kim Moy, Assistant Director-General of the Domestic Nuclear Policy Branch, Department of Defence also admitted that this Bill would allow for the dumping of foreign nuclear waste:

Senator SHOEBRIDGE: And they can take waste from an AUKUS submarine, which is an Australian nuclear submarine or a US or UK nuclear submarine armed with conventional weapons?

Mr Moy: Yes. The bill enables the management of radioactive waste. It is a separate question about what policy or plans are associated with those aspects.

Senator SHOEBRIDGE: Just to be clear, when the bill says 'nuclear waste', it doesn't limit that to low or intermediate but allows it to address high-level nuclear waste, such as the highly enriched weapons-grade uranium that's in the reactors of Virginia-class submarines. It allows for all of that, doesn't it?

Mr Moy: It enables future government decisions to be made when it comes to the management of radioactive waste.[19]

1.56Question on Notice 1 from Defence during this hearing also made clear that the current definition is not just limited to low-level nuclear waste, but high-level nuclear waste too.[20]

1.57This is particularly disturbing given the UK currently has no plan to dispose of the nuclear waste from their nuclear submarines. In the UK there are now six decades of decommissioned rusting nuclear submarines that are filled with high and medium-level nuclear waste for which they have no solution.

1.58To be clear, under this Bill, there is a real and present danger that either this government or a future government will allow UK nuclear waste to be brought to Australia. This is an extraordinary proposal and is so clearly not in Australia’s interests, let alone the interests of communities and First Nations peoples on whose land this toxic waste will be dumped.

1.59Mr Dave Sweeny, Nuclear Policy Analyst, Australian Conservation Foundation addressed these concerns:

Nuclear waste has not been solved by our AUKUS partners, despite six decades of commercial and military nuclear experience. This does provide at least an initial opportunity to host radioactive waste. Ministerial statements have said that we will advance radioactive waste and draw on the experience of our AUKUS partners. So there are dots that can be joined that are deeply concerning. It may well be that that is never the intention. It may well be that there are a set of assumptions that each AUKUS partner will manage their own waste. But we live in a rapidly evolving world, and one could see a situation where our AUKUS partners would see Australia as a little bit of a radioactive terra nullius and see that as an opportunity to address a longstanding and growing critical problem.[21]

1.60If the AUKUS nuclear submarine deal is to splutter on, then it must not be allowed to become a back door entry for the world’s most toxic nuclear waste.

1.61The Bill must be amended to ensure that no UK or US nuclear waste can be stored or disposed of in Australia.

Overrides other laws

1.62This Bill also seeks to override or disregard other laws and international obligations.

1.63For example, the Bill allows for the Minister to override State and Territory laws that might limit where the Federal Government proposes nuclear waste will be stored through proposed section 135 which reads:

If a law of a State or Territory, or one or more provisions of such a law, is prescribed by the regulations, that law or provision does not apply in relation to a regulated activity.

1.64This issue has been noted by local communities and environmental groups including David J Noonan who stated in his submission:

The Bill is undemocratic and disrespectful to the people of SA in a proposed power under Section 135 “Operation of State and Territory laws” to over-ride any SA Laws or provisions of our Laws effectively by decree, a fiat of unaccountable federal agents to annul our Laws by naming then in Regulations.[22]

1.65Section 136 is also very weak concerning the Bill's adherence to international law, stating:

If this Act confers a function on a person, the person must have regard to Australia’s obligations under any international agreement prescribed by the regulations in performing that function.

1.66Compared to other legislation such as the ARPANS Act that uses the stronger term ‘in accordance with’. This point was raised by the International Campaign to Abolish Nuclear Weapons (Australia) in their submission, stating:

This is inadequate and concerning, and different from the ARPANS Act. Australia's non-proliferation obligations and effective application of nuclear safeguards must not be weakened by the planned nuclear-powered submarine acquisition.[23]

1.67Underlining all these concerns is section 132 which states the Australian Radiation Protection and Nuclear Safety Act 1998 ‘does not apply’ to this Bill. If this was not the case, many issues would be rectified.

1.68It is recommended that section 135 of the Bill should be removed to retain existing State and Territory protections for the safe treatment of nuclear materials.

1.69It is recommended, to ensure the Bill meets the existing requirements for Australia's nuclear safety regime to be consistent with international standards, that section 136 be amended to require functions performed to be in accordance with, rather than simply to have regard to, prescribed international agreements.

1.70Each of the above amendments are intended to strengthen a dangerously undercooked bill. Taken together they would significantly strengthen the proposed regulatory regime to make it more independent and to ensure the public interest, public consultation and First Nations’ rights are respected.

1.71However, even if all were adopted, the Bill’s express purpose is to facilitate Australia spending some $368 billion to obtain a handful of nuclear submarines. This entire project comes at an eye-watering cost that strips vital public resources from addressing the climate challenge, the housing crisis and rising economic inequality in our country.

1.72For all these reasons the Bill should be rejected by the Parliament in its entirety.

1.73It is recommended that the Bill be rejected in full.

Senator David Shoebridge

Substitute member

Greens Senator for New South Wales

Footnotes

[1]International Atomic Energy Agency, Fundamental Safety Principles: Principle 2: Role of government, p. 7.

[2]Radiation Health and Safety Advisory Council (RHSAC), letter to Dr Gillian Hirth, Chief Executive Officer of ARPANSA, 13 October 2022.

[3]Dr Lynn Williams, Nuclear Safety Consultant, RINA, Committee Hansard, 13 March 2024, p. 4.

[4]Dr Gillian Hirth, Chief Executive Officer, Australian Radiation Protection and Nuclear Safety Agency, Committee Hansard, 13 March 2024, p. 16.

[5]Dr Gillian Hirth, Chief Executive Officer, Australian Radiation Protection and Nuclear Safety Agency, Committee Hansard, 13 March 2024, p. 16.

[6]Dr Tilman Ruff, Board Member, ICAN, Committee Hansard, 13 March 2024, p. 32.

[7]ASFU, Submission 26, p. 4.

[8]Mr Kim Moy, Assistant Director-General Domestic Nuclear Policy Branch, Department of Defence, Committee Hansard, 13 March 2024, p. 52.

[9]The Hon Richard Marles MP, Minister for Defence, Statement: AUKUS nuclear-powered submarine pathway, House of Representatives, 22 March 2024.

[10]Friends of the Earth Adelaide, Submission 7, p. 5.

[11]Ms Kathryn Kelly, Public Officer, Independent and Peaceful Australia Network, Committee Hansard, 13 March 2024, p. 34.

[12]Dr Marcos Orellana, UN Special Rapporteur on Toxics and Human Rights, End of Mission Statement, 8 September 2023, p. 6.

[13]Nuclear Free WA and Stop AUKUS WA, Submission 15, p. 6.

[14]Dr Gillian Hirth, Chief Executive Officer and Mr Martin Reynolds, General Counsel, Australian Radiation Protection and Nuclear Safety Agency, Committee Hansard, 13 March 2024, pp. 18–19.

[15]RHSAC, letter to Dr Gillian Hirth, Chief Executive Officer of ARPANSA, 13 October 2022.

[16]Lisa Visentin, ‘Marles rejects ‘fear-mongering’ over Greens’ nuclear waste AUKUS claims’, Sydney Morning Herlad, 17 December 2023.

[17]Mr Peter Quinlivian, Senior Legal Counsel and Mr Craig Lockhart, Managing Director, BAE Systems Australia, Committee Hansard, 22 April 2024, p. 7.

[18]Mr Adam Beeson, General Counsel, Australian Conservation Foundation, Committee Hansard,13 March 2024, p. 31.

[19]Mr Kim Moy, Assistant Director-General Domestic Nuclear Policy Branch, Department of Defence, Committee Hansard, 13 March 2024, p. 46.

[20]Department of Defence, answers to questions on notice from a public hearing, 13 March 2024, Canberra (received 24 April 2024).

[21]Mr Dave Sweeny, Nuclear Policy Analyst, Australian Conservation Foundation, Committee Hansard, 13 March 2024, p. 32.

[22]Mr David Noonan, Submission 8, p. 9.

[23]International Campaign to Abolish Nuclear Weapons (Australia) (ICAN Australia), Submission 24, p. 8.