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Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ d) The counterpart of reporting requirements of the management. In the two best case examples, decommissioning by EDF in France (see chapter 3.2.2) and in Germany at EWN (see chapter 3.4.2) the driving factor for achieving consistent and well-controlled organisation structures was in the economic as well as the political self-interest of the responsible organisations: to reduce the costs by effective re-structuring and by achieving a well-balanced accord between decommissioning targets and effective cost control (EDF: on behalf of its shareholders; EWN: on behalf of the taxpayers). In the cases of EDF and of EWN the achieved cost optimization had direct advantages for these organisations. Another difference between the best cases and the decision-making in the Bulgarian, Lithuanian and Slovakian cases is the quality of supervision imposed on the managing organisation. It is neither directly required to report on its performance nor to achieve consent for their projects in the Donor Assembly, because EBRD acts on behalf of them. If delays or excess costs have to be reported it is not the managing organisation that has to take over responsibility. Supervision by the Donor Assembly is not imposed on the management organisation but on EBRD. Thus, the continuous supervision imposed by BMF on EWN’s management cannot be compared with the much less rigorous practice in this case. Over the past years the national structures to steer and supervise the managing organisations have progressed in all three countries but never reached intensity and tightness like in the two described best cases. One reason for that might be that the vast majority of the spent resources stems from external sources so that cost optimization has a much smaller advantageous effect for those countries. 4.3.3. Development of a proposal to strengthen the national framework In this current situation, opportunities to strengthen the role of the national administering and supervising agencies could be to a) Principally co-share the decommissioning projects, and to b) Implement a joint supervision over the managing organisation. The following develops a proposal on how these structures could be improved. Co-financing the decommissioning costs would increase the country’s interest in controlling the managing organisation’s strategic decisions towards increased cost effectiveness. In the co-financed projects both institutions financing the activity (EC and National Administration) should equally and in a co-directed manner oversee their effectiveness. The share should be defined at a fixed level, but allowing the EC’s contribution to be lowered when projects are only in part related to decommissioning. The fixed level should be depending upon the country’s abilities, but should not be below certain thresholds to achieve the desired goal. Shared financing is a well-known EU instrument, e.g. with structural funds in regional policy to improve development in needy regions (EU 2013). Strengthening the overall control over the management’s organisation could in parallel be achieved by implementing a joint control institution, following BMF’s approach at EWN. In the case of EWN, BMF was the only supervising agency, so the design of control structures was easier than in Bulgaria, Lithuania and Slovakia. As there are two institutions co-financing the decommissioning – the EC and 104
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ the national control organisation -, a joint control instrument is appropriate in this instance of coshared financing. The joint control should be limited to Strategic decisions (see chapter 2.4.3), leaving operational decisions with the management of the implementing organisation, Those parts of the organisation that relate directly to decommissioning. The latter is relevant for Bulgaria and Slovakia. There, the managing organisation has additional tasks beyond decommissioning (such as radiation protection, planning and operating interim storages or final waste disposal facilities, etc.), so that a large part of the organisation’s tasks are not related to funded decommissioning projects. As a result, the persons in the Supervisory Body to oversee the decommissioning process must meet specific criteria and expectations: It should be continuous in terms of nominated persons. As the decommissioning process is a long-term undertaking it is absolutely essential to strive for high continuity. The nominated persons have to be closely familiar with the subject, the technical plans, their cost implications and the organisational framework, because the supervised management organisation can only act in a responsible manner if it has a highly qualified counterpart. The nominated persons should be and act independent from the managing organisation, the funding sources and the fund administration, so that their central interest in achieving a consistent management approach is not biased by contradicting aspects and interests. As working successful in the supervisory board envisages close communication with the national supervisor, close knowledge of the national framework as well as high-level communication skills are required. Where not (yet) appropriately qualified, the supervisory board should engage external experts of its own choice to evaluate the management’s plans and proposals. The following structure (Figure 34) would result from that setting. Single sided arrows mean 'sent representatives to' and 'having control over', the double sided arrow means 'exchange' and 'coordination'. 105
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