Manitou River
We offer the following commentary and recommendation for your careful consideration:
Is the “initial” screening of radionuclides adequate basis for removing them from the designation process?
The Annex 3 co-leads recommend that you not go onto the “detailed screening” step. Our review of their presentation to GLEC and of their 123-page draft screening document1 is that it is not an adequate basis for not advancing radionuclides onto the “candidate CMC” stage. In material attached to this letter, we provide feedback on items that we think are the main flaws in the analysis and assessment of the criteria framework.
The fundamental flaw in the “initial” screening is that it ignores the GLWQA. Since CMCs are an instrument unique to the GLWQA, that Agreement must be the major guide when making decisions on CMCs or potential CMCs.