Written evidence submitted by the Australian Conservation Foundation (ACF).

ACF

The Australian Conservation Foundation Inc (ACF) was founded in the mid-1960s with the support of prominent Australians, the Government and the wider community and is Australia’s lead national environment organization and advocate for the environment.

ACF is strictly non-partisan, and we are proud of our political independence.

ACF and AUKUS

ACF holds serious concerns around the AUKUS Agreement and especially the nuclear submarine acquisition project. These exist around environmental and waste management impacts, costs and consequences and the way this initiative has been advanced.

ACF welcomes this opportunity to engage with a review being conducted by one of the AUKUS partner nations. We appreciate this is an initiative of the UK Parliament’s Defence Committee and as such is less focussed on Pillar One considerations, but we contribute these comments to provide some insight into civil society attitudes in Australia and because some of these concerns may be shared and of value in your consideration from a UK perspective.

ACF maintains there needs to be broader examination of the AUKUS proposal. We support the Australian civil society call for further scrutiny and a dedicated and transparent inquiry with terms of reference that address the cost and rationale of AUKUS as well as nuclear proliferation, emergency management, and waste management.

The approach of successive Australian national governments in relation to assessing AUKUS to date has been modular and constrained and has failed to address genuine concerns with the Agreement’s strategic foundation and rationale.

This constrained approach is highlighted in earlier National Interest Analysis (ATNIA 14) of the Agreement by Australian government agencies which stated: “No public consultation has been undertaken, given the classified scope of consultations between the Parties on the Agreement”.

In September 2021, the acquisition of nuclear-powered submarines was described by the Australian Chief of Navy Vice Admiral Michael Noonan as “the single most consequential capability decision” and one that would “no doubt change the shape of our nation”.

Given the profound – indeed nation changing - strategic, safety, environmental and economic implications of this decision there has been little public or Parliamentary scrutiny of the AUKUS project in Australia.

ACF maintains this approach actively reduces scrutiny, precludes the credible and comprehensive consideration of the many complex issues and undermines both community confidence and procedural credibility.

We hope that your Inquiry addresses some of the many areas of uncertainty and concern around the Agreement’s implications.

Scope of ACF concerns

ACF concerns around the AUKUS Agreement include:

•                      Radioactive waste management issues and impacts

•                      First Nation and wider community consultation, consent and social license

•                      Nuclear security, safety and non-proliferation considerations

•                      Environmental and public health risks and impacts, esp. from nuclear materials

•                      Emergency management and nuclear incident response capacity

•                      Adequacy and robustness of licensing and regulatory regimes

•                      Political uncertainty around issue alignment with the Trump Administration

•                      Untested assumptions over efficacy, rationale and capacity to deliver 

•                      Mission creep - including with proposals to extend the Agreement to Space            

•                      Environmental and social opportunity costs due to massive capital diversion

Please find attached and below for the Committee’s consideration the following ACF materials:

• Comments on the Australian Naval Nuclear Power Safety legislative framework
• Submission regarding the Agreement among the Government of Australia, the UK and the USA
• Media piece from the Australian newspaper (27/5/25) outlining increasing scope AUKUS in space: ScoMo proposes ‘Pillar 3’ for defence pact

Conclusion and contacts: 

ACF welcomes this opportunity to share concerns that we have raised through Australian Parliamentary processes to the UK Parliament.

We feel that this is pertinent to your Committee because of both the material linkages and the wider need for enhanced scrutiny of this Agreement.

The importance of such transparency was well made by the House of Lords in R v Shayler (2003):

Modern democratic government means government of the people by the people for the people. But there can be no government by the people if they are ignorant of the issues to be resolved, the arguments for and against different solutions and the facts underlying those arguments. The business of government is not an activity about which only those professionally engaged are entitled to receive information and express opinions. It is, or should be, a participatory process. But there can be no assurance that government is carried out for the people unless the facts are made known, the issues publicly ventilated.

30th May 2025