82 F. KOPPENBORG
to live up to the ideal of an independent safety agency. These include
competent staff and in-house expertise, sufficient financial resources, independent decision-making, as well as transparency as a prerequisite for
public scrutiny (Gilardi and Maggetti 2011; Wilson 1980). The progress
the NRA has made towards becoming an independent regulatory agency,
according to these criteria, differs from area to area.
Regarding in-house expertise, the NRA implemented different
measures, such as hiring fresh graduates and mid-career officials, limiting
staff rotation with those parts of the administration promoting nuclear
power, restricting retirement to the nuclear industry, and creating a
career in nuclear regulation, including comprehensive in-house training.
Without a doubt an ongoing effort, the NRA embarked on a good path to
achieving sufficient in-house expertise. Turning to the financial resources,
the NRA’s predecessor depended on METI for its budget, making it
vulnerable to external influence. In contrast, the NRA became as financially independent as possible within the administration with seemingly
sufficient financial resources.
All decisions, including regulatory judgements, are made within what
I term a “council system”. Essentially, a two-step process, it ensures
the board, the “NRA Commission”, has the last word in every decision. First, NRA officials from different divisions, or utility representatives
in the case of safety review meetings, provide information and answer
questions about their activities to the respective council. In a second
step, one or two representatives from this council present the matter
to the NRA Commission, which makes all final decisions. As part of
the council system, new regulatory standards were developed without
influence from the regulated parties. Industry representatives were only
consulted regarding practical aspects of conducting the safety review.
The “council system” allows the board of five scientists to control
decision-making processes and to minimise outside influence.
Transparency is an integral part of how administrative agencies should
conduct themselves in a democratic system. By inviting public scrutiny, it
can also limit the extent to which others can openly try to exert influence.
The NRA achieved a high degree of transparency by taking a proactive
approach to being open to the public. Guidelines for transparency and
administrative documents interlink to form an information release system
not subject to disclosure requests. This includes streaming all meetings 7
live on its YouTube channel “NRAJapan” as well as publishing reference
materials on its website. The NRA also opened press conferences to all
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