Reflection on ‘risk analysis and uncertainty: what does this mean for the Dutch energy transition’ by Frederic Bouder and Ragnar Lofstedt

A general trend in the use of the Dutch deep subsurface is a shift from hydrocarbon production to geothermal energy production and subsurface storage of CO2 and H2. A broad mistrust by the general public, and many local governments, of any deep-subsurfacerelated activity leads to an increasing tendency to block any development that might potentially cause harm to humans or the environment. A complicating factor in this respect is the uncertainty surrounding new technology and the lack of related historical data (notably seismic records). We support the opinion of Boulder and Lofstedt (2024) that to effectively address this problem, we should avoid a dichotomy of acceptable versus unacceptable risks, as stimulated by the use of the precautionary principle. Instead, we should use a Tolerability Of Risk (TOR) approach with the As Low As Reasonably Practicable (ALARP) principle as key element.