I think after the "specific landfill disposal" bullet point additional criteria should be added to explain when this would be used and to stress this would not be utilized for LLW/ILW/HLW. REGDOC-2.11.1 does not mention "landfill disposal" so I believe it should have clarifying details in the policy.
"The waste owner is also responsible for implementing those plans and ensuring that funding is in place to maintaining institutional control, unless that responsibility was transferred to a third party"- should this be clarified to identify how long the control must be maintained? Should there be a mention of optimization or about revisiting LNT assumptions for when control would no longer be required?
In regards to the question about whether the State's disposal facilities would only accept radioactive waste of national origin or from other States as well I believe there should be a clause added which would state that if we accept fuel from an international origin (i.e. SMR fuel, "spent" PWR/MOx/BWR fuel for feedstock in CANDU reactors, etc.) we should accept disposal responsibility for the waste rather than shipping the waste internationally for disposal. Essentially if we are utilizing the international fuel for domestic energy and are therefore gaining usefulness from the import we should accept responsibility for disposal rather than transporting it back internationally for disposal.
Ultimately I agree that we should continue with the Adaptive Phase management and not be in a rush to permanently dispose of spent fuel as there are technologies/reactors which can still extract energy from them but I strongly encourage the creation of a spent fuel repository as the lack of this facility has been used as an argument that nuclear should no longer be pursued.