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Letter to the Department of Energy Requesting More Time to Comment on Reprocessing
published Monday, November 10, 2008  3755 Views :: 3 Comments
11/3/2008
Samuel Bodman
Secretary of Energy
1000 Independence Ave, SW
Washington, DC 20585
The.secretary@hq.doe.gov

Dear Secretary Bodman,

On behalf of our members, the undersigned 48 local and national environmental, peace and security, taxpayer and public health organizations, we request a 120-day extension to the comment period for the Draft Global Nuclear Energy Partnership (GNEP) Programmatic Environmental Impact Statement (PEIS) currently scheduled to end on December 16, 2008, before the final PEIS is released.

We believe this extension is warranted because (1) Department of Energy (DOE) failed to provide analysis of nonproliferation impacts within the draft PEIS even though DOE had indicated that this important assessment would be made available in conjunction with the PEIS, (2) online accessibility to reference materials cited in the draft PEIS was delayed by more than a week, and is still not available for many documents, (3) the proposal is technically complex with national implications, and (4) the comment period coincides with the upcoming Presidential elections, and holidays, which may make it more difficult for the public to review and comment on the draft PEIS.

Most significantly, DOE has failed to provide any nonproliferation analysis within the draft PEIS. Instead, the draft PEIS simply states that a separate assessment of the nonproliferation aspects of the programmatic alternatives is being prepared and that it “will be considered by DOE in decisions regarding the GNEP proposal.” No timetable is given for the document’s release other than “in the same time frame as this Draft GNEP PEIS.” Given that the nonproliferation impacts of GNEP are one of the most important aspects of the program, the public cannot adequately comment on the GNEP proposal until a complete nonproliferation impact analysis is provided. Once the nonproliferation analysis is released, the public needs adequate time to review and comment.

Furthermore, the DOE GNEP website contains a 22-page index to the draft PEIS references (http://www.gnep.energy.gov/peis/Draft_PEIS/ReferenceIndex.pdf), but does not make all of these reference documents accessible to the public. Reference documents should be more than just publicly available; they need to be easily accessible. All of the reference documents cited in the 22-page index need to be posted online. After that, the public will need additional time for the documents to be read.

In addition, the comment period is insufficient to enable the public to thoroughly review and comment on this highly technical and enormous document. DOE acknowledges in the draft PEIS that GNEP affects “the entire United States because facilities associated with the programmatic alternatives could be deployed anywhere in the country” and that the “PEIS involves a technically complex subject matter with unique concepts and terminology.” In 2007, the national scale and complex nature of the GNEP proposal required a scoping period of 151 days, which resulted in an unprecedented 14,000 comments submitted to DOE. The National Environmental Policy Act (NEPA) requires that public scoping comments must be at least 30 days (10 CFR 1021.311(c)) and that public comment on a draft EIS must be at least 45 days (10 CFR 1021.313(a)). The intent of this regulation is that the public comment period for the draft EIS be longer than the scoping comment period. Since the GNEP scoping comment period was 151 days, the public comment period on the draft PEIS should be longer, at least 180 days.

Finally, the current period allotted for public comment spans the last few weeks of an historic presidential and congressional election, followed by turbulent period of transition between old and new administrations, and also includes a large part of the holiday season. This is the worst possible time for members of the public and interested agencies to be attempting to review and comment on a complex document such as this, on such a sensitive and controversial subject, and without any of the supporting documentation yet made available to the public. The new teams coming into DOE and other relevant executive agencies, and new members of Congress and their staffs, deserve adequate time to review and comment on the PEIS before the agency moves to a Record of Decision. In order to bring the national public’s attention to the GNEP proposal and allow sufficient time to respond to the draft PEIS, an extension of the comment period is essential. Therefore, we ask that the comment period extend well into the New Year.

Failure to provide adequate time for public review and comment on the draft PEIS, nonproliferation impact statement, and all EIS supplementary references would marginalize and compromise the public’s role as an essential participant in the NEPA process. It would have a further negative impact on the Department’s ability to assess the impacts of the vast GNEP proposal.

We believe that the requested 120-day extension is necessary and reasonable. It would allow for the distribution of the nonproliferation impact statement, associated reference materials, and provide adequate time for the public to provide comments to DOE.

Thank you for your consideration,
List of 48 signatories is attached.

Please direct your response to:
Nickolas Roth
Program Director
Alliance for Nuclear Accountability
322 4th Street NE
Washington, DC 20002
nroth@ananuclear.org
(p)202-544-0217
(f) 202-544-6143


National Organizations

Susan Gordon
Director
Alliance for Nuclear Accountability

Daryl Kimball
Executive Director
Arms Control Association

Kevin Kamps
Radioactive Waste Watchdog
Beyond Nuclear

Martin Fleck
Coordinator
Campaign for Nuclear Weapons Free World

Leonor Tomero
Director of Nuclear Non-Proliferation
Center for Arms Control and Non-Proliferation

Joe Volk
Executive Director
Friends Committee on National Legislation

Tom Clements
Southeastern Nuclear Campaign Coordinator
Friends of the Earth

David Krieger
President
Nuclear Age Peace Foundation

Paul Kawika Martin
Organizing, Political and PAC Director
Peace Action & Peace Action Education Fund

Michele Boyd
Director, Safe Energy Program
Physicians for Social Responsibility

Frank Von Hippel
Professor and Co-Director Program on Science and Global Security
Princeton University

Tyson Slocum
Director, Energy Program
Public Citizen

Diane D’Arrigo
Radioactive Waste Project Director
Nuclear Information and Resource Service

Dave Hamilton
National Radiation Committee
Sierra Club

Autumn Hanna
Senior Program Director
Taxpayers for Common Sense

Stephen Young
Senior Analyst/Washington Representative Global Security Program
Union of Concerned Scientists

Susan Shaer
Executive Director
Women’s Action for New Directions

State Organizations

Rochelle Becker
Executive Director
Alliance for Nuclear Responsibility
San Luis Obispo, California

Judith Mohling
Staff Member
Rocky Mountain Peace and Justice Center
Boulder, Colorado

Molly Johnson
Area Coordinator
Grandmothers for Peace/San Luis Obispo County Chapter
San Miguel, California

Marylia Kelley
Executive Director
Tri-Valley CAREs
Livermore, California

Glenn Carroll
Coordinator
Nuclear Watch South
Atlanta, Georgia

Bobbie Paul
Executive Director
Women’s Action for New Directions Atlanta, Georgia

Beatrice Brailsford
Program Director
Snake River Alliance
Boise, Idaho

Kristi Hanson
Regional Association of Concerned Environmentalists
Brookport, Illinois

David A. Kraft
Director
Nuclear Energy Information Service
Chicago, Illinois

Mark Donham
Coalition for Health Concern
Benton, KY

Ann Suellentrop
PeaceWorks/KC Physicians for Social Responsibility
Kansas City, Missouri

Jane Feldman
Energy Chair
Sierra Club, Toiyabe Chapter
Reno, Nevada

Joni Arends
Executive Director
Concerned Citizens for Nuclear Safety
Santa Fe, New Mexico

Jay Coghlan
Director
Nuclear Watch New Mexico
Santa Fe, New Mexico

Don Hancock
Nuclear Waste Program Director
Southwest Research and Information Center
Albuquerque, New Mexico

Alice Slater
Nuclear Age Peace Foundation
NewYork, New York

Louis Zeller
Science Director
Blue Ridge Environmental Defense League
Glendale Springs, North Carolina

Connie Altman
President
Scioto Peace & Justice, local branch of Fellowship of Reconciliation
Lucasville, OH

Kathleen Boutis
President
Southern Ohio Neighbors Group
Piketon, Ohio

Vina Colley
National Nuclear Workers For Justice/ Portsmouth/Piketon Residents for Environmental Safety and Security
Portsmouth, Ohio

Lisa Crawford
President
Fernald Residents for Environmental Safety & Health
Harrison, Ohio

Patricia A. Marida
Nuclear Committee
Sierra Club, Ohio Chapter

Rachel Larson
Chapter Director
Physicians for Social Responsibility,
Oregon Chapter

Thomas Au
Conservation Chair
Sierra Club, Pennsylvania Chapter

Arnold E. Karr
Director
Carolina Peace Resource Center
Columbia, South Carolina

John Ramsburgh
Chapter Director
Sierra Club, South Carolina Chapter
Columbia, South Carolina

Nancy Vinson
Program Director
South Carolina Coastal Conservation League

Ralph Hutchison
Oak Ridge Environmental Peace Alliance
Oak Ridge, Tennessee

Vanessa Pierce
Executive Director
Healthy Environment Alliance of Utah
Salt Lake City, Utah

Tom Carpenter
Hanford Challenge
Seattle, Washington

Gerry Pollet, JD;
Executive Director,
Heart of America Northwest
Seattle, Washington


 



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