Folks - do we want to sign and send this letter?
Jim Sconyers jim_scon@yahoo.com 603.969.6712
Remember: Mother Nature bats last.
----- Forwarded Message ---- From: John Hartz Hartzjm1@AOL.COM To: CONS-SPST-GLOBALWARM-CHAIRS@LISTS.SIERRACLUB.ORG Sent: Thursday, October 30, 2008 1:37:21 PM Subject: Please sign onto GNEP comment extension letter!
FYI
________________________________ -----Original Message----- From: Nickolas Roth nroth@ananuclear.org To: bananas@ananuclear.drizzlehosting.com Sent: Thu, 30 Oct 2008 12:30 pm Subject: [Bananas] Please sign onto GNEP comment extension letter!
To all,
Tomorrow is the deadline for signing onto the letter to DOE requesting an extension to the GNEP PEIS comment period. More than local and national 20 groups have signed on. If you have already signed on, YOU ROCK! If you have not yet done so, FOR SHAME. However, there is still time. Be part of a growing movement! Sign today!
Thanks, Nick
Samuel Bodman Secretary of Energy 1000 Independence Ave, SW Washington, DC 20585
Dear Mr. Bodman,
On behalf of our members, the undersigned 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 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 PEIS even though DOE had indicated that this important assessment would be made available in conjunction with the PEIS, (2) reference materials cited in the PEIS have not been made available for review, (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 PEIS.
Most significantly, DOE has failed to provide any nonproliferation analysis within the EIS. Instead, the 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 documents 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,
Nickolas Roth Program Director Alliance for Nuclear Accountability 322 4th Street NE Washington, DC 20002 (p)202-544-0217 (f) 202-544-6143
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