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