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