Missing Bombplex Comments
November 28, 2008
In late October, the Department of Energy (DOE) released the almost 4,000 page final Complex Transformation Supplemental Programmatic Environmental Impact Statement, also known as "The Bombplex." The document contains DOE plans for transformation of the nuclear weapons complex from the Cold War to an enterprise for the 21st Century. The plan includes the two national laboratories in New Mexico: Los Alamos National Laboratory (LANL) and Sandia National Laboratories.
Under the National Environmental Policy Act, DOE is required to provide public review of the draft document, an opportunity for the public to submit comments either at a public hearing or in writing, and an opportunity to provide comments to the final document. DOE received over 100,000 comments about the draft plan.
The final document contains four volumes. Two volumes contain the plan and the other two volumes contain reprints of the public comments and the DOE response to them. A CD accompanies the plan.
CCNS reviewed the final document and prepared comments to DOE that focused on the impacts of continued plutonium pit production on communities both downstream and downwind of LANL. In our review, we discovered that some of the public comments, which we knew had been submitted by people in Northern New Mexico, were missing in the printed volumes.
One example is a letter of support for the formal comments submitted to DOE by the Tribal Council of Santa Clara Pueblo signed by over 240 members and residents of Santa Clara Pueblo.
Another example is the petition circulated by the youth members of Community Service Organization del Norte in the Espanola Valley requesting an extension of the comment period for the draft plan.
CCNS contacted DOE and learned that these comments were located on the accompanying CD. Ted Wyka, of DOE, explained that adding the petitions would have added hundreds of more pages to the length of the document and for that reason they were put on the CD.
Marian Naranjo, of Honor Our Pueblo Existence and one of the people who gathered the signatures of support at Santa Clara Pueblo, said, "DOE chose to separate the signatures of support from the actual comments of the Santa Clara Pueblo Tribal Council. DOE buried the signatures of support on the CD without making any direct reference to them in the text of the massive document. This action diluted the strength of the essences making these comments as a community. The Santa Clara Pueblo Tribal Council comments and signatures of support should be viewed as historical and inclusive of the unity of a sovereign nation where the DOE's plan is concerned."
CCNS also discovered that individual comment letters from people living in the Rio Embudo Watershed are omitted from any listing in the final plan and the CD.
The April 9, 2008 comments of the New Mexico Conference of Catholic Bishops are also missing. The Most Rev. Michael J. Sheehan, Archbishop of Santa Fe, and the Most Rev. Ricardo Ramirez, CSB, Bishop of Las Cruces, sent the comments.
DOE says they are still searching for the missing comments.