CCNS Submits Comprehensive Comments in Opposition to Proposed LANL Electrical Line
This week Concerned Citizens for Nuclear Safety, individuals and NGOs submitted comments opposing the U.S. Forest Service’s plan to approve a Los Alamos National Laboratory (LANL) proposal to install a companion electric transmission line through the heart of the Caja del Rio traditional cultural landscape, an area sacred to Pueblos. wo addresses CCNS et al. Objections to USDA USFS re DOE NNSA f EPCUP (1)
Progression of events and supportive documentation:
02/07/2024
240207 Agenda No.4.A. FFS+BESS Presentation Addl Slides
02/21/2024
20240221 LAC BPU Agenda, FFS+BESS Agenda Item No. 7.C
20240221 LAC BPU Minutes FFS+BESS
A – DESRI Foxtail Flats Presentation for LAC_022124
B – Foxtail Flats Solar PPA-ESA Presentation_022124
C – Foxtail Flats – Solar Power Purchase Agreement_022124
D – Foxtail Flats – Energy Storage Agreement_022124
02/27/2024
20240227 LAC Council Agenda FFS+BESS
20240227 LAC Council Minutes FFS+BESS
A – DESRI Foxtail Flats Presentation for LAC_022724
B – Foxtail Flats Solar PPA-ESA Presentation_022724
C – Foxtail Flats Solar – Power Purchase Agreement_022724
D – Foxtail Flats Storage – Energy Storage Agreement_022724
From the Caja, located in southwest Santa Fe, the line would follow the path of two existing electric lines above the Rio Grande and connect to Department of Energy (DOE) electric substations on the Pajarito Plateau to the west. LANL’s proposed project is called the Electrical Power Capacity Upgrade Project and would carry 173 megawatts per day. https://environment.lanl.gov/resources/epcu/
The big questions are: Why is the line needed? Why is LANL tripling its capacity? For the last 30 years, LANL energy use has remained steady at 90 megawatts per day. Is the extra energy needed to fabricate 30 plutonium pits, or the triggers, for nuclear weapons? https://discover.lanl.gov/news/1002-diamond-stamps-plutonium-pit/ LANL is not saying.
The National Environmental Policy Act, or NEPA, requires federal agencies to prepare analyses of the alternatives to its preferred project. In this case, DOE said there were two choices: build the Electrical Power Capacity Upgrade Project or do nothing.
In February 2024, CCNS discovered that Los Alamos County was pursuing construction and operation of a 170 megawatt solar project located in the area of the now defunct coal-burning San Juan Generating Station. For decades, the coal-fired energy from the northwest corner of New Mexico flowed across existing electricity lines to LANL.
The new solar project, called the Foxtail Flats Solar + Battery Energy Storage System, would use the existing lines to deliver carbon free energy to LANL. https://www.losalamosnm.us/Initiatives/Foxtail-Flats-Solar-Power-and-Battery-Storage
Even though DOE has been involved in the Foxtail Flats Project through a 1985 energy pooling agreement with Los Alamos County (the Los Alamos Power Pool), DOE neglected to include the Foxtail Flats Project in its NEPA analyses as a valid alternative to the Caja line. That omission is one of the topics addressed in the objections CCNS submitted to the Forest Service.
Further, the Honorable Mary Geiger Lewis, a US District Court Judge in South Carolina, recently ruled in the NEPA plutonium pit case that “an ‘agency’s elimination of an alternative from detailed study . . . [is] arbitrary and capricious [when] its explaination for doing so [is] inconsistent with its stated purpose.”
Similarly, DOE eliminated the alternative of the Foxtail Flats Project from detailed study in its Caja line NEPA documents in an arbitrary and capricious manner.
See NEPA plutonium pit case: Savannah River Watch, Tom Clements, The Gullah/Geechee Sea Island Coalition, Nuclear Watch New Mexico and Tri-Valley Communities Against a Radioactive Environment v. United States Department of Energy, Jennifer Granholm, in her Official Capacity as the Secretary; the National Nuclear Security Administration; and Jill Hruby, Administrator.
https://law.justia.com/cases/federal/district-courts/south-carolina/scdce/1:2021cv01942/265178/207/
- Friday, November 1st at noon at the intersection of West Alameda and Sandoval for the weekly one-hour peaceful protest for nuclear disarmament. Join the weekly peaceful protest with Veterans for Peace, CCNS, Nuclear Watch NM, Loretto Community, New Mexico Peace Fest, Pax Christi and others. Bring your flags, signs and banners!
- Sunday, November 3rd –
Daylight Savings Time ends.
- Tuesday, November 5th –
Election Day. If you haven’t voted, CCNS urges you to go to the polls to vote.
- Monday, November 11th from 10:30 am to noon on the Santa Fe Plaza –
Armistice Day. Join Veterans for Peace to celebrate Armistice Day. There will be singing and speakers.
Over one hundred years ago, in 1918, the world celebrated peace as a universal principle. The first World War had just ended and nations mourning their dead collectively called for an end to all wars. Armistice Day was born and was designated as “a day to be dedicated to the cause of world peace and to be thereafter celebrated.”
- Tuesday, November 12th – Friday, November 15th
– PFAS Rulemaking Hearing by the NM Oil Conservation Commission (OCC), a division of the Energy Minerals & Natural Resources Department. For more information, https://www.emnrd.nm.gov/ocd/wp-content/uploads/sites/6/Notice-of-Public-Meeting-and-Rulemaking-hearing.pdf.
Take action at: https://action.wildearthguardians.org/page/57741/petition/1 ; https://www.defendnmwater.org/
- Friday, November 15th,
NM Radioactive and Hazardous Materials Committee meeting at State Capitol in Santa Fe. https://www.nmlegis.gov/Committee/Interim_Committee?CommitteeCode=RHMC Check back for more information as it is posted.
Tags: All Pueblo Council of Governors, amend July 2022 Santa Fe National Forest Land Management Plan, APCG, APCG Resolution 2024-01, BLM, Bureau of Land Management, Caja del Rio Plateau, conduct full environmental impact statement, Decision Notice and Finding of No Significant Impact, Department of Energy, DOE, EA, Electrical Power Capacity Upgrade, EPCU, FFS + BESS, final Environmental Assessment, FONSI, Foxtail Flats Solar + Battery Energy Storage System, LANL, Los Alamos National Laboratory, MA, meaningful tribal consultations, National Environmental Policy Act, National Nuclear Security Administration, NEPA, NNSA, Pueblo-led ethnographic study, Rio Grande, S/N Transmission Line Utility Corridor Management Area, scoping comments, special use permit, The Honorable Mary Geiger Lewis – U.S. District Court Judge in South Carolina, U.S. Forest Service
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