January 23, 2025

Crunch time! Please come to the LANL Site-Wide Environmental Impact Statement Hearings Feb. 11-13. Help spread the word! (Part I)

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This is a letter to our New Mexico-oriented activist mailing list, a subset of our whole mailing list.

• Our most recent Bulletin, sent to our whole mailing list: Bulletin 354: Thank you! / Fundraising drive continues / "How New Mexico Ranks" (12/23/24)
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Synopsis of this letter:

• If you live within driving distance of one or more of the upcoming hearings regarding the Draft Site-Wide Environmental Impact Statement (SWEIS) for Los Alamos National Laboratory (LANL), we urge you to attend those meeting(s) IN PERSON, and get others to do so as well. Virtual attendance is much less valuable. Signs, banners, costumes, are all possible and welcome.

• We urge you to use these hearings in whatever way you can to publicly proclaim your resistance to producing any plutonium warhead cores ("pits") at LANL, and get your friends, and organizations you know, to do so as well. You can be as creative as you like. Sincerity and commitment count. It is our job to help amplify your voice. Help us help you.

• We must make these hearings serve us -- the public, tribes, and local and state governments -- not the National Nuclear Security Administration (NNSA) or LANL. While we respect those who worked on the draft SWEIS, most of whom are doing the best they can, overall these hearings are not a good-faith exercise on NNSA's or LANL's part. In themselves, these hearings are a simulacrum of democracy, a show, not the real thing. Those who testify or send comments will not be heard by NNSA in any meaningful way; all the decisions have been made or will be made regardless of what is said by any of us. For us, these hearings are blank slates on which we all can write, empty stages where we can speak and enact the truths we see. They are occasions in which we can build solidarity and find fellowship as we pursue a very different agenda from LANL's: a life-affirming agenda for New Mexico and the United States. How would YOU express that? Tell us all, at the hearings!

• We want everyone to endorse the Call for Sanity, Not Nuclear Production. Your endorsement helps build solidarity with the more than 1,000 individuals and 245 businesses and organizations currently on board.

• If you plan to testify using words, please send us your testimony in written form before, or at, or soon after the hearings and we will collect and post these testimonies on-line. We will also film the procedings and make that footage available on our YouTube channel.

• LANL pit production is far from a "done deal." Many years and billions of dollars of continued plutonium build-up lie ahead, if investment continues. It is a troubled program, with many strikes against it. We urge you to join us in building further opposition. See What You Can Do. Pit production in the U.S. has already been postponed many years by public opposition, especially in New Mexico. New Mexicans have repeatedly stood up bravely and successfully against new nuclear weapons, by opposing the making of plutonium pits at LANL. Do not give in to counsels of acceptance and passivity. If pit production at LANL is normalized and accepted it could metastasize, despite all its problems. Other hazardous missions might come as well.

Dear friends --

As you probably read ("Nuclear agency releases draft environmental impact statement for Los Alamos National Laboratory," 1/9/25), the Department of Energy (DOE) and NNSA have released their draft SWEIS for LANL.

We urge you to attend and testify at one or more of the upcoming hearings regarding this draft document.

LANL Draft SWEIS hearing dates, times (all are in Mountain Time), and locations

• Tuesday, February 11, 2025, 1:00-4:00 pm (Virtual Meeting: 1:30-4:00 pm), Santa Fe Community Convention Center, Sweeney Ballroom, 201 W. Marcy St., Santa Fe, NM 87501 (map)
• Tuesday, February 11, 2025, 5:00-8:00 pm (Virtual Meeting: 5:30-8:00 pm), Santa Fe Community Convention Center, Sweeney Ballroom
• Wednesday, February 12, 2025, 5:00-8:00 pm, Mision y Convento, 405 N. Paseo de Onate, Española, NM 87532 (map)
• Thursday, February 13, 2025, 5:00-8:00 pm, Fuller Lodge, 2312 Central Ave., Los Alamos, NM 87544 (map)

The draft SWEIS is long and detailed. Some of us will read it carefully, but you can get a pretty good idea of what it says from the Summary.

It has three "alternatives," a word we to which we would add quote marks. Quoting from NNSA, these are:

The No-Action Alternative includes 87 new projects, totaling almost 1.5 million square feet, that would be implemented between 2024 and 2038. Also, under No-Action, NNSA would implement 11 projects involving facility upgrades, utilities, and infrastructure affecting about 216 acres of the LANL site. About 1.6 million square feet of excess or aging facilities would undergo DD&D under the No-Action Alternative. The No-Action Alternative also includes changes in operations, examples of which include increased plutonium pit production and the remediation of a chromium plume in Mortandad Canyon (which was the subject of a recent environmental assessment).

The Modernized Operations Alternative includes the scope of the No-Action Alternative plus additional modernization activities, including (1) construction of replacement facilities; (2) upgrades to existing facilities, utilities, and infrastructure; and (3) DD&D projects. Under the Modernized Operations Alternative, NNSA would replace facilities that are approaching their end of life, upgrade facilities to extend their lifetimes, and improve work environments to enable NNSA to meet operational requirements. The Modernized Operations Alternative also includes proposed projects to reduce greenhouse gases and other emissions. The Modernized Operations Alternative includes 139 new projects, totaling over 3.4 million square feet, that would be implemented between 2025 and 2038. Under Modernized Operations, NNSA would implement 27 projects involving facility upgrades, utilities, and infrastructure affecting about 925 acres of the LANL site. Of these 925 acres, up to 795 acres are proposed for installation of up to 159 megawatts of solar photovoltaic arrays across the site. An additional 1.2 million square feet of excess or aging facilities would undergo DD&D under the Modernized Operations Alternative.

The Expanded Operations Alternative [the "Preferred Alternative"] includes the actions proposed under the Modernized Operations Alternative, plus actions that would expand operations and missions to respond to future national security challenges and meet increasing requirements. This alternative includes construction and operation of new facilities that would expand capabilities at LANL beyond those that currently exist. The Expanded Operations Alternative includes 18 additional new projects, totaling about 947,000 square feet, that would be implemented between 2025 and 2038. Under Expanded Operations, NNSA would implement 4 additional projects involving utilities and infrastructure affecting about 46 acres of the LANL site. Most of the utilities and infrastructure projects would be directly related to proposed projects under the Expanded Operations Alternative. The Expanded Operations Alternative also includes changes in operations, examples of which include revised wildland fire risk reduction treatments and management of feral cattle.

The simplest and best way to see these SWEIS "alternatives" is to understand that they aren't alternatives at all. By merely including all these projects in the SWEIS, NNSA will have done, by its lights, sufficient analysis under the National Environmental Policy Act (NEPA) to go ahead with any or all of them. Anything named in this SWEIS will be "covered" no matter which alternative is chosen in the first Record of Decision (ROD). If it turns out that the ROD omits a particular action named, all NNSA has to do is to to issue an amended ROD (AROD) including that particular project. NNSA will then deem, as it has many times before, that no new analysis or consideration of alternatives is necessary.

To create this freedom of government action without any need for project-specific analysis of alternatives (the whole point of NEPA), all NNSA has to do is to get through these hearings and write a final SWEIS. They do not have to agree with any comments or engage with commenters in good faith. They just have to "consider" testimony and comments by putting them in a "comment response document" to protect themselves (more or less) from future litigation and amend the text of the SWEIS as needed to explain why they rejected this or that comment -- or perhaps accepted it in whole or in part, making some trivial correction.

Think of the drafting of this SWEIS as NNSA and LANL making a big list of projects and programs: current, planned, possible, and also certain "stalking horses" (like the proposed plutonium disposition facility, which could be anything big that handles tons of plutonium, creating a "plutonium-shaped" placeholder in NNSA's big NEPA tent). There are also "sweeteners" in their alternatives (e.g. the solar field with batteries -- not however sufficient to avoid the new power line through the Caja del Rio -- killing feral cattle, better fire mitigation).

To decipher this SWEIS and understand it holistically, reassemble the original list from the three seemingly-separate baskets. All three baskets are in the same delivery truck, heading our way. Everything comes with a NEPA "impact-back guarantee," allowing NNSA to exchange one or more projects and programs for others of equal or lesser impact if the first ones don't fit future "needs."

The most important thing about this SWEIS is that it comes long after, rather than before, the Sept. 2, 2020 decision to add a pit factory to LANL. The present NEPA process is being staged to create a veneer of legitimacy for decisions taken prior to environmental analysis in direct violation of NEPA, and also to avoid proper NEPA analysis in the future. A completed SWEIS is a NEPA "get out of jail free" ticket.

Enough for now; further discussion is coming in "Part II" next week. See you at the hearings!

Best wishes,

Greg