NNSA, Please Repair Your Broken NEPA Process Or Don’t Bother With It

Executive Director
Los Alamos Study Group

As previewed in January (“Is DOE going to conduct a new SWEIS for LANL and if so what would it mean?,” Jan 7, 2022) and in August (“NNSA to conduct fake ‘environmental impact statement process to justify decisions, big future expansion, at Los Alamos,” Aug 18, 2022), the National Nuclear Security Administration (NNSA) has opened a “scoping” process for a Site-Wide Environmental Impact Statement (SWEIS) for Los Alamos National Laboratory (LANL).

Unless this process is fixed (see below), don’t bother taking part. It is a complete red herring. Your comments will mean nothing and accomplish nothing. If you care about nuclear weapons policy, or nuclear disarmament, or stopping the U.S. war against Russia and the looming U.S. war with China, or climate collapse, or any other important political objective, your time is better spent working on that.

This “scoping” process is designed to seduce you into thinking it is a legitimate process that will result in a more environmentally-friendly nuclear weapons laboratory, or a better and more complete environmental cleanup, or that the federal government is behaving in a responsible, legal manner. Above all it aims to solidify those beliefs at a group-emotional level.

It’s designed to legitimate nuclear weapons. The concept of an “environmental impact statement” for a new nuclear weapons factory, especially at this point in world history, is absurd. And as Voltaire said, “Those who can make you believe absurdities can make you commit atrocities.” Any use of nuclear weapons would be a war crime, so these devices aren’t really “weapons” at all, as even Harry Truman belatedly figured out. They put the “terror” in “deterrence.” The terror comes from “collateral damage,”  i.e. mass civilian death, which is known, accepted, and planned.

It would be far more worthwhile to solidify, deepen, and make public your antiwar and anti-nuclear weapons activism in any of a thousand ways, building solidarity there rather than in a vacuous process designed by a rogue nuclear weapons agency for its own purposes.

Don’t imagine that participation in this process will help lead towards a better environmental cleanup at LANL. It won’t. “Cleanup” is for “antinuclear” groups what “nonproliferation” is for arms control and academics — something for them to do that helps, rather than threatens, the nuclear weapons establishment by providing legitimacy and a distracting sense of agency to non-governmental actors far greater than actually exists. In both fields, various exogenous factors dominate. The views of citizens, or the contributions of academics, matter little.

The NNSA has offered two rather pathetic scoping meetings this week, in its minimalist show of compliance with the National Environmental Policy Act (NEPA). You can find out about them here.

In the face of such congealed error — moral, political, legal, economic, environmental — it is difficult for all of us to know how best to proceed. For legal reasons, and despite this being a fake process, we have made some initial comments, posted here: LASG initial scoping comments on the Site-Wide Environmental Impact Statement (SWEIS) for the Continued Operation of LANL, Sep 11, 2022. We did it so you don’t have to.

In brief, we request that NNSA:

  1. Halt implementation of decisions taken without adequate NEPA analysis;
  2. Provide documents necessary for us and others to submit informed public comment on the scope of the proposed LANL SWEIS;
  3. Identify the proposal and proposed action in a way that allows informed comments on impacts, alternatives, and mitigation measures;
  4. Extend the scoping period until NNSA clears its FOIA backlog regarding this vaguely defined pit production proposal, with adequate time to review these documents;
  5. Provide in-person scoping hearings in Los Alamos, Santa Fe, and Espanola with adequate time for questions, answers, and testimony; and
  6. Provide interactive scoping hearings that include:
    1. Detailed exhibits encompassing the full range of possible NNSA actions at LANL;
    2. Direct interaction between the interested public and responsible NNSA officials capable of answering questions about the proposed action and alternatives;
    3. Protocols to ensure all public comments are  on the record.