[NukeNet] TVC's 4-page Bombplex insert/for your use

[Marylia Kelley]

Dear colleagues: We will post this in PDF on our website soon. In the mean
time, here is a pasted version (below).

Please:
1. If you are a group that is not producing your own bombplex analysis - do
feel free to use all or part of this. If convenient, and you use alot of
the text, do credit TVC, If that's not convenient, just go ahead and use
it! No worries!
2. Also feel free to give me feedback regarding what you think about these
points.
3. You may also use this to prepare comments for the public comment period.

Read on... --Marylia Kelley

A Tri-Valley CAREs Community GuideŠ  January 2008

HOW TO STOP A BOMBPLEX

Raise Your Voice to Oppose "Revitalizing" the Nuclear Weapons Complex

Coming Soon, Your Chance to Stop Bombs and Pollution
Public Hearings in Tracy & Livermore March 18 and 19, 2008

Just before Christmas 2007, the Department of Energy (DOE) National Nuclear
Security Administration (NNSA) held a press conference to announce the
latest in a series of deadly, irresponsible schemes to "revitalize" and
rebuild the U.S. nuclear weapons research, development, testing and
production complex of the future.

The DOE calls the plan "Complex Transformation" (it was formerly known as
"Complex 2030"). Tri-Valley CAREs and other groups continue to call it
"Bombplex," a more true and accurate title. The proposed plan is described
in a multi-volume draft Supplemental Programmatic Environmental Impact
Statement (PEIS), which has just been released. It is available on line at
http://www.complextransformation.com/project.html.

"Complex Transformation" involves 8 DOE locations across the country,
including Livermore Lab. The plan, if implemented, will result in new
capabilities and new infrastructure (meaning new facilities) to make new
nuclear weapons.

Why our future is at stake,
and we must act

The most important thing to know about "Complex Transformation" is that
fundamental decisions about our nation's nuclear weapons policies are at
stake here: Will U.S. behavior continue to scream out "nuclear weapons
forever," resulting in a further escalation of global proliferation and
danger? Or, will we (finally) turn toward full adherence to the nuclear
Non-Proliferation Treaty (NPT) and the greater safety of a nuclear weapons
free world?

The DOE's "Complex Transformation" is about continuing, entrenching and
enshrining for decades to come the Bush Administration's aggressive nuclear
posture. "Complex Transformation" does this by creating a
"capability-based" infrastructure to carry out the R & D, maintenance and
production of new and "modified," as well as existing, nuclear weapons. The
language of "Complex Transformation" is lifted verbatim out of Bush's
Nuclear Posture Review.

To accomplish the "mission" of building the infrastructure at sites across
the country, the DOE has laid out various options in the draft PEIS. Many
of them involve questions of where to put facilities; not whether to build
them. In this community guide, we will detail the main points in DOE's
favored option. But, we want to emphasize up front that DOE's "options" in
no way encompass a true range of reasonable possibilities. Instead, they
amount to showcasing differing quantities and layouts for arranging deck
chairs on the Titanic while locking the rudder in place and steaming more
quickly ahead.

Should we be arguing about where this or that chair goes, or should we be
discussing where the ship is headed? Instead of changing course, the
"Complex Transformation" plan locks in nuclear weapons as permanent U.S.
tools of fear, oppression and empire.

If you can tell the DOE that "Complex Transformation" takes us all in the
"wrong direction," you already have a profound comment ready for the
upcoming public hearings (see page 4 for the hearing schedule).

Please know that your voice, when used to speak truth to power, is
significant and makes a difference. When the DOE held public hearings in
2006 on the scope of  "Complex 2030," more than 33,000 people spoke or
submitted written comments against it.

We believe that this public outcry is the number one reason why DOE was
stymied and forced to regroup - and has suddenly changed the title of the
plan. DOE is hoping the switcheroo to "Complex Transformation" will baffle
you. We trust that you are figuring it out - and that you will continue to
oppose the "Bombplex" by whatever new name the DOE chooses to assign it.

Now, in 2008, we have a fresh opportunity to use our voices (and pens) to
prevent the Bombplex from ever becoming a reality. According to our
nation's most fundamental environmental law, the National Environmental
Policy Act, DOE must solicit public comment - and answer to it. As Mahatma
Gandhi and others have told us, the change we seek in the world begins with
each of us. Is there anything more important and crucial to our common
survival than stopping nuclear weapons?

The DOE's story:
big rhetoric, small adjustments

The DOE claims that the "Complex Transformation" plan is their "vision for
a smaller, safer, more secure and less expensive nuclear weapons complex
that leverages the scientific and technical capabilities of [its] workforce
and meets national security requirements."

First there is the obvious: We don't accept a somewhat smaller nuclear
weapons complex refurbished with new capabilities and new facilities in
order to more efficiently develop and produce nuclear bombs (as in more
nukes per square foot). Moreover, the most safe, secure and least expensive
nuclear weapons are the ones we don't build at all.

Second, in laying out its "Complex Transformation" plan, the DOE takes
credit for proposing to demolish old buildings that, at least in some
cases, are already in the queue to be torn down and decontaminated. That's
not really progress.

Third, the removal of some nuclear materials from facilities that are most
vulnerable to terrorist attack may be laudable, but can and should occur
solely for safety and security reasons. For example, by artificially tying
the consolidation of nuclear materials to "Complex Transformation," the DOE
is attempting to ensure that Livermore Lab's plutonium continues to be used
in service of nuclear weapons research.

Tri-Valley CAREs has long noted that the plutonium at Livermore Lab is
uniquely vulnerable to a catastrophic release in either a terrorist attack
or a major earthquake, with 7 million people crowded into a 50-mile radius
around the Lab.

However, it has also long been our position that this plutonium should
never be used in nuclear weapons experiments. We will be advocating this
(again) at the upcoming hearings.

Let us list for you the major features (the good, the bad and the really
ugly) that would be part of the nuclear weapons complex of the future under
DOE's "preferred alternative" in "Complex Transformation." The DOE would:

_	Close or transfer about 600 mostly old buildings or structures,
many by 2010.

_	Reduce the square footage of buildings and structures supporting
weapons missions, going from about 35 million square feet today to about 26
million square feet.

_	Consolidate plutonium and highly enriched uranium at five sites by
the end of 2012 - Los Alamos Lab in NM, the Nevada Test Site, the Pantex
Plant in TX, the Savannah River Site in SC, and Y-12 in TN - with reduced
square footage within those sites by 2017.

_	Build a larger plutonium complex at Los Alamos Lab, with a new
Chemistry and Metallurgy Research buildings Replacement project, or CMRR,
(notice how often DOE calls new facilities and weapons "replacements"; who
do they think they're fooling?) - with the capability of producing up to 80
new plutonium bomb cores per year.

_	Build a new uranium processing facility for weapons at Y-12.

_	Cease DOE NNSA operations at the Tonopah Test Range in Nevada, and
move operations to another location.

_	Eventually end bomb blasts at Livermore Lab's Site 300 high
explosives testing range after building new facilities elsewhere in the
complex. (Yet, possibly, still conducting bigger, open-air bomb blasts at
Site 300 "for hire" to the Dept. of Homeland Security and Dept. of Defense,
according to what Livermore Lab officials have told us.)

_	Employ 20-30% fewer workers directly supporting nuclear weapons
missions consistent with "Complex Transformation's" vision of a smaller,
more efficient complex.

_	Dismantle weapons at a faster pace. (This is the one part of the
proposal we support wholeheartedly. In fact, many more resources could be
put toward dismantlement if DOE foregoes the new bomb facilities it
proposes.)

The real story, part one:
DOE aims to prejudice
impending policy changes

_	In the "Complex Transformation" draft PEIS, DOE should not be
allowed to dismiss alternatives that it claims fall outside the current
scope of nuclear policy, which it defines as the 2001 Nuclear Posture
Review.  The NPR is not a law, it is merely a policy statement developed by
the Bush Administration. Changes in policy are possible and imminent with
end of the Bush era fast approaching.

_	DOE claims that it merely implements the national security policy
established by the President and Congress, rather than developing its own
policy. However, the "Complex Transformation" plan would lock the nuclear
weapons complex into a path that entrenches the current nuclear policy,
preempting a full and complete policy debate. "Complex Transformation," as
some in Congress have noted, seeks to put the "cart before the horse."

_	The U.S. should, instead, adopt a new nuclear policy geared toward
nonproliferation, disarmament, and the worldwide abolition of nuclear
weapons.

_	"Complex Transformation" seeks to rebuild the nuclear weapons
complex, essentially creating a new complex to meet the claimed needs of
the future, including the development of new nuclear weapons.  However,
there has been no national debate or Congressional input on the future U.S.
nuclear policy, and there is legislation pending in Congress (S. 1914) to
force such a debate and require the development of a Nuclear Policy Review
and a Nuclear Posture Review.  Moreover, the omnibus spending bill that
passed Congress in December mandates the beginning part of that process.
Until this work is complete, it is unreasonable and premature for DOE to
make such important and long-lasting decisions regarding the nuclear
weapons complex of the future. These decisions made now will prejudice
options for decades into the future.

_	Although the draft PEIS does include some rhetoric about making the
weapons complex responsive to an evolving national security policy, it is
only responsive within a narrow scope.  The "Complex Transformation" plan
does not seriously address substantial changes in nuclear policy such as a
"Curatorship" approach, which would maintain the safety and reliability of
the existing nuclear weapons stockpile without military enhancements until
such time as they are dismantled, or the even  more immediate active
disarmament option.

The real story, part two:
DOE fails to prioritize
safety and security

DOE clearly has a goal in mind for "Complex Transformation" -- the creation
of a new nuclear weapons complex. Unfortunately, DOE first set out what the
agency wanted to do, and then it attempted to address safety and security
within that framework. A more rational approach would have been to make
safety and security organizing principles for the future complex, and then
develop a plan that embodies them.

The real story, part three:
DOE ignores alternatives

Consideration of alternatives to the action the agency proposes is "the
heart" of any PEIS. It's the law, and it's not supposed to be an empty
exercise through which the agency (in this case DOE) merely justifies the
action it intends to take. This section of the draft PEIS should present
the environmental impacts of the proposal and the alternatives in
comparative form, thereby sharply defining the issues and providing a clear
basis for choice among the alternatives by decision-makers and the public.
The "Complex Transformation" draft PEIS fails utterly to do this.

For example, "Curatorship," which was first suggested by Tri-Valley CAREs,
was among the alternatives supposedly considered by DOE, but it was
eliminated from further study in the draft PEIS. This alternative is based
upon reliance on the surveillance and nonnuclear testing program to
determine when repairs might be called for. Only if there is compelling
evidence that components have degraded, or will soon degrade, and could
cause a significant loss of safety or reliability, would  DOE replace the
affected parts with new ones that would be remanufactured as closely to
their original designs as possible. In other words, no new nukes.

Yet, DOE claims that Curatorship was eliminated from detailed study
"because it does not define a programmatic alternative distinctly different
from the range of alternatives analyzed in [the draft] PEIS."

Apparently DOE mistakes its stockpile stewardship program to be the
functional equivalent of Curatorship, despite the fact that nuclear weapons
systems are not only being refurbished but modernized with new components
-- and new military capabilities -- under the stockpile stewardship
program. All such changes would be forbidden under "Curatorship."

We believe that DOE is deliberately misunderstanding the implications of
moving to a less aggressive Curatorship approach to the arsenal in order to
avoid analyzing it. For Curatorship would not require the new capabilities
and new facilities that DOE wants. Moreover, under a Curatorship program,
DOE could close down a large percentage of its existing nuclear weapons
infrastructure. We will also be challenging DOE on this issue at the public
hearings.

The real story, part four:
DOE sidesteps treaties

As with Curatorship, strict adherence to U.S. treaty obligations to disarm
is a viable alternative that must be examined in the draft PEIS.
Thirty-three thousand people demanded just such an alternative during the
public "scoping" process. The DOE mentions the comments, but sidesteps
their substance.

Under Article VI of the nuclear Non-Proliferation Treaty, the United States
is obligated "to pursue negotiations in good faith on effective measures
relating to cessation of the nuclear arms race at an early date and to
nuclear disarmament, and on a Treaty on general and complete disarmament
under strict and effective international control."  The "Complex
Transformation" plan -- and the Reliable Replacement Warhead effort to
build new nuclear weapons (which we expect to reemerge in the next budget
request) -- undermine the Treaty. If the U.S. is truly committed to the NPT
and the elimination of nuclear weapons, one wonders why the nuclear weapons
complex needs to be revitalized in such a dramatic fashion.

What is the public's role?

NEPA gives everyone the opportunity to express their opinions concerning
government actions that may affect the environment. Your voice is
important, and it needs to be heard. While the government has selected its
preferred alternative as part of "Complex Transformation," that decision is
not final and this is your opportunity to help shape the future of nuclear
policy and the weapons complex.

Specifically, there are a number of reasons to comment on NEPA documents:
(1) to influence federal agencies to minimize environmental impacts, (2) to
convince the  agency to deny the proposed action, (3) to improve the
documents by adding different perspectives or additional information, and
(4) to lay the groundwork for future litigation. (Simply stated, if people
don't bring up an issue during the hearings and comment period, then DOE
cannot be sued later for not considering it. So, do not hesitate to bring
up issues you think are important.)

Tips on how to comment

Your oral comments should be a summary of your major concerns, emphasizing
the most important points. It is a good idea to write down what you plan to
say. You should also submit your comments in written form. At the  hearing,
you may hear others' comments and want to incorporate them. An issue gains
additional political and legal force if it is submitted by many people.

1.	Introduce yourself: State your name and what special relationship
you bring (local resident, trained as a scientist, grew up here, have kids,
teach kids, care about the environment, etc.).
2.	Introduce your group: If you're affiliated with a group such as
Tri-Valley CAREs, state it.
3.	State the problem: In this case, talk about DOE, the Bombplex
("Complex Transformation"), nuclear weapons proliferation, economic waste,
environmental harm, plutonium, sick nuclear workers, etc.
4. State the solution: Discuss what you envision as a better outcome,
including alternatives to the proposed action such as a "green lab" in
Livermore, or "Curatorship" and no new nuclear weapons, or compliance with
the NPT, etc.

BOX:
PUBLIC HEARINGS

Tracy -  Tue, March 18th, 6 - 10 pm,  Holiday Inn Express,
3751 N. Tracy Blvd

Livermore -  Wed, March 19th,
11 am - 3 pm and 6 -10 pm,
Robert Livermore Community Center, 4444 East Avenue

BOX:
Coming in your next newsletter from Tri-Valley CAREs:

A special focus on Livermore Lab's role in the Bombplex, more on the new
nukes-Bombplex connection, plus additional "talking points" for the public
hearings.

Tri-Valley CAREs o 2582 Old First Street, Livermore, CA 94551 o
www.trivalleycares.org



Marylia Kelley,
Executive Director

Tri-Valley CAREs
2582 Old First Street
Livermore, CA  94551

Ph: (925) 443-7148
Fx: (925) 443-0177
Web: www.trivalleycares.org
Email: marylia at trivalleycares.org or marylia at earthlink.net