Thursday, October 28, 2010

Just checked the National Environmental Policy ACT

It uses "needs" only ONCE, in relation to "cultural needs".

I can forgive sociologists and anthropologists using "needs", but not economists, engineers, or "hard" scientists. "Purpose" on the other hand, appears NINE times.

The Council of Environmental Quality, the agency writing the implementing regulations for an Environmental Impact Statement [EIS], unfortunately does use the word "need" seven times, but mostly (all but twice) in conjunction with "purpose and need" .

So could we please talk about "purpose" rather than "need"?

And follow NEPA in defining purpose broadly enough, so that NOT ONLY nuclear weapons, or weapons in general, are options for addressing the broader purpose (security?) as the act MANDATES?

Sec. 1502.14 (c)  Include reasonable alternatives not within the jurisdiction of the lead agency.

This clause was inserted to avoid "feathering one's own nest only", precisely what appears to me the intent of DOE, NNSA, and LANL in trying to avoid doing an EIS by proposing an SEIS suffice.

After all

This section is the heart of the environmental impact statement. Based on the information and analysis presented in the sections on the Affected Environment (Sec. 1502.15) and the Environmental Consequences (Sec. 1502.16), it should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decisionmaker and the public.

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