Friday, May 27, 2011

Comments on LANL Draft Community Relations Plan

The Draft LANL Community Relations Plan of May, 2011 (LA-UR-11-10608), the "Plan", was mandated by Sect. 1.12 of the LANL Hazardous waste Facility Permit, issued by NMED for the state of New Mexico on December 28, 2010 (RCRA Renewal Permit, the "Permit")

The Permit mandates that LANL create a Plan which will:

 1) Establish an open working relationship with the public
 2) Establish a productive government to government relationship with the tribes
 3) Keep the public informed about Permit actions of interest
 4) Minimize disputes and resolve differences with the public
 5) Provide a mechanism for dissemination of information to the public
 6) Provide a mechanism for public input to the Permittees

The Plan asserts compliance with Permit mandates because:

 1) LANL hazardous activities have become more transparent and responsive to the public
   a) As measured by the annual survey of attitudes of local community leaders toward LANL, and the evolution  toward more positive attitudes over the last several years
   b) Mechanisms facilitating exchange of information and opinions with the public have been set up; e.g.,  an email address at; information repositories, electronic at and printed  media at LANL's Oppenheimer Center; a schedule of formal meetings and briefings; tours of LANL facilities; the NNMCAB.
 2) Government to government relations with the tribes are being promoted
 3) Professional facilitators are being employed to conduct public meetings

However, I believe that the Plan is inadequate for the following reasons:

It seems that all of the cited Plan elements have been ongoing for many years. Thus, the Plan is a collection of previously existing programs; no programs were created specifically to comply with the mandates of the Permit. As to the individual Plan elements:

 1a) The annual surveys of the attitudes of local community leaders toward LANL is insufficient to convincingly demonstrate approval, or disapproval, by the local community of LANL behavior. A better means of determining the opinions of local community members would be to survey these opinions directly. Moreover, the annual survey of local community leaders has been ongoing for several years and could hardly be counted as a part of a new plan to improve relations with the general public.

 1b) All of the mechanisms and entities mentioned here by LANL have been in existence for many years and cannot be considered a part of a new community relations plan.

 2) Government to government relations with the tribes have long been promoted by the DOE and are also nothing new.

 3) It has long been DOE policy to employ professional facilitators to keep order at public meetings. Therefore, this element is also not new.

Furthermore, the enumerated Plan elements do not even include all of the existing LANL community relations programs. For example:

 A.) The Plan makes no mention of the RACER electronic database. RACER is an online record of measurements made by LANL and NMED of the concentrations of a large number of contaminants of groundwater and soil all around the Pajarito Plateau over a period of many decades. RACER was created with DOE money, and the accumulation of its important environmental data is an ongoing process.

 B.) The Plan makes no mention of the New Mexico Community Foundation and its commitment to providing a regular forum for the exchange of information and opinions between LANL personnel and members of the general public. The NMCF has recently been funded by the DOE to accomplish this important task and it's hard to understand why LANL's Plan does not claim part ownership of this group. After all, LANL includes the NNMCAB in its Plan. Yet the NNMCAB is wholly a DOE creation.

 C.) The Plan makes no mention of the NEWNET air quality data available, online and in real time, to the general public.

 D.) The Plan makes no mention of the Bradbury Museum, an important part of LANL ongoing community relations. Perhaps this is because the Bradbury invites contributions from the general public, for which it provides exhibit space. Some of these contributions are very critical of LANL operations, past and present.

 E.) The Plan makes no mention of the many other materials available through the existing LANL Community Programs Office.

Worse, the Plan's authors have made no attempt to accommodate the demands of local citizens, presented during the public RCRA Hazardous Waste Permit hearings:

 A.) There is no mention of the extensive information on environmental contamination compiled by the LAHDRA project, which was funded by the DOE, and is available online in the LAHDRA final report.

 B.) No attempt has been made to create a repository of historical records describing the involvement of DOE/LANL in the lives of local citizens and in the life of the surrounding communities. It was suggested that such a repository of historical records should be established at Northern New Mexico College.

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