ML20023C369
| ML20023C369 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 05/12/1983 |
| From: | Cavanagh R COLUMBIA RIVER INTER-TRIBAL FISH COMMISSION, NATIONAL WILDLIFE FEDERATION, National Resources Defense Council, NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION, OREGON ENVIRONMENTAL COUNCIL |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8305170272 | |
| Download: ML20023C369 (2) | |
Text
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,i UNITED STATES OF AMERICA f gn i A NUCLEAR REGULATORY COMMISSION,.'
S BEFORE THE ATOMIC SAFETY AND LICEN G
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May 12, 1983 (Skagit/Hanford Nuclear Project
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INTERVENORS ' MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 1 By Memorandum and Order dated November 2, 1982, the Licensing Board accepted Contention 1.
Contention 1, as restated by the Board's Memorandum and Order of January 18, 1983, provides:
The Applicants have relied upon an inflated calculation of demand for electrical energy; reliable regional energy forecasts demonstrate no need for the Skagit/HNP.
The bases for this contention are reviewed at length in two attachments to this Motion: the Affidavit of David B.
Goldstein and the Memorandum of Points and Authorities.
The Northwest Power Planning Councils final Northwest Conservation and Electric Power Plan demonstrates no need for the Skagit/Hanford Nuclear Project; the same conclusion has been reached in forecasts and related analyses prepared under the direction of the Washington State Legislature, the Bonneville Power Administration, and the Natural Resources Defense Council.
The discovery process has elicited no o,ther regional forecasts prepared independently of 8305170272 830512 3
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of Applicants and the Pacific Northwest Utilities Conference Committee (to which Applicants belong).
Consequently, Contention 1 does not present an issue in controversy, and the Intervenors hereby move for summary disposition of that contention.
Respectfully submitted, W
U Ralph Cavanagh Counsel for the Natural Resources Defense Council, Inc., Lead Party for Intervenors on Contention 1 25 Kearny S tree t San Francisco CA 94108 Telephone: (415) 421-6561 Submitted on behalf of NRDC and the following Intervenors:
Nina Bell Coalition for Safe Power Suite 527, Governor Building 408 S.W. Second Avenue Portland OR 97204 Robert C. Lothrop, Esq.
Colunbia River Inter-Tribal Fish Commission Suite 320.
8383 N.E. Sandy Boulevard Portland OR 97220 Terence L. Thatcher, Esq.
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National Wildlife Federation and Oregon Environmental Council 708 Dekum Building 519 S.W. Third Avenue Portland OR 97204 James B. Hovis, Esq.
Yakima Indian Nation P.O.
Box 487 Yakima WA 98907
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