ML24318B710
| ML24318B710 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/07/2024 |
| From: | Curran D Beyond Nuclear, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, Sierra Club |
| To: | NRC/OGC, US Federal Judiciary, Court of Appeals, for the District of Columbia Circuit |
| References | |
| 24-1318, 2084087 | |
| Download: ML24318B710 (1) | |
Text
UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT
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BEYOND NUCLEAR, INC. and
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the SIERRA CLUB, INC.
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Petitioners,
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Case No. 24-1318
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- v.
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UNITED STATES NUCLEAR
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REGULATORY COMMISSION and the
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UNTIED STATES OF AMERICA,
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Respondents.
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PETITIONERS RESPONSE TO MOTION TO INTERVENE BY FLORIDA POWER & LIGHT CO. AND NEXTERA ENERGY POINT BEACH, LLC Pursuant to Fed. R. App. P. 27(a)(3) and D.C. Cir. Rule 27, Petitioners Beyond Nuclear, Inc. and the Sierra Club, Inc. respond to Joint Motion for Leave to Intervene by Florida Power & Light Company and NextEra Energy Point Beach, LLC in Support of Respondents (Nov. 6, 2024) (Joint Motion). Petitioners respectfully submit that the Joint Motion is duplicative of a motion to intervene submitted two days earlier by the Nuclear Energy Institute (NEI), the nuclear industry trade association. Unopposed Motion of Nuclear Energy Institute for Leave to Intervene in Support of Respondents (Nov. 4, 2024). The NEI Motion claimed that NEI represents all U.S. commercial nuclear power operators, USCA Case #24-1318 Document #2084087 Filed: 11/07/2024 Page 1 of 3
2 presumably including the sponsors of the Joint Motion. Id. at 5. In addition, NEI stated that many of its members are currently navigating the license renewal application process. Id. at 6. NEI also stated that its purposes in seeking to intervene included ensur[ing] that industrys direct and substantial interests are fully represented. Id. at 8. Petitioners did not oppose NEIs motion to intervene.
Florida Power & Light Company and NextEra Energy Point Beach, LLC state that they seek to protect their interests as license renewal applicants, but they have not demonstrated how their interests differ from those of other NEI members or would not be adequately represented by NEI. Therefore, Petitioners oppose their independent admission as intervenors. If the Court does admit them as intervenors, Petitioners request that they be required to share a single brief with NEI.
Respectfully submitted,
/s/ Diane Curran Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 Email: dcurran@harmoncurran.com November 7, 2024 USCA Case #24-1318 Document #2084087 Filed: 11/07/2024 Page 2 of 3
CERTIFICATE OF COMPLIANCE Pursuant to Federal Rule of Appellate Procedure Rule 32(g), I certify that the attached Petitioners Response to Motion To Intervene by Florida Power & Light Co. and NextEra Energy Point Beach, LLC is proportionately spaced, has a typeface of Times New Roman, 14 points, and contains 246 words. This calculation includes the body of the document but excludes the caption, signature line, and date. I have relied on Microsoft Words calculation feature for this calculation.
___/signed electronically by/__
Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 Email: dcurran@harmoncurran.com November 7, 2024 USCA Case #24-1318 Document #2084087 Filed: 11/07/2024 Page 3 of 3