ML20269A415
| ML20269A415 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/23/2020 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 85FR16150 | |
| Download: ML20269A415 (5) | |
Text
From: Harvie, Shani, EDD <Shani.Harvie@state.nm.us>
Sent: Wednesday, September 23, 2020 11:20 AM To: Holtec-CISFEIS Resource
Subject:
[External_Sender] Letter of Support - HOLTEC Application for Consolidated Spent Nuclear Fuel and High Level Waste Storage Facility in SE New Mexico Attachments: EDD Holtec Letter- Final.pdf
- Hello, Please find that attached letter of support.
Respectfully submitted on behalf of the New Mexico Economic Development Department.
Thank you, Shani Harvie Executive Assistant to Secretary Alicia J. Keyes O: 505.827.0330 C: 505.699.2809
Federal Register Notice: 85FR16150 Comment Number: 4647 Mail Envelope Properties (aad8c262bf3a4e5c9c51ee4888170dc9)
Subject:
[External_Sender] Letter of Support - HOLTEC Application for Consolidated Spent Nuclear Fuel and High Level Waste Storage Facility in SE New Mexico Sent Date: 9/23/2020 11:19:42 AM Received Date: 9/23/2020 11:20:21 AM From: Harvie, Shani, EDD Created By: Shani.Harvie@state.nm.us Recipients:
Post Office: MBXCAS006.nmes.lcl Files Size Date & Time MESSAGE 302 9/23/2020 11:20:21 AM image003.png 31483 EDD Holtec Letter- Final.pdf 201924 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
Michelle Lujan Grisham
- Governor Alicia J. Keyes
- Cabinet Secretary John Tappert, Director Sept. 22, 2020 Division of Rulemaking, Environmental and Financial Support U.S. Nuclear Regulatory Commission Mail Stop T4-B72 11545 Rockville Pike Rockville, MD 20852 Submitted by email to: Holtec-CISFEIS@nrc.gov
Reference:
Docket ID NRC-2018-0052 Director Tappert, The New Mexico Economic Development Department (NM EDD) is a cabinet-level agency responsible for improving the lives of New Mexico families by increasing economic opportunities and providing a place for businesses to thrive. Holtec Internationals (Holtecs) license application to construct and operate a consolidated interim storage facility (CISF) for spent nuclear fuel (SNF) in Lea County, New Mexico not only jeopardizes our environment but our economy as well. For the reasons mentioned below, the NM EDD has concluded that the risks of this license far outweigh any possible economic benefits to the state. The proposed alternative will cause irreparable harm and set efforts to grow jobs and diversify our economy back years. The NM EDD strongly supports the No Action alternative.
Licensing a consolidated interim storage facility in Lea County, New Mexico brings unnecessary environmental risk to the states economy, which the NRC neglected to recognize in the economic analysis of the draft Environmental Impact Statement (EIS).
New Mexico is home to a growing renewable energy industry and a well-established oil and natural gas industry. Approximately one-third of the states operating budget is derived from these industries. In Lea, Chaves and Eddy counties, these industries directly account for 35 percent of all sales-tax spending and almost half of the indirect economic activity in the region due to construction and transportation employment tied to the energy sector.
Additionally, southern New Mexico has a tradition of family farms resulting in New Mexico being the number one pecan producer in the United States, ahead of both Georgia and Texas.
Further, chile remains an important specialty crop in New Mexico, and many ranchers raise beef and dairy cattle in this region. Lea and Eddy counties, specifically, contain over 3 million acres of farm and ranch land, which contribute nearly 300 million dollars to the local economy each year.
In order to diversify the economic base of the state and these counties, Governor Michelle Lujan Grisham has identified nine key target industry sectors that can flourish in New Mexico. These are areas where the state has a workforce and some natural advantage, such as climate, natural beauty or the federal research laboratories. Those sectors are Outdoor Recreation, Film and Television, Advanced Manufacturing, Sustainable Agriculture, Biosciences, Cybersecurity, Global Trade, Sustainable Energy, and Aerospace. For example, film and television in particular is taking hold in southern New Mexico, especially since the state has offered additional tax incentives to productions that film outside of Albuquerque and Santa Fe.
The state also offered economic assistance grants for manufacturing, agricultural, aerospace, outdoor recreation, and sustainable energy businesses in southern New Mexico. Some of the job growth realized last year was specifically tied to these initiatives.
When companies chose to relocate or expand in the state they looked at the quality of life and the business climate, as well as our rich natural resources - one of the necessities to recruit workers. They relied on certainty and consistent policies from all branches of government. But according to the International Economic Development Council, Companies, like people, do not want to take on the risks associated with living in proximity of a nuclear waste storage dump, and sharing their roads with transport containers. In short, the proposed alternative will undermine business confidence, jeopardizing future efforts to both recruit new businesses and help current ones expand.
In conclusion, the economic assumptions and conclusions reached in the draft EIS fail to recognize the impact of Holtecs proposal on our existing state economy. Further, the NRC made forward looking statements about Holtecs impact on the states economy which fail to account for any of New Mexicos economic efforts. The NRC failed to quantify the impact of granting a license to NM EDDs efforts to diversify our economy by attracting new investments which never included the liability of a CISF. Further, the NRC failed to present any economic analysis related to realized risk scenarios - actual or perceived environmental impacts - to the states economy.
For these reasons, NM EDD strongly supports the No Action alternative.
Sincerelly, Sincerely, Ali i J. Keyes Alicia Cabinet Secretary New Mexico Department of Economic Development