Responses to DOE’s Request for Information on Consent-Based Siting

The Department of Energy has a Request for Information out for the public to submit responses to a list of questions. I cover it in depth in a previous post, and I present my responses to their questions in this post.

I. Consent-Based Siting Process

1. How should the Department build considerations of social equity and environmental justice into a consent-based siting process?
   1. The Department should recognize, first and foremost, the opportunity cost present in the energy industry. The volume of spent nuclear fuel and it’s impact on the environment relative to other forms of waste from other energy generation technologies is miniscule. The risk of harming the public at a federal facility or existing nuclear facility is dwarfed when compared to the real harm and danger being imposed on the public now by other energy generation techniques. An estimated 13,000 people die in the United States every year because of air pollution caused by emissions from fossil burned energy sources. These deaths could be alleviated if we used a cleaner technology for generating electricity and transportation. Nuclear stands a realistic chance to replace those technologies and displace the continued harm caused by their waste streams. A large hurdle and black mark on the industry inhibiting development and increasing assumed risk is the lack of a permanent disposal facility for the waste products. It is intrinsically unfair to the nuclear industry to be forced to dispose of and manage their waste permanently when all other forms of generation are not held to an equivalently stringent standard, but the precedent exists nonetheless and is unlikely to dissipate. As such, in the interest of protecting the well being of the public and minimizing humanity’s impact on the environment, the Department should seriously consider expediting this process to complete it as quickly as possible. If not, then the environment will continue to be polluted by the technologies we’re currently exploiting and people will continue to die.
   2. Under the Department’s current plan, based on the 2017 Draft Report, the Process is planned to require 20 to 37 years to have an interim or permanent facility in place. This is unacceptably slow and wildly detrimental to the public’s health. The Department should have a plan to build and commission a facility in as few as two years.
2. What role should Tribal, State, and local governments and officials play in determining consent for a community to host a federal interim storage facility?
   1. Tribal, State, and local governments should exist as partners with the Federal government to generate buy-in, should be beneficiaries of the overall process, but shouldn’t be allowed to stonewall a decision which will help the entire world. They should be empowered to decide the fate of their home, but shouldn’t prohibit the decision of a neighboring community.
3. What benefits or opportunities could encourage local, State, and Tribal governments to consider engaging with the Department as it works to identify federal interim storage sites?
   1. Money is always a motivator. Create jobs, guarantee long term opportunities (i.e. don’t waffle on the decision making and not build the facility), and ensure price stability. Additionally, present the option for growth. Plant the seed in the minds of the community that they could be the host for all of the spent nuclear fuel from around the country and around the world.
4. What are barriers or impediments to successful siting of federal interim storage facilities using a consent-based process and how could they be addressed?
   1. Three primary barriers exist: the time it takes to implement and deploy, the potential for lack of public support, and a resulting imbalance in power between communities who want to be hosts and larger communities.
   2. The Department’s current plan estimates 20 to 37 years to build a facility. This is radically unacceptable. Large projects take time, but if a project stands to span several decades, then it’s unlikely to be accepted by the host community. An entire generation may come and go, political regimes will change, and it will be impossible to attract private capital, investment, or buy-in from local communities. This must be shortened.
   3. The repeated myth around nuclear energy – and the spent nuclear fuel in particular – is it’s widely unpopular among the public. In my circles, I find this to simply not be true. Many people are ignorant about most attributes of the nuclear industry, but the public at large – and millennials in particular – is not afraid of it. They’re just ignorant and don’t understand it. A large marketing and educational campaign about spent nuclear fuel would be helpful in expediting public acceptance of the issue and the subsequent approval of a facility.
   4. A common challenge in American politics and our government system is the mismatch in geography and political alignment among certain communities. Three examples come to mind. Yucca Mountain was a popular project among the host community who was excited about the jobs and opportunities it would bring, but it was extremely unpopular among the people in urban centers in the state of Nevada. It became so unpopular that the federal government could never commission it. The same thing is happening now in New Mexico where the people in urban centers (Santa Fe, Albequerque, etc.) are voting to ban the establishment and operation of a nuclear waste facility. I spend a significant amount of time in the oilfields in southeast New Mexico, and I can say with confidence that a nuclear waste facility would be welcomed and largely unnoticed by the local population. The exact same scenario occurs in Colorado. I grew up on the western slope of Colorado, and the politics and public acceptance of which kind of operations occur are polar opposites. People working and living in the rural communities often feel tyrannized and controlled by the agendas, beliefs, and desires of the larger populations in urban centers. It’s feasible to imagine a spent fuel waste facility being accepted in rural Colorado, but the state banning the construction of it because of the agenda and ignorance of the larger population in Denver. The Department should consider seriously how to circumvent this potential outcome and make it possible for small, rural communities to participate in the process without the buy-in from their parent states.
5. How should the Department work with local communities to establish reasonable expectations and plans concerning the duration of storage at federal interim storage facilities?
   1. Disseminate the information in a format that’s consumable and easy for the public to accept. Utilize the media platforms which people consume content through. In addition to the traditional methods of communication (i.e. host webinars for Q&A sessions, townhall meetings, and post content on websites), consider starting an Instagram or TikTok page, an educational YouTube channel, and recording Q&A podcasts for communities to consume on their own time.
6. What organizations or communities should the Department consider partnering with to develop a consent-based approach to siting?
   1. Energy Impact Center
   2. Center for Industrial Progress
   3. Switch Energy Alliance
   4. Environmental Progress
   5. Generation Atomic
   6. Organizations & landfills who accept toxic waste
   7. Technical experts on nuclear waste
7. What other issues, including those raised in the Draft Consent-Based Siting Process, should the Department consider in implementing a consent-based siting process?
   1. Consider approaching communities in western Colorado first.
   2. Consider sequestering the waste similar/identically to how the oil and gas industry sequesters sand during the hydraulic fracturing process.

II. Removing Barriers to Meaningful Participation

1. What barriers might prevent meaningful participation in a consent-based siting process and how could those barriers be mitigated or removed?
   1. The spread of misinformation around spent nuclear fuel has been rampant and generated a fundamental misunderstanding among the public about it’s relative danger compared to almost anything else the public is likely to encounter in their lives. Because of this reality, an educational campaign in a format that’s consumable by communities e.g. through social media is likely the best method for educating populations. Doing so accomplishes several things:
      1. Educates: such a campaign will inform the public on the process and potential of a consent-based siting process.
      2. Respectful of time: with access to all of the information all around the world, humans are extremely strapped on time. Education through a social media campaign meets them on their terms and minimizes the amount of time spent on informing them of the process.
      3. Broad Audience: A social media campaign also stands a better chance at reaching a broader audience than pamphlet distribution, mailings, town halls, or other forms of information dissemination.
2. What resources might be needed to ensure potentially interested communities have adequate opportunities for information sharing, expert assistance, and meaningful participation in the consent-based siting process?
   1. There is sufficient information on the internet for most intelligent humans to educate themselves about this topic; however, it’s likely not packaged succinctly or sufficiently enough. I recommend the following:
      1. Five minute informational video on YouTube explaining the process, the reason for it, and how people can get involved.
      2. A 30 – 45 minute Q&A podcast with a leader on the process. This could likely be similar or identical to the webinar released by the Department in the Request for Information.
      3. A list of organizations and experts (see list in 1.6) who are willing to help interested communities understand the science.
3. How could the Department maximize opportunities for mutual learning and collaboration with potentially interested communities?
   1. Host regular panel discussions with experts and invite communities to participate and ask questions.
   2. Record the sessions and release them as podcasts and YouTube videos.
4. How might the Department more effectively engage with local, State, and Tribal governments on consent-based siting of federal interim storage facilities?
   1. Engage with leaders from local communities who are willing and able to setup meetings with leaders in the local, State, and Tribal governments. Reach out to the Govorners of each state directly. Identify the largest donors from each Governor’s campaign and reach out directly to them and ask for an introduction.
   2. Once you’re in the room with the key decision makers i.e. Governors and elected officials of each state, clearly and concisely communicate the idea around consent-based siting with them. Communicate the benefits, the reason it’s necessary, and the opportunity available for them and their state. Offer it up as a win for them to participate in the fight against Climate Change while simultaneously providing jobs for their constituents.
5. What information do communities, governments, or other stakeholders need to engage with the Department on consent-based siting of federal interim storage facilities?
   1. Stakeholders need to understand first and foremost the relative risk of a consent-based siting facility and how non-existent it is compared to most other industrial processes. They need to know spent nuclear fuel from a commercial facility has never and is unlikely to ever hurt anyone. Without this clearly being explained, they’re likely to push back.
   2. They also need to know anticipated specifics about the proposed facility. How big is it going to be? How many buildings? How long with the fuel be there?

III. Interim Storage as Part of a Waste Management System

1. How can the Department ensure considerations of social equity and environmental justice are addressed in developing the nation’s waste management system?
   1. Environmental justice will be served if millions of tons of carbon dioxide aren’t emitted into the atmosphere, millions of solar panels disposed of as trash in poor countries, and millions of holes in the ground aren’t drilled. Social equity will be realized if climate change is slowed to allow poor countries time to adapt, low-cost and reliable electricity is deployed all over the world, and slaves aren’t forced to build solar panels in China. All of these things can be accomplished if we deploy nuclear power at a global scale. In order to do that, we must develop a waste management system. As such, I believe this question is worded poorly. It’s not, how the department can ensure considerations are addressed in developing a system; rather, it’s develop a system in order to ensure social equity and environmental justice are addressed.
   2. The Department can ensure considerations of social equity and environmental justice are addressed in developing the nation’s waste management system by:
      1. Understand before being understood: the public will communicate its questions and concerns. Listen to them. It won’t be necessary to act on or solve all of them, but the effort of engaging with the public will be welcomed.
      2. Build an educational campaign to answer the unknowns: after consuming the questions from the public, deploy an educational campaign providing answers to their questions and concerns.
      3. Engage with technical experts who are best suited to advise and build the waste management system: The United States of America is full of incredibly intelligent humans who have built unfathomably complex and mind-bogglingly impressive systems over the past 100 years. I’m 100% confident we will continue to build, develop, and deploy systems which are admired around the world. The Department should engage with these people to ensure the waste management system is flexible enough to allow for innovation and excellent engineering practices, and social equity and environmental justice will be natural byproducts.
2. What are possible benefits or drawbacks to co-locating multiple facilities within the waste management system or co-locating waste management facilities with manufacturing facilities, research and development infrastructure, or clean energy technologies?
   1. Co-locating multiple facilities within the waste management system.
      1. Benefits: sharing of resources (staff, knowledge, parts, etc.), exploits economies of scale, supply chain advantages, fewer communities to work with, simplifies process
      2. Drawbacks: doesn’t normalize the waste issue and make it acceptable across larger populations or multiple communities, likely increases transportation costs from power plants to storage facilities, and increases space required at a single facility (unless doing subsurface sequestration)
   2. Co-locating waste management facilities with manufacturing facilities, research and development infrastructure, or clean energy technologies?
      1. Benefits: access to industrial infrastructure, access to labor and workforce, partnering with staff and local organizations, improved communication between organizations and community, normalization of waste and the waste process in public perception (“they put it right next to the University – it can’t be that dangerous!”), and reinforcing the fact in the minds of everyone that this kind of facility is necessary to save the world with the cleanest and safest energy technology in existence.
      2. Drawbacks: few. No, actually – none. Seriously. There’s virtually no downside. Prove me wrong.
3. To what extent should development of an interim storage facility relate to progress on establishing a permanent repository?
   1. It should not be a distraction. We need a permanent facility. The world is going to need more nuclear power over the coming millennia – not less. Don’t let this process get in the way.
4. What other issues should the Department consider in developing a waste management system?
   1. We should build one now.
   2. Faster, faster, faster.
   3. Git-r-dun!!!
   4. Why? Because people are dying from air pollution. Those deaths are (indirectly) on the nuclear industry’s hands and the Department’s hands. Every single day that goes by, more people die. Let’s solve this problem as quickly as possible to help save them.