From Nuclear Watch South

Dear Friends,

Nuclear Watch South invites all U.S. based organization and individuals
to sign the comments pasted below. Turn around time is tight!! The
Navy’s deadline to submit comments is Monday, July 24.

Send sign-ons to to Glenn Carroll atom.girl@nonukesyall.org by midnight
Sunday, July 23

Please include your name, title, organization, city, state or for
individuals your name, city and state.

We ask you to please circulate this sign-on opportunity widely! Nuclear
Watch South has traditionally focused on environmental concerns and is
not as well connected to the peace community as many of you!

The draft EA can be found here:
https://www.nepa(dot)navy(dot)mil/Current-Projects/Aircraft-Home-Basing-Ship-Homeporting/Columbia-Class/Documents/

You  may submit comments here:
https://www.nepa(dot)navy(dot)mil/Current-Projects/Aircraft-Home-Basing-Ship-Homeporting/Columbia-Class/Public-Commenting/

The Navy’s Environmental Assessment is narrow and concerned with
expanding Kings Bay Trident base to accommodate the new Columbia class
submarines, part of the nuclear weapons modernization program. Nuclear
Watch South has taken NEPA’s requirements to look at all impacts
seriously and is demanding a full EIS to include studying the impacts on
the North Atlantic right whales, whose Georgia birthing waters were only
first discovered as the Navy was displacing these creatures to the open
Atlantic Ocean by constructing Kings Bay. We bring the U.N. Treaty on
the Prohibition of Nuclear Weapons into the mix, and challenge the Navy
to contemplate that the environmental impact of nuclear weapons is,
ERRR, wholesale environmental destruction!

We invite U.S.-based organization and individuals to sign on to the
following comments on the draft EA:

July 24, 2023

Ms. Sara Goodwin
code: EV22.SG
6506 Hampton Blvd
Norfolk, VA 23508-1212

COMMENTS ON COLUMBIA CLASS HOMEPORTING EA | KINGS BAY TRIDENT SUBMARINE
BASE

Dear Ms. Goodwin,

Thank you for granting the request by Nuclear Watch South and others for
a deadline extension on the Columbia Class Homeporting Environmental
Assessment for Kings Bay Trident Submarine Base in the Cumberland Sound
near St. Marys, Georgia. The original deadline was June 25, 2023. We
requested a 90-day extension of which you granted 30 days for a July 24,
2023, deadline.

Nuclear Watch South (formerly Georgians Against Nuclear Energy) is
drafting these comments and inviting additional signatories. Nuclear
Watch South is a grassroots, direct action, environmental nonprofit
based in Georgia since 1977. The Kings Bay Trident nuclear submarine
base near St. Marys, Georgia, deploys enough nuclear firepower to
destroy all life on Earth. The environmental impact of Kings Bay is
planetary. Nuclear Watch South invites all U.S.-based organizations and
individuals to co-sign these comments.

BACKGROUND AND HISTORY OF KINGS BAY

Georgia’s 100 miles of Atlantic Ocean coastline is a globally unique,
fertile, and fragile marshland environment of barrier islands,
freshwater tidal forests, maritime forests, and endangered longleaf pine
forest. Georgia’s vast salt marshes support a staggering diversity of
plant and animal life nurturing the eggs and hatchlings of countless sea
creatures and providing significant nesting and migration habitat for
200 bird species.

Kings Bay, near the Georgia-Florida state line is home base for six
Trident submarines and deploys 25% of the U.S. nuclear arsenal. A
Trident submarine is the most expensive and deadly nuclear weapons
system on Earth. The only other nation to possess a similarly powerful
system is the United Kingdom, a longtime United States ally. The Trident
has been controversial since its inception as it upsets the so-called
MAD (Mutually Assured Destruction) power balance, fueling a dangerous
and costly international arms race.

The Navy conducted an Environmental Impact Statement (EIS) in 1977 when
Kings Bay Naval Submarine Base was first proposed. The EIS was performed
to fulfill environmental and public accountability requirements of the
newly instituted National Environmental Protection Act (NEPA) of 1969.
In 1979, construction began on Kings Bay. In 1984, it was first
discovered that the base had unwittingly intruded upon the (previously
unknown and apparently only) birthing waters for the critically
endangered North Atlantic right whales in the Cumberland Sound.

Kings Bay base began operations in 1989. The Soviet Union dissolved in
1991. At the same time, the U.S. nuclear weapons manufacturing complex
occupying vast reservations in more than a dozen states from Washington
to South Carolina was shuttering its reactors and facilities amidst
revelations of widespread nuclear contamination and vast inventories of
poorly managed radioactive wastes. The nuclear weapons complex suddenly
and belatedly became subject to environmental law and NEPA has since
proved to be a difficult filter through which to permit new nuclear
weapons manufacture. For example, the U.S. Department of Energy and
National Nuclear Security Agency have failed in five attempts over the
past 30 years to establish a plutonium pit production facility at the
Savannah River Site (SRS) on the South Carolina/Georgia state line
(Savannah River.

Nuclear weapons manufacturing has languished since 1990 in all
nuclear-armed nations and limited nuclear treaties have greatly reduced
nuclear stockpiles. All nuclear testing ceased in 1992. Trident
submarines now carry fewer nuclear weapons, but each Trident submarine
currently can deploy the explosive power of 1,825 Hiroshimas.

In 2021, the U.N. ratified the Treaty on the Prohibition of Nuclear
Weapons, presently counting 68 nations as parties. The treaty begins by
expressing the parties’ concern for “the catastrophic humanitarian
consequences that would result from any use of nuclear weapons, and
recognizing the consequent need to completely eliminate such weapons,
which remains the only way to guarantee that nuclear weapons are never
used again under any circumstances.” This landmark, game-changing Treaty
sets forth as international law that it is illegal to “develop, test,
produce, manufacture, otherwise acquire, possess or stockpile nuclear
weapons or other nuclear explosive devices.”

The North Atlantic right whale population rebounded from near extinction
when hunting the whales was outlawed in 1935. The whales encountered new
hazards, however, with the industrialization of shipping and fishing.
Ship strikes and entanglement in fishing gear are held responsible for
mortality events which are now decimating the whale population. The
current population of the critically endangered North Atlantic right
whale has crashed to fewer than 350 animals. National Oceanic and
Atmospheric Administration (NOAA) estimates 50 births per year are
required to avoid extinction of these ancient, magnificent marine
mammals. In 2022, only 15 North Atlantic right whales were born. _No
environmental study has ever been conducted of the impact of the North
Atlantic right whales’ protected birthing waters being occupied by the
massive Kings Bay naval station._

Despite the moribund state of nuclear weapons manufacture, in 2022, the
U.S. spent _$83,000 per minute_ on nuclear weapons. This budget includes
items like the redundant Columbia class submarine which this
environmental study narrowly contemplates. Earth’s inhabitants now face
extreme dislocation from climate change in addition to living under the
Damocles sword of nuclear annihilation for the previous three
generations. Clearly, resources now squandered on nuclear weapons can be
converted to the task of making the lifestyle changes required to retain
our planet’s life-supporting atmosphere.

NATIONAL ENVIRONMENTAL POLICY ACT
It is the pleasure and duty of the public to participate in important
decisions as framed and codified by the National Environmental Policy
Act of 1969. Nuclear Watch South lists here the pertinent portions of
the Act upon which these comments rely. The powerful words of the
opening paragraph declare, “The purposes of this chapter are: To declare
a national policy which will encourage productive and enjoyable harmony
between man and his environment; to promote efforts which will prevent
or eliminate damage to the environment and biosphere and stimulate the
health and welfare of man; to enrich the understanding of the ecological
systems and natural resources important to the Nation; and to establish
a Council on Environmental Quality. _(42 U.S.C. 4231) (Pub. L. 91–190,
§ 2, Jan. 1, 1970, 83 Stat. 852.) _

NEPA then says: “(a) The Congress, recognizing the profound impact of
man’s activity on the interrelations of all components of the natural
environment, particularly the profound influences of population growth,
high-density urbanization, industrial expansion, resource exploitation,
and new and expanding technological advances and recognizing further the
critical importance of restoring and maintaining environmental quality
to the overall welfare and development of man, declares that it is the
continuing policy of the Federal Government, in cooperation with state
and local governments, and other concerned public and private
organizations, to use all practicable means and measures, including
financial and technical assistance, in a manner calculated to foster and
promote the general welfare, to create and maintain conditions under
which man and nature can exist in productive harmony, and fulfill the
social, economic, and other requirements of present and future
generations of Americans. “

NEPA continues in its statement of standards: “(1) fulfill the
responsibilities of each generation as trustee of the environment for
succeeding generations; (2) assure for all Americans safe, healthful,
productive, and esthetically and culturally pleasing surroundings”
_(SUBCHAPTER I—POLICIES AND GOALS [TITLE I] 42 U.S.C. 4331.
Congressional declaration of national environmental policy [Sec. 101])_

NEPA requires analysis of: “(i) reasonably foreseeable environmental
effects of the proposed agency action; (ii) any reasonably foreseeable
adverse environmental effects which cannot be avoided should the
proposal be implemented; (iii) a reasonable range of alternatives to the
proposed agency action, including an analysis of any negative
environmental impacts of not implementing the proposed agency action in
the case of a no action alternative, that are technically and
economically feasible, and meet the purpose and need of the proposal;
(iv) the relationship between local short-term uses of man’s
environment and the maintenance and enhancement of long-term
productivity; and (v) any irreversible and irretrievable commitments of
Federal resources which would be involved in the proposed agency action
should it be implemented.” (42 U.S.C. 4332. Sec. 102 paragraph C)

Finally, at 42 U.S.C. 4336: “(b) Levels of review
(1) Environmental impact statement An agency shall issue an
environmental impact statement with respect to a proposed agency action
requiring an environmental document that has a reasonably foreseeable
significant effect on the quality of the human environment.
(2) Environmental assessment An agency shall prepare an environmental
assessment with respect to a proposed agency action that does not have a
reasonably foreseeable significant effect on the quality of the human
environment, or if the significance of such effect is unknown, unless
the agency finds that the proposed agency action is excluded pursuant to
one of the agency’s categorical exclusions, another agency’s
categorical exclusions consistent with section 4336c of this title, or
another provision of law. Such environmental assessment shall be a
concise public document prepared by a Federal agency to set forth the
basis of such agency’s finding of no significant impact or
determination that an environmental impact statement is necessary.”

COMMENTS

AN ENVIRONMENTAL ASSESSMENT IS INADEQUATE. AN ENVIRONMENTAL IMPACT
STATEMENT SHOULD BE PERFORMED.
An Environmental Impact Statement for Naval Base Kings Bay was last
published in 1977. Base construction began in 1979 and continued until
1989. The original EIS failed to contemplate the impact of the submarine
base on the critically endangered North Atlantic right whales. Indeed,
it was not known until 1984 that the Georgia barrier islands, in
particular the Cumberland Sound where Kings Bay is situated, is crucial
habitat to North Atlantic right whales. The presence of a dead North
Atlantic right whale calf on Little St. Simons Island in 1982 prompted a
study which determined in 1984 that the protected waters behind the
Georgia barrier islands, most notably Cumberland Sound, the site of
Kings Bay, are where pregnant North Atlantic right whales migrate each
November through April to give birth to and nurture their calves. In
1985, Georgia adopted the North Atlantic right whale as its Official
State Marine Mammal. The impact of Kings Bay on the North Atlantic right
whales must be analyzed in an EIS.

An Environmental Assessment is too narrow to contemplate the impacts on
the North Atlantic right whales, nor the impacts listed below. As stated
in NEPA, an EA is used when an agency intends to claim a finding of “no
significant impact” rendering an EIS unnecessary. As we shall show,
there are reasonably foreseeable environmental impacts from ongoing and
future planned activities at Kings Bay which meet the threshold for an
EIS.

Before 1984 it was unknown where the critically endangered North
Atlantic right whales gave birth to their calves. Nuclear Watch South
believes that the construction activities of the naval base forced the
whales into open waters during a most vulnerable part of their life
cycle which led to the death of the baby calf discovered in 1982 and
puts ongoing pressure upon the dwindling population of this critically
endangered, protected species. Kings Bay’s presence must be counted
among the human-created hazards driving the North Atlantic right whale
to extinction.

THE REASONABLY FORESEEABLE IMPACT OF NUCLEAR WEAPONS IS WHOLESALE
ENVIRONMENTAL DESTRUCTION
NEPA requires analysis of all foreseeable impacts from the proposed
activity. The environmental impact from use of the nuclear weapons and
nuclear weapons system housed at Kings Bay must be contemplated in an
EIS. It is the nature of the SSBN (Sub-Surface Ballistic Nuclear)
program that it is capable of destroying the whole Earth. The whole
Earth is stakeholder.

Since Kings Bay was first started in 1979, the perceived enemy of the
U.S., the Soviet Union has collapsed and disbanded, the United Nations
has outlawed nuclear weapons, and the world urgently needs to address
its changing climate. It is in the best national interest to divest from
nuclear weapons and the new arms race, upon which $83,000 tax dollars
are lavished every minute. This is more than all other nuclear-armed
nations combined spend to respond to the nuclear threat posed by the
United States.

The environmental impact of converting the nuclear weapons budget to
address the energy conversion that will save our planet’s atmosphere is
globally significant and should be analyzed as the “preferred action
alternative.”

KINGS BAY IMPACTS ON UNIQUE GEORGIA COASTAL ENVIRONMENT ARE ABSENT FROM
EA AND MUST BE CONSIDERED IN AN EIS
Kings Bay is a complex and unique site with environmental impacts from
30 years of Kings Bay operation in the sensitive Georgia coastal
eco-system. Kings Bay’s previous environmental impacts, some of which
are highlighted below, must be included in an EIS.

Kings Bay houses a considerable portion of the U.S. nuclear weapons
arsenal. It is not only capable of destroying the Earth’s biosphere, but
also makes Georgia a target for other nation-states’ nuclear doomsday
arsenals. Use, and possession, of the death-dealing nuclear weapons
deployed at Kings Bay pose catastrophic threats to Georgia and the Earth
which must be considered in the EA. Nuclear weapons have been outlawed
since 2021 by the U.N. Treaty on the Prohibition of Nuclear Weapons.

The sound where whales have given birth for previous millennia is
regularly dredged to accommodate the five-story Trident submarines. In
addition, U.S. Navy sonar testing has been shown to harm sea turtles and
marine life including the large marine mammals, whales, and dolphins.
The impacts of Kings Bay on the dwindling North Atlantic right whale
population’s southern range must be considered in addition to its
impacts on other sea-life.

There are environmental threats to Kings Bay infrastructure, especially
underground nuclear weapons bunkers, from sea-level rise and monster
hurricanes and storm surges fueled by the climate crisis that must be
considered. The carbon footprint of Kings Bay must also be analyzed in
an EIS.

Tritium contamination from routine radiation releases from the nuclear
reactors on-board the Trident submarines must be considered.

The Atomic Age is notably absent from the historical section in the EA.
It is important, and mandatory, to consider all the above impacts of the
proposal to renovate and operate the Kings Bay Trident submarine base in
the context of future nuclear weapons manufacture and use. The proposed
action to renovate Kings Bay to support a new fleet of submarines far
into the future, a future directly threatened by the proposed action, is
out-of-step with the U.N. Treaty on the Prohibition of Nuclear Weapons
which internationally outlaws the possession and use of nuclear weapons.
This profound, burgeoning cultural shift must be considered in the EA.

The U.S. Navy is not only embarking on significant renovation for Kings
Bay base that is projected to deteriorate out of compliance by 2050, but
it is also planning to replace most of the Trident fleet by 2050, at a
cost of $100 billion U.S. tax dollars. The justification for continuing
to deploy this weapons system, capable of destroying all life on Earth,
and of which no other nation besides the U.K. is in possession, is
absent from the EA.

We are at a cultural crossroads that requires contemplation of whether
to continue planet-killing nuclear arms roulette or to denuclearize and
end the Atomic Age to avert annihilation. The NEPA process provides for
a public and transparent exploration of the “big picture” with respect
to large projects. Indeed, NEPA was borne out of the previously
unforeseen environmental misadventures of the military industrial
complex and instituted as a method to avert disaster with experience and
deep foresight.

An alternative to continued “business as usual” at Kings Bay would be to
remove the submarine killing machines and nuclear weapons from this
sensitive, fragile, and vital eco-system and instead maintain a presence
of national defense in the coastal marsh with a Coast Guard base and
marine wildlife sanctuary.  

Nuclear Watch South, and the undersigned, oppose the proposed action and
propose an alternative, more benign project for our national defense
that will also defend our wildlife and restore a healthy atmosphere to
our planet.

Respectfully submitted,

Glenn Carroll
Coordinator
Nuclear Watch South
Atlanta, GA
atom.girl@nonukesyall.org

ADDITIONAL SIGNATORIES

———————————

THANK YOU!!!

Send your sign-on information to atom.girl@nonukesyall.org by midnight
on July 23, 2023.

No nukes y’all!
Glenn

*
Glenn Carroll
Coordinator
Nuclear Watch South
P.O. Box 8574
Atlanta, GA 31106
atom.girl@nonukesyall.org
404-378-4263
404-432-8727 cell
https://www.nonukesyall.org