Wednesday, August 18, 2010

Comments on the Composition of the Uranium Mining Study Committee from NAS

Comment:  This has been a lot of work done by some great people and thanks Olga, D. D, D. L, Beyond Nuclear and Nuclear Information and Resource Service!  I hope the NAS will listen to the people who understand that uranium mining only ruins our land, our air, our water and our lives!  No to uranium mining and milling!

August 18, 2010

Dr. David Feary
Study Director
Board on Earth Sciences and Resources
Division on Earth and Life Studies
National Academy of Sciences
500 Fifth Street, NWWashington, DC 20001

Re: The Composition of Provisional Committee for the Study of
Uranium Mining in Virginia, DELS-BESR-09-06

Dear Dr. Feary:

We appreciate the opportunity to comment on the composition of the provisional study committee on uranium mining in Virginia, established to examine the scientific, technical, environmental, human health, safety, and regulatory aspects of uranium mining, milling, and processing as they relate to the Commonwealth of Virginia. The committee’s work is extraordinarily important, as the findings of the study will assist the Commonwealth in determining whether uranium mining, milling, and processing can be undertaken in a manner that safeguards the environment, natural and historic resources, agricultural lands, and the health and well-being of its citizens.

Proposed uranium mining has been a controversial issue in the Commonwealth of Virginia since late 1970s when the uranium mining deposits were first discovered. For years, this matter has been an issue of utmost concern for the communities that may potentially be affected by uranium mining. For these reasons, it is very important that this uranium mining study be performed by a well-balanced and objective panel of scientists and experts who are free of any obligations to entities that may either benefit or be disadvantaged by the findings of this study.

Unfortunately, it appears that several members of the provisional committee have conflicts of interest that could significantly impair their objectivity and further damage the credibility of this study in the eyes of the public. As more fully discussed below, we respectfully request that the Board on Earth Sciences and Resources (thereafter, BESR) conduct a review of Dr. Corby G. Anderson, Dr. Lawrence W. Barnthouse, and Dr. Michel Cuney for a potential conflict of interest, and remove Mr. Henry Schnell from the study committee due to an apparent conflict of interest.

It has been widely reported in the Virginia local press that the funding for this study is coming from Virginia Uranium, Inc., the company seeking to lift Virginia’s 1982 ban on uranium mining, and that the Virginia Center for Coal and Energy Research at the Virginia Polytechnic Institute and State University is serving as a mere conduit for funneling the study funds to the National Research Council. The Governing Board Executive Council of National Academies was apprised of this situation in an October 2, 2010 letter signed by over 30 concerned citizens. Because of the nature of the end source of funding, the study’s credibility is already being questioned by the public.

Under these circumstances, it is especially important that the study process be conducted in a manner ensuring transparency and an ample opportunity for public comment. Accordingly, we respectfully request that the BESR extend the comment period until August 30, 2010. Pursuant to Section 15(b) of the Federal Advisory Committee Act (thereafter, FACA), the National Academy of Sciences “shall … provide a reasonable opportunity for the public to comment on … appointments before they are made or… in the period immediately following the appointments.” While a 20-day comment period has been the National Academies’ long-standing practice, limiting it to 20 days is not required by law. In this particular case, given the controversial nature of the issue to be examined in the uranium mining study, and the fact that most of Virginia residents received either no notice or insufficient notice of the commencement of the comment period, the BESR should extend the public comment period until August 30, 2010 to allow all interested parties to comment on the composition of the provisional committee.

In addition, we urge the BESR to conduct public hearings to provide an open public forum for interested parties to participate in the study committee discussions in accordance with Section 15(b)(3) of FACA, and to promptly make available to the public a summary of any committee meetings and any materials provided to the study committee in compliance with Sections 15(b)(3)-(4). The general public should also be provided with a sufficient notice of at least thirty (30) days prior to the date of the public meeting and an opportunity to submit written comments on the public committee discussions.

We believe that public meetings should be conducted so as to include all the locations in the Commonwealth of Virginia that may potentially be affected by uranium mining. Historically, uranium companies have shown interest in uranium in Culpeper, Fauquier, Franklin, Floyd, Henry, Madison, Nelson, Orange, Patrick, and Pittsylvania Counties and leased mineral rights on approximately 50,000 acres in the 1980s. Downstream from these areas, there are counties and municipalities whose drinking water could be affected by uranium mill tailings. These include Brunswick, Fairfax, Halifax, Mecklenburg, Virginia Beach, Chesapeake, and others. If the uranium mining ban is lifted, we would likely see exploration for uranium in the black shale of Southwest Virginia, in crystalline granite throughout the Blue Ridge, and in sedimentary rock in the Coastal Plains, as well as further exploration in the Northern and Southern Piedmont. Conducting public meetings at multiple locations will ensure the utmost degree of transparency of the study process for such a controversial issue as uranium mining.

Potential Conflict of Interest

The National Academies have established policies and procedures for addressing potential conflicts of interest to be used by committees in the development of its reports. This policy states that “[i]t is essential that the work of committees of the institution used in the development of reports not be compromised by any significant conflict of interest. For this purpose, the term "conflict of interest" means any financial or other interest which conflicts with the service of the individual because it (1) could significantly impair the individual's objectivity or (2) could create an unfair competitive advantage for any person or organization. Except for those situations in which the institution determines that a conflict of interest is unavoidable and promptly and publicly discloses the conflict of interest, no individual can be appointed to serve (or continue to serve) on a committee of the institution used in the development of reports if the individual has a conflict of interest that is relevant to the functions to be performed.”

We wish to bring the following matters of concern to the attention of the National Academies and the BESR regarding employment, existing fiduciary duties, consulting services, and promotional activities of Dr. Corby G. Anderson, Dr. Lawrence W. Barnthouse, Dr. Michel Cuney, and Mr. Henry Schnell that to the best of our knowledge have not been publicly disclosed as potential conflicts of interest in regard to the uranium mining study.

It is also unclear from the published bios of the provisional committee members whether anyone of them has an expertise required for evaluating post-mining impacts of tailings impoundments. We, therefore, respectfully request that BESR ensure that an expert in this very specific area is included in the committee.

Thank you very much for your time and attention. We hope that BESR will give sufficient consideration to the concerns raised in these comments and will ensure that this very important study proceeds in a most transparent manner.


S.J. Dunavant, Jr.
Southside Concerned Citizens, Inc.
Halifax, VA

Rev. Walter Stark
Cumberland Countians for Peace & Justice
Pleasant Hill, TN

Donald B. Clark
Network for Environmental & Economic Responsibility
United Church of Christ
Pleasant Hill, TN

Patricia T. Birnie,
GE Stockholders' Alliance

Tucson, AZ

Joanne Sheehan
New England War Resisters League,
Norwich, CT

Scott Sklar
The Stella Group, Ltd.
Arlington, VA

Paula Gotsch
Normandy, NJ

Judy Treichel
Nevada Nuclear Waste Task Force
Las Vegas, NV

Deb Katz

Vermont Citizens Action

Hancock Vermont

Marilyn McCulloch
The Carrie Dickerson Foundation
Tulsa, OK

Rinaldo Brutoco
World Business Academy
Santa Barbara, CA

Madeleine Austin
World Business Academy
Honolulu, HI

Joni Arends
Concerned Citizens for Nuclear Safety

Santa Fe, NM

Marylia Kelley
Tri-Valley CAREs


Alice Slater
Nuclear Age Peace Foundation
New York, NY

Nina Bell, J.D.
Northwest Environmental Advocate
Portland OR

Lloyd K. Marbet
Oregon Conservancy Foundation
Boring, Oregon

Mary Davis
Lexington, KY

Nikos Pastos
Center for Water Advocacy
Moab, UT

Portland, OR

Tom Ferguson Foundation for Global Community
Atlanta, GA

Bob Darby
Food Not Bombs
Atlanta, GA

Robert M. Gould, MD
SanFrancisco/Bay Area Chapter: Physicians for Social Responsibility
San Francisco, CA

Cara Campbell
Ecology Party
Ft. Lauderdale, FL

Mark Haim
Missourians for Safe Energy
Columbia, MO

Ken Bossong
SUN DAY Campaign
Takoma Park, MD

Bonnie Urfer

Luck, WI

John LaForge

Luck, WI

Michael Casper
Larson Transportation Institute
University Park, PA

Christopher LaForge
Great Northern Solar
Port Wing, WI

William S. Linnell
Cheaper, Safer Power
Portland, ME

Anna Aurilio
Environment Virginia
Richmond, VA

Dagmar Fabian
Crabshell Alliance
Cockeysville, MD

Hope Taylor,MSPH
Clean Water for NC
Asheville & Durham, NC

Lynn Sims

Don't Waste Oregon

Portland, OR

Greg Wingard
Waste Action
Seattle, WA

Ellen Thomas
Proposition One Campaign
Washington, DC

Egan O'Connor
Committee for Nuclear Responsibility
San Francisco CA

Mary Beth Brangan
The Ecological Options Network, EON
Bolinas, CA

Elena Day
People's Alliance for Clean Energy
Charlottesville, VA

Patricia Gillis
Voices for Earth Justice
Southfield, MI

Douglas Meiklejohn
New Mexico Environmental Law Center
Santa Fe, NM

Ernest Fuller

CCSS (Concerned Citizens for SNEC Safety)

Six Mile Run, PA

Carolyn Treadway
No New Nukes
Normal, IL

Alliance For A Clean Enviornment
Pottstown, PA

Linda Seeley
Terra Foundation
San Luis Obispo, CA

Dr. F. Taylor
Hilton Head for Peace
Hilton Head, SC

Jeff Unsicker
Nuclear Free Vermont
Brattleboro, VT

Cynthia Weehler
Energia Mia
San Antonio, Texas

Catoctin Group, Maryland Sierra Club
Myersville, MD

Suzanne Miller
AFSC (American Friends Service Committee
Cleveland Heights, OH

Wells Eddleman
Staff Scientist
NC Citizens Research Group, Durham NC

Glenn Carroll
Nuclear Watch South
Atlanta, GA

Andrew Fellows
Chesapeake Regional Director
Clean Water Action
Washington, DC

Janet Greenwald
Co-coordinator Citizens for Alternatives to Radioactive Dumping
Albequrque, NM

Molly Johnson Grandmothers for Peace/San Luis Obispo County Chapter
San Miguel, CA

Ralph Hutchison
Oak Ridge Environmental Peace Alliance
Oak Ridge, TN

Alice Slater
Nuclear Age Peace Foundation, NY
New York , NY

Judy Treichel
Executive Director
Nevada Nuclear Waste Task Force

Byron & Janice Motley
Chatham, VA

Barbara M. Hancock
Pittsville, VA

Terry H. Andrews
Halifax, VA

Nancy Gillespie
Roanoke, VA

Tony Dix
Blair, VA

Albert Nunez
Takoma Park, MD

Hattie Nestel
Brattelboro, VT

Hunter Austin
Hurt, Virginia

Lynnea Smith
Crownpoint, NM

Bert Marian
Addison, ME

Karl J. Novak
Hinesburg, Vt

Rebecca L. Ramsay
Cambridge, MA

Barbara Antonoplos
Atlanta, GA

David N. Pyles
Nelson, NH

Denise Jakobsberg
Mt. Rainier, MD

Jessie Dodson
Richmond, VA

Ann Van Kuren
State College, PA

Jonathan M. Block,
Santa Fe, NM

Deborah Dix
Blairs, VA

Bob Brister
Salt Lake City, UT

Natalie Hanson
Lansing, MI

Gail Merrill

New Canaan, CT

Lisa Kasenow
Sanibel, Florida

Tom and Nancy Florsheim

Santa Fe, NM

Diane Pontius
Evanston, IL

Roy C. Treadway
Normal, IL

Leah R. Karpen
Asheville, Nc

Elizabeth Covington
Richmond, Va

Peggy Pryor
Andrews County, TX

Melodye Pryor
Andrews County, TX

Holly Rose
New Smyrna Beach, FL

June Sevilla
Lusby, MD

James Wishart
Lexington Park, MD

Maya Be
Seattle, WA

Dudley Lindsley
Leonardtown, MD

Dr. Thomas B. Cochran
Arlington, VA

Lee Ann Olohan
Owings, MD

Charles K. Johnson
Portland, OR

Gary Shaw
Croton on Hudson, NY

Olga Kolotushkina
Annandale, VA

Karen B. Maute
Danville, VA

Valentin Lukashuk
Fairfax, VA

Joan R. Sprinkle (Mrs. James D.)
Danville, VA

Ricky Simpson
Altavista, VA

Andrey and Larisa Lukashuk
Mount Solon, VA

Deborah Quinn Lovelace
Gretna, VA

Carolyn A. Gibson
Ringgold, VA

Andrew Lester
Keeling, VA

Winnie Pruitt
Danville, VA

Wm. and Barbara Winn
Martinsville, VA

Peyton Wrenn
Blairs, VA

Sergey and Dina Lukashuk
Harrisonburg, VA

Linda Worsley
Chatham, VA

Robert Pruitt
Danville, VA

Barbara Bass Thompson
Chatham, Virginia

Frank H. (Jesse) Andrews, Jr.
Halifax, VA

Kenneth D. And Karen H. Schneider
Caswell County, NC

Phillip Lovelace
Gretna, VA

Ann M. Rogers
Boones Mill, VA

Annette G. Ayres
Summerfield, NC

Barbara Hudson
Chatham, VA

Janice H. Overbey
Chatham, VA

Cory Greer
Roanoke, VA

George Warren Stanhope
Chatham, VA

Janet Lincoln Stanhope
Chatham, VA

Richard Austin
Hurt, VA

Laura D. Meder
Danville, VA

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