AFORR Concerns about the Proposed Leasing of Parcel ED-3 to CROET

AFORR Concerns about the Proposed Leasing of Parcel ED-3

Piecemeal Decision-Making. This is another in a continuing series of piecemeal decisions regarding Oak Ridge Reservation land use. This year it is ED-3, a year or two back it was leasing of undeveloped parts of the K-25 site, in 1997 it was Parcel ED-1, and before these came Parcel A and other controversial transfers.

Each one of these was proposed as a stand-alone action uniquely needed to foster economic development, but together they form a program to carve up the public lands of the Oak Ridge Reservation for private benefit. Under the National Environmental Policy Act it is illegal to divide an action into small segments in order to avoid environmental scrutiny for the overall action, but this seems to be what DOE is doing for land use.

Piecemeal decision-making must stop -- DOE should present and assess its comprehensive plans for the Oak Ridge Reservation.

Benefits are Questionable. This proposal is based on a questionable premise -- that making more land available for development will create many jobs to help offset the impacts of DOE downsizing. The EA assumes that there would be about 1000 direct jobs in businesses locating on the 450-acre site, plus another 3000 indirect jobs in the region. Are these numbers credible?

Divert Resources from K-25 Reindustrialization? At K-25 and parcel ED-1 the CROET controls large areas that are available for development and redevelopment right now. Progress at these sites is limited by lack of money to upgrade and extend utilities, clean up contamination, and demolish older buildings to make way for new construction. Adding ED-3 to CROET's portfolio would divert limited resources away from reindustrializing K-25, which should be DOE's and CROET's highest priority.

Ecological Impacts Overlooked. The EA overlooks some potential adverse effects on biodiversity and wildlife habitat. The EA treats the proposed lease areas as if they were isolated in space, failing to acknowledge that several of the various pieces of ED-3 are parts of much larger tracts of forested land. Also, the presence of wetlands, floodplain, and stream habitats is largely ignored. Development of these habitats would continue the cumulative loss of natural habitat in this area and would increase habitat fragmentation.

Historical and Cultural Impacts not fully considered. The EA does not fully consider how the proposed lease would affect the Wheat District -- the remnants of the thriving community that stood in this area before lands and homes were taken to build Oak Ridge. A particular concern is the visual and noise impacts at the George Jones Memorial Church and nearby cemetery if factories or strip malls are built next door.

Need to Assess Impacts of Commercial Development. Considering the location and configuration of the sites that would be leased, highway-oriented businesses are the most likely tenants for most of the parcel. The EA does not say anything about the environmental impacts of strip malls and convenience stores along Highway 58 and Blair Road. Does anyone really believe that more strip malls will restore our economy?

If this land is leased, is CROET the right entity to be put in charge? CROET has been entrusted with public lands and public funds in order to foster economic development of the region, but the organization has not won the public's confidence for its performance in the areas of public openness, accountability, and environmental responsibility.

Send comments on the proposal and the environmental assessment (EA) to Mr. Larry Clark, U.S. Department of Energy, PO Box 2001, Oak Ridge, TN 37831. Comments are due April 28, 2000.

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