MOTION OF INTERVENOR SUSTAINABLE ENERGY AND ECONOMIC DEVELOPMENT COALITION FOR LEAVE TO FILE LATE-FILED CONTENTION, AND CONTENTION 17

Filed by Toledo, Ohio attorney Terry Lodge, on behalf of SEED Coalition of Texas.

Robert Alvarez serves as expert witness. See his expert witness declaration, here. See his CV here.

The contention is based on revelations contained in a U.S. Nuclear Waste Technical Review Board report, published in September 23, 2019.