•    Account for disproportionate impacts to low-income communities of color (environmental justice communities) in the American Southwest and along transport routes there and nationwide.
•    Detail transportation routes and consider nationwide risk to millions of Americans along transport routes.
•    Consider the risk of leaks, contamination, sabotage/intentional attacks, or severe transportation accidents.
•    Include a plan to repackage leaking waste casks and a plan to move waste when required.
•    Complete the required alternatives analysis by considering Hardened On-Site Storage (HOSS), at or near reactors, as an alternative to Consolidated Interim Storage.
•    Consider lessons learned from past accidents, nor the potential for future radioactive waste accidents to cost hundreds of millions to billions of dollars to clean up.
On behalf of our members and supporters, our organizations oppose Consolidated Interim Storage Facilities at this and other sites, including Holtec International/Eddy-Lea Energy Alliance's CISF, targeted at Laguna Gatuna in southeastern New Mexico, just 40 miles from WCS. The DEIS fails to adequately analyze environmental and cumulative impacts and the socioeconomic risks of the two proposed CISF applications in the same local area. The NRC should protect public health and safety, the economy and the environment, by halting the application processes and denying the licenses for both ISP's and Holtec's proposed facilities.

We also oppose as unacceptably dangerous the plan to multiply transport risks, and the environmental justice burden, that is inherent in Consolidated Interim Storage. As ISP/WCS itself admitted in its Environmental Report (Revision 2, Chapter 2, Figure 2.6-1, Transportation Routes, Page 2-78), the outbound shipments from the CISF, heading to Yucca Mountain, Nevada for permanent burial, would travel through the very same communities in New Mexico, Texas, and Oklahoma that had already seen the inbound shipments, carrying irradiated nuclear fuel from eastern reactors, to the CISF in the first place. These outbound shipments could number in the several tens of thousands if the irradiated nuclear fuel is repackaged at WCS (itself a hazard to workers and local residents), into smaller-sized TAD (Transport, Aging, and Disposal) containers, required for compliance with DOE's Yucca repository design plans. CIS makes no sense, and would significantly increase transport risks and EJ burdens.