Number of resolutions growing against Canadian nuclear waste dump on the Great Lakes

As compiled by Stop the Great Lakes Nuclear Dump, more and more resolutions are being passed on both sides of the border in opposition to Ontario Power Generation's (OPG) proposed Deep Geologic Repositories (DGRs), or DUDs (for Deep Underground Dumps).

In addition to these numerous resolutions, as of April 10, 2014, over 53,000 individuals have signed the Stop the Great Lakes Nuclear Dump petition.

Below, please find links to many of these resolutions opposing, or voicing serious concerns, regarding Deep Geological Repositories (DGRs) for burying radioactive wastes in the Great Lakes Watershed:

2006

Great Lakes United

(GLU, disbanded in June 2013, was an environmental coalition comprised of scores of groups from the U.S., Canada, and Native American First Nations)

2008

Macomb County Water Quality Board - (Macomb County, Michigan)

Macomb County Board of Commissioners - (Macomb County, Michigan)

(As of 2012, Macomb County had a population of 847,383);

St. Clair County Water Quality Board - (St. Clair County, Michigan)

(As of 2012, St. Clair County had a population of 160,644);

Marine City - (St. Clair County, Michigan)

(As of 2012, Marine City had a population of 4,174);

City of St. Clair Shores - (Macomb County, Michigan)

(As of 2012, the City of St. Clair Shores had a population of 59,749)

Environmental and public interest group sign-on statement (around 300 organizations, including coalitions, as well as many hundreds of individuals).

2012

The Huron Declaration, Nuclear Labyrinth on the Great Lakes - International Conference held in Huron, Ohio, focused on critical nuclear issues affecting the health of the Great Lakes watershed;

Great Lakes United (re: DGR 1 and 2). GLU also passed a companion RESOLUTION ON THE HUMAN RIGHT TO WATER, inherently incompatible with OPG's proposed DUDs, which resolved: "that Great Lakes United urge the governments of Canada and the United States in national and global trade, to exercise responsible stewardship over this life-giving resource by respecting water as a common good and basic human necessity thereby a human right that cannot be bought and sold, this being ensured through public ownership; and recognize that this human right brings with it the duty to treat water responsibly, and the obligation to ensure all citizens’ human rights are met." (emphasis added)

2013

Michigan State Senate

(The State of Michigan, as of 2012, was home to 9,883,000);

Macomb County Board of Commissioners - (Macomb County, Michigan - 2nd resolution);

Village of Lexington - (Sanilac County, Michigan)

(As of 2010, Lexington had a population of 1,178);

Lynn Township - (St. Clair County, Michigan, one of three townships in St. Clair County that defeated a "low" level radioactive waste dump for 8 states, a little over two decades ago)

(Lynn Twp.'s population is reported as 1,129 to 1,187);

St. Clair County Board of Commissioners - (St. Clair County, Michigan);

Wayne County Board of Commissioners - (Wayne County, Michigan)

(As of 2012, Wayne Co. had a population of 1,792,000);

City of Oregon, Ohio

(As of 2012, Oregon had a population of 20,221);

Friends of the Detroit River;

Lambton County, Ontario

(Lambton Co. currently has a population of 126,199);

City of Sarnia - (Lambton County, Ontario)

(As of 2011, Sarnia, the largest city on Lake Huron, had a population of 72,366);

Greenwood Township - (St. Clair County, Michigan)

(As of 2000, Greenwood Twp. had a population of 1,373);

County of Essex, Ontario

(As of 2011, Essex Co. had a population of 177,891);

Town of Blue Mountains, Ontario

(As of 2011, The Blue Mountains (Town) had a population of 6,453);

Town of Kingsville, Ontario

(As of 2011, Kingsville had a population of 21,362);

Attached to Sen. Hopgood's written testimony to the Joint Review Panel are statements of opposition to the Great Lakes radioactive waste dump provided by: Michigan United Conservation Clubs (with 42,000 members); Michigan Boating Industries Association (comprised of 300 marine businesses); Michigan Charter Boat Association; Michigan Steelhead & Salmon Fishermen's Association (the largest sport fishing organization in the Great Lakes Basin); Michigan Environmental Council (a coalition of more than 70 organizations); and Michigan Clean Water Action (boasting 200,000 members);

Toledo City Council, Ohio

(As of 2012, Toledo had a population of 284,012);

London, Ontario

(As of 2011, London had a population of 366,151);

Great Lakes and St. Lawrence Cities Initiative, May 24th and August 13th. The Great Lakes and St. Lawrence Cities Initiative (GLSLCI) is a binational coalition of mayors and other local officials (in over 100 cities) that works actively with federal, state, and provincial governments to advance the protection and restoration of the Great Lakes and the St. Lawrence River.

Update on October 3, 2013 by admin

City of Wyandotte, Michigan

(As of 2012, Wyandotte had a population of 25,485);

Port Clinton, Ohio (City Council considering passage of a resolution, after its Planning and Development Committee urges it);

City of Mississauga, Ontario

(As of 2011, Mississauga was Canada's 6th largest municipality, with a population of 713,443).

Update on November 21, 2013 by admin

The City of Toronto, Canada's largest city, with a population of 2.79 million, on Nov. 14th

Update on November 22, 2013 by admin

The City of Windsor, Ontario -- just across the Detroit River from Detroit, MI -- has also passed a resolution opposing OPG's DUD! Its population is 215,000.

Update on November 25, 2013 by admin

The City of Kingston, Ontario passed resolution on Nov. 19th opposing OPG's DUD. Kingston, where the St. Lawrence River meets Lake Ontario, has a population of 123,363.

This ever expanding list, above, of 7 counties, and more than a dozen cities, towns, townships, and villages across MI, OH, and ON, represent jurisdictions with a combined population of nearly 17.7 million downstream residents.

Update on November 28, 2013 by admin

The Town of Ajax "By the Lake" (Lake Ontario, that is), just east of Toronto, near the 8-reactor Pickering Nuclear Power Plant, has also passed a resolution against the DUD. Ajax, as of 2011, had a population of 109,600.

This takes the total population of municipalities (cities, towns, townships, counties, villages, etc.) with resolutions against the DUD to around 17.8 million.

Update on December 16, 2013 by admin

The Town of Port Clinton, OH passed a resolution on Dec. 10, 2013. Port Clinton is located within the 10-mile Emergency Planning Zone of FirstEnergy Nuclear's Davis-Besse atomic reactor. Port Clinton has a population of over 6,000.

Update on February 6, 2014 by admin

Our allies at Stop the Great Lakes Nuclear Dump report that the following municipalities have recently adopted resolutions opposing the DGR (or DUD):

Ontario:

City of Sault Ste. Marie;

City of St. Catharines;

Municipality of Chatham-Kent.

Michigan:

City of Eastpointe;

Clinton Township.

Update on March 4, 2014 by admin

City of Milan, MI, in Southeast MI, population 5,836.

NRC Nuke Waste Con Game public comment meetings begin next week

An irradiated nuclear fuel assembly being moved underwater in an indoor storage pool.The U.S. Nuclear Regulatory Commission (NRC) has published information on how you can take part in the very first "Nuclear Waste Confidence" draft Generic Environmental Impact Statement (DGEIS) public comment meeting, to be held on Tuesday, October 1st from 2 to 5 PM Eastern at NRC's Rockville, MD HQ.

While it is not required to pre-register to view the proceedings on the NRC's webcast (as NRC has stated, "It is not necessary to register to view the webcast. Please go to http://video.nrc.gov for connection information), Beyond Nuclear encourages you to testify orally, to provide public comments. Sample public comments can be found here. (You can also submit public comments by various means -- email, internet webform, snail mail, fax, etc. -- anytime between now and Nov. 27th. Here is how you can do so.)

Nuclear Information and Resource Service (NIRS) also has a helpful resources page you can check out in preparation for the upcoming public comment meetings.

If you are in the D.C. area and can attend this first public comment meeting on Oct. 1 in person, great! But if you are not able to come in person, you can still take part by listening in and watching at the webcast, and very importantly, by providing oral public comment over the phone.

Note that this Oct. 1st meeting, and the very last meeting of all on Nov. 14th (again, to be held at NRC's HQ in Rockville, MD), are the only public meetings of the dozen to be held around the country where viewing by webcast and providing oral public comment by phone will be allowed. To take part in the dozen additional public comment meetings across the U.S., you must attend in person (NRC is urging pre-registration for those, too).

In order to provide oral public comments on Oct. 1st (whether in person, or by phone), you must pre-register as soon as possible. Following are NRC's pre-registration instructions:

REGISTRATION:

Persons interested in providing oral comments at the October 1 meeting are encouraged to register no later than 3 days prior to the meeting; however, registration will be accepted at the meeting. Please note that individual oral comments may be limited by the time available, depending on the number of persons who register.

NRC will accept written comments any time during the meeting.

Registration by Telephone:

To register for and request to provide oral comments at the October 1 meeting, whether in-person or by teleconference, please call 301-287-9392.

Voicemail is available for calls received after hours or if no one is available to take your call directly. Please clearly state your name, affiliation or organization if appropriate, and request for accessibility accommodations if necessary. Also, please indicate whether you would like to provide oral comments. Registration will be confirmed by phone.

Registration by Email:

Please send your name, affiliation or organization if appropriate, and request for accessibility accommodations if necessary, to WCRegistration@nrc.gov. Also, please indicate whether you would like to provide oral comments. Registration will be confirmed by email.

To attend the open house and/or meeting at NRC headquarters in person, please provide your full name as it appears on a government-issued photo ID, which you must present upon entering the NRC facility. Directions to the NRC and parking information will be sent to you upon registration.

To provide comments by telephone during the webcast, dial 1-888-603-9749 and provide passcode 5132332. An operator will assist you. Speaking priority will be given to those who have registered in advance. Individual oral comments may be limited by the time available, depending on the number of persons who register.

For more information on NRC's Nuke Waste Con Game, please see Beyond Nuclear's weekly email bulletin entry from last week.

Momentum building of international opposition against OPG DUD

The Stop the Great Lakes Nuclear Dump petition now has nearly 35,000 signatures! If you haven't already signed it yourself, please do. And please continue to circulate it to everyone you know! Beverly Fernandez, spokesperson for Stop the Great Lakes Nuclear Dump, gave powerful testimony last Saturday in opposition to the proposal to "bury poison next to the well" of 40 million people, the Great Lakes, drinking water supply for 8 U.S. states, 2 Canadian provinces, and a large number of Native American/First Nations.

On September 23rd, Beyond Nuclear's Radioactive Waste Watchdog, Kevin Kamps, also testified against Ontario Power Generation's (OPG) proposal to bury all of Ontario's so-called "low" and "intermediate" level radioactive wastes (L&ILRWs), from 20 atomic reactors across the province, within a half-mile of the Lake Huron shoreline (see image, left).

OPG refers to its proposal as the DGR, for Deep Geologic Repository. But critics use DUD, for Deep Underground Dump, an apt appellation coined by Dave Martin of Greenpeace Canada.

Dave, along with Irene Koch of Nuclear Awareness Project, published a map of Nuclear Hotspots on the Great Lakes in 1990. It gave an overview of the vast number of uranium fuel chain activities taking place in the bio-region, including scores of atomic reactors on the shorelines. Anna Tilman of International Institute of Concern for Public Health recently updated the map, to include the proposed DUDs. Both maps helped frame Kevin's testimony to the JRP regarding the DUDs.

Kevin's testimony focused on the woeful inadequacy of OPG's environmental assessment of cumulative impacts, as well as synergistic effects, of radiological and toxic chemical hazards in the Great Lakes bio-region caused by nuclear power facilities, as well as other dirty, dangerous and expensive energy industries, such as fossil fuel burning power plants.

The Canadian federal Joint Review Panel, comprised of a majority of two members from the CNSC (Canadian Nuclear Safety Commission), and one member from the CEAA (Canadian Environmental Assessment Agency), have posted the transcript of Kevin's testimony (beginning at Page 112, or 116 of 350 on the PDF counter). The JRP has also posted the video recording of Kevin's testimony (beginning at time code 2:26, for two hours 26 minutes into the segment). Kevin's Power Point presentation was based on his previously filed written submission.

CNSC is as infamous, if not more so, as the U.S. Nuclear Regulatory Commission, in terms of rubber-stamping nuclear industry proposals.

Altogether, dozens of concerned local residents and environmental group represenatives have testified thus far against the DUD, with many more to come. During Kevin's short two days in Kincardine, Ontario, alone, (the "company town" where the Bruce Nuclear Generating Station and its Western Waste Management Facility are located), he was joined by the likes of Don Hancock of Southwest Research and Information Center (SRIC) in New Mexico, Brennain Lloyd of Northwatch, Angela Bischoff of Ontario Clean Air Alliance, John LaForge of Nukewatch in Wisconsin, Theresa McClenaghan of Canadian Environmental Law Association, Janet McNeill of Durham Nuclear Awareness, and many others

In addition to his formal JRP testimony, Kevin joined with Brennain of Northwatch and Don of SRIC as featured speakers at community forums regarding yet another proposed dump in the vicinity of Bruce Nuclear, "DUD#2," for all of Canada's high-level radioactive wastes (HLRW). The two events were held in Ripley, Ontario, just a few kilometers, as well as Goderich, Ontario, just 50 kilometers, from Kincardine. Those two municipalities, and four more in the area, have "volunteered" to "host" HLRW from 22 atomic reactors in Ontario, Quebec, and New Brunswick. Both events drew good turnouts of deeply concerned local residents.

The international opposition against both DUDs is growing, despite the perception of intimidation and harassment by the Ontario Provincial Police (OPP) which has garnered multiple articles in the Toronto Star about OPP's interactions with local Canadian residents, as well as American interveners (including Beyond Nuclear). CNSC has disavowed having put the OPP up to the now controversial knocks on Canadian doors and phone calls to the U.S., even though an OPG spokesperson has said they did.

Yesterday, the neighboring Saugeen Ojibwe Nations gave powerful testimony.

On Monday, Michigan State Senator Hopgood and State Representative Roberts will testify against the DUD. Hopgood introduced a resolution critical of the DUD which garnered unanimous passage in the Michigan State Senate. Roberts is working on a companion resolution in the Michigan State House of Represenatives.

Update on September 28, 2013 by admin

Janet McNeill's blog, "Things That Matter," has provided links to much of the news coverage on the DUD hearings thus far. Beyond Nuclear's Kevin Kamps and Janet's testimony before the Joint Review Panel overlapped on Sept. 23 and 24 in Kincardine, Ontario.

And the Sarnia Observer has just reported that "Deep Geological Repository opponents getting leg up at hearings, Sarnia Mayor Mike Bradley says." Sarnia is the largest city on Lake Huron. Mayor Bradley has long been a Bruce Nuclear watchdog, such as breaking the story on the proposed radioactive steam generator shipments on the Great Lakes, which were eventually cancelled due to public opposition.

Update on September 30, 2013 by admin

The number of resolutions -- in Ontario, Michigan, and Ohio -- opposing the DUD is also growing!

The fate of the Great Lakes is at stake, as OPG DUD hearings begin

The Stop the Great Lakes Nuclear Waste Dump petition now has nearly 33,000 signatures! If you haven't already signed it, please do! And please spread the word about the petition to everyone you know!

As reported in the Stop the Great Lakes Nuclear Waste Dump's press release section, Canada's most famous environmentalist, David Suzuki, as well as North American physicians organizations, have joined the effort to block the dump!

On August 19th, Beyond Nuclear's Kevin Kamps had to honor of sharing the stage with Stop the Great Lakes Nuclear Dump's Beverly Fernandez, as well as Sierra Club South East Michigan Group's Ed McArdle, Michigan State Senator Hoon-Yung Hopgood, and Michigan State Representative Sarah Roberts, at a town hall meeting at Wayne State University's law school in downtown Detroit, held to organize resistance to this nuke waste dump.

As documented in Tom Lawson's recently published, inspiring book Crazy Caverns: How one small community challenged a technocrat juggernaut...and won!, Suzuki played an important role in the successful grassroots campaign in the mid-1990s that stopped the burial of radioactive wastes on the Lake Ontario shore at Port Hope, Ontario.

As reported last week, Beyond Nuclear's Radioactive Waste Watchdog, Kevin Kamps, will testify on Sept. 23rd alongside a large number of environmental allies from both the U.S. and Canada at a hearing that could determine the fate of the Great Lakes, the drinking water supply for 40 million people in 8 U.S. states, 2 Canadian provinces, and a large number of Native American First Nations.

Kevin has already submitted written testimony and prepared a power point presentation.

The pre-mature Joint Review Panel environmental assessment hearings for Ontario Power Generation's (OPG) proposed Deep Geologic Repository (DGR) for all of Ontario's so-called "low" (LLRW) and "intermediate" level radioactive wastes (ILRW) began last week.

LLRWs and ILRWs from a dozen additional atomic reactors, at the Pickering and Darlington nuclear power plants just east of Toronto, have been imported, over the past 40 years, into the Bruce Nuclear Generating Station, itself one of the world's single largest nuclear power plants with 9 reactors (one a permanently shutdown prototype, Douglas Point, but 8 still-operable). Bruce is on the Lake Huron shoreline, less than 100 miles from Michigan (see map, above left).

Months ago, Beyond Nuclear joined with a coalition of environmental groups from both sides of the border, to protest the commencement of the hearings, as the environmental assessment is woefully incomplete. As Kevin will testify on Monday, OPG has barely even considered the cumulative impacts of dozens of atomic reactors, as well as a large number of fossil fuel burning power plants, discharging radioactivity and toxic chemicals into the Great Lakes watershed, combined with the risks of future leaks or accidents at the proposed DGR. The JRP is composed of two members from the Canadian Nuclear Safety (sic) Commission (CNSC), as well as one member from the Canadian Environmental Assessment Agency (CEAA).

Once at Bruce, the LLRWs have been incinerated. Atmospheric radioactive emissions from this large-scale incineration of radioactive wastes are very likely greater than zero, to put it mildly! The resulting LLRW ashes, as well as the ILRWs, have since been stored at Bruce's Western Waste Management Facility (WWMF), alongside a growing stockpile of high-level radioactive wastes (HLRW) in dry cask storage. It is immediately adjacent to the WWMF that OPG wants to dig the entrance tunnel to its DGR, or as Dave Martin of Greenpeace Canada dubbed it, the DUD (for Deep Underground Dump). This proposed entrance tunnel is a mere half-mile from the waters of Lake Huron.

But this LLRW and ILRW DGR is but DUD#1. It could easily pave the way for DUD#2--a national HLRW dump for irradiated nuclear fuel from 22 Canadian reactors in three provinces (20 in Ontario, plus Gentilly-2 in Quebec and Point Lepreau in New Brunswick). A half-dozen Bruce area municipalities have "volunteered" to be considered by Canada's Nuclear Waste Management Organization (NWMO) for the national HLRW dump. Never mind that these municipalities are mostly populated by Bruce Nuclear workers, and are also blinded by dollar signs.

Beyond Nuclear has joined with Canadian environmental allies like Northwatch to demand answers about a DUD#3, that could double the capacity of DUD#1 from 200,000 to 400,000 cubic meters of radioactive waste. While DUD#1 is supposedly to be limited to operational and refurbishment LLRWs and ILRWs, DUD#3 is for decommissioning LLRWs and ILRWs.

Media coverage of the hearings began on day one, and has continued steadly, including this hard-hitting column in the Toronto Star.

The Star also reported on the environmental coalition's challenge to DUD#3, as mentioned above.

Sample comments you can use to write your own for NRC's "Nuke Waste Con Game" draft GEIS public comment period (Sept. 13 to Nov. 27)

Following are a number of basic, sample comments you can use to prepare your own written comments, and/or oral testimony for the upcoming public meeting nearest you. There is no limit to the number of times you can submit comments between now and the end of the 75-day public comment period. As Beyond Nuclear, as well as other organizations, further digest the 600-page GEIS, additional ideas for public comments will be shared widely. Please comment "early and often"! Public participation in this proceeding is vital, to show decision makers that people across the country care deeply about high-level radioactive waste risks.

For more information, contact Beyond Nuclear's Radioactive Waste Watchdog, Kevin Kamps, at kevin@beyondnuclear.org or (301) 270-2209 ext. 1.

SAMPLE PUBLIC COMMENTS:

1. Stop making it. The only solution to the high-level radioactive waste (HLRW) problem is to not generate irradiated nuclear fuel in the first place. Our society's "preferred alternative" to nuclear power and the forever deadly radioactive waste it inevitably generates is efficiency and renewables, such as wind and solar power. As Dr. Arjun Makhijani, President of the Institute for Energy and Environmental Research, showed in his 2007 book Carbon-Free, Nuclear-Free: A Roadmap to U.S. Energy Policy, both fossil fuels and nuclear power can be completely phased out of the U.S. economy by 2040, and replaced by efficiency and renewables, without any further technological breakthroughs required, and for the same percentage of our Gross Domestic Product (GDP) as we currently spend on dirty, dangerous, and expensive fossil fuels and nuclear power.

2. For the HLRWs that already exist, require Hardened On-Site Storage (HOSS). Hundreds of environmental and public interest groups, representing all 50 states, have endorsed the Statement of Principles for Safeguarding Nuclear Waste at Reactors, which describes HOSS. Where possible, densely-packed, vulnerable HLRW storage pools, at risk of catastrophic fires and radioactivity releases, should be emptied into on-site dry cask storage that is "hardened": designed and built well, safeguarded against accidents, fortified against attacks, and protected against leakage into the environment. This should be expedicted as a national security top priority. Locations where HOSS is not safe (places vulnerable to flooding, for example), hardened dry cask storage should be done as close to the wastes' point of generation as possible, as safely as possible. HOSS must be monitored and retrievable, and is but an interim measure. HOSS cannot be a permanent measure on the sea coasts and fresh water sources (rivers, lakes, reservoirs) of our country, due to rising sea levels and risk of leakage into our vital drinking water supplies.

3. NRC's assumption that "indefinite storage" at reactor sites can go on literally forever, without a loss of institutional control, is absurd. As the environmental coalition's expert witness, Dr. Makhijani of IEER, has pointed out, one of the oldest continuous human institutions in the world, the Catholic Church, is only 2,000 years old. Plutonium-239, for one, will remain hazardous for at least 240,000 years.

4. Under its "indefinite storage" scenario, NRC has assumed that dry cask storage -- cask pads, inner canisters, and the dry casks themselves -- will be replaced once every 100 years, forevermore into the future. NRC assumes that Dry Transfer Systems will be built (and also replaced every 100 years), since pools will have been dismantled during decommissioning, by at most 60 years after permanent reactor shutdown. But NRC has not dealt with the very real risk that the irradiated nuclear fuel will so degrade with age that such transfer operations cannot be carried out safely or smoothly. This is especially a risk with "high burn-up fuel," that has spent more time in an operating reactor core, and is thus significantly more radioactive and thermally hot. NRC has also not provided the price tag for such future transfer and replacement operations.

5. It is inappropriate for NRC, in this GEIS, to use the Private Fuel Storage (PFS), LLC "centralized interim storage" proposal, targeted at the Skull Valley Goshutes Band of Indians in Utah, as a model for away-from-reactor storage. Although licensed by NRC for construction and operation, PFS was canceled in December 2012. NRC claims in its GEIS to observe Environmental Justice (EJ) principles, and yet PFS was a blatant violation of EJ. Nearly 500 organizations across the U.S. joined with Skull Valley Goshute traditionals urging NRC to disapprove PFS's license, due to its inherent violation of EJ.

6. NRC downplays the risks of pool fires by assuming that surrounding populations will be successfully evacuated. But nuclear utilities are allowed to store HLRW in pools for many decades after reactors permanently shutdown, in order to defer the costs of dry cask storage as far off into the future as possible, despite the inherent risks. At the same time, NRC allows utilities, via exemptions from regulations, to do away with 10-mile radius emergency planning zones (EPZs) within as soon as 12 to 18 months post-reactor shutdown. This, despite the lingering risk of storing HLRW in pools at such shutdown reactor sites. How can populations be evacuated, if EPZs have been dismantled?!

7. NRC also downplays the risks of pool fires by assuming that a pool drain down accident (or attack) involves the complete drain down of the pool. However, as environmental coalition expert witness Dr. Gordon Thompson of the Institute for Resource and Security Studies (IRSS) has pointed out, any technically competent person paying attention to the issue should have known since 1979 that a partial drain down of the pool is actually a worse-case scenario, for the leftover water in the bottom of the pool would block convection current air flow which would help cool the irradiated nuclear fuel, leading to faster heat up to the ignition point.

8. You can also comment to NRC about specific risks with HLRW storage pools or dry casks at the nuclear power plant near you. As a Generic EIS, NRC's current draft largely ignores site-specific risks.

Click on this link to see HOW you can submit public comments to NRC on its "Nuke Waste Con Game" draft GEIS, including by email, webform, fax, snail mail, hand-delivery, and orally at a dozen public comment meetings across the country (including NRC HQ public comment meetings on Oct. 1 and Nov. 14, which can be called into from anywhere, as well as attended by webcast, thus allowing remote oral comments to be submitted).