Dear Ms. Atkins:

 

The Energy Communities Alliance (ECA) is pleased to be able to submit our comments on the draft Memorandum of Agreement (MOA) for the Manhattan Project National Historical Park (Park).  ECA, in particular our members that will be the host communities for the new Park, strongly supports the Park’s creation.  ECA member communities are united in their full support of the National Park Service (NPS) and the Department of Energy (DOE) as they take the next steps in the mandated implementation process. 

 

This Park will be about giving current and future generations a better understanding of the indisputable turning point in world history that was the Manhattan Project.  ECA communities are proud of the role they have played in the Manhattan Project and recognize that the entirety of that incredible story deserves to be preserved and shared.

 

Overall, ECA is pleased with the MOA as presently drafted.  We would like to commend those at DOE and NPS who were involved in the preparing of this document.  ECA looks forward to witnessing its signing as soon as possible by the Secretaries of the Interior and Energy.  We believe this document is broadly in keeping with the recommendations we submitted in testimony on legislation to create the Park that was considered in 2012.  Those recommendations included establishing the Park to protect the honor Manhattan Project and Cold War veterans, protecting the ongoing missions of DOE, and allowing for the inclusion of nationally significant sites, especially those on DOE property.

 

ECA notes, however, that the MOA does not currently apply to all of the individual sites listed in the law creating the Park.  We feel strongly that DOE and NPS should include all the facilities as “eligible” in the legislation so as to ensure access to as many historical resources in the future as possible, in keeping with the spirit of the law creating the Historical Park.  Even if a facility is not yet ready for public access in the near term, putting it in the Park will ensure its preservation over time and will help keep DOE focused on what needs to happen to make the facility accessible.  We also urge DOE and NPS to develop a process for evaluating additional properties and areas to determine whether they should be added to the Park in the future.  These include both DOE facilities and community-based resources.  This will only help to expand public understanding of the Manhattan Project.

 

ECA believes it is necessary and appropriate for NPS to have decision making authority for the content of the interpretation of the Manhattan Project for the purposes of administering the Park.  While outside of the scope of the MOA, ECA anticipates the NPS will seek input from local elected officials, community leaders, former workers, and other local stakeholders when weaving together a national theme for the entire Park.  We are confident that NPS will rightly put the Manhattan Project in the context of World War II, including the scale and brutality of the War.  Our communities also expect to have input, where appropriate, in the formation of the management plans to be created for the Park. 

 

ECA member communities agree, in accordance with the Act establishing the Park, that DOE should seek to strike a balance between access to historical sites of DOE property while protecting national security and ongoing operations.  We anticipate that DOE will not prevent access to historical properties or documents that will aid in sharing the Manhattan Project story for reasons except those that are absolute safety or security concerns.

 

We further agree that DOE should retain the responsibility to take any and all actions to protect Park facilities, resources, and values.  However, ECA suggests the term “emergency situation” in Article III.C.2 be explicitly defined.  While we have faith that current and future DOE leadership will seek to preserve Park areas and resources, defining that term may prevent any abuse of authority – intended or otherwise – during the operation of the Park.

 

The joint operating plans outlined in Article III.C.3 should address coordination with local governments.  The success of every listed component of the joint operating plan is contingent upon not just cooperation between NPS and DOE, but input from and in some cases action by nearby local governments. 

 

While we are pleased that the MOA will include a section detailing how NPS and DOE will consult with third parties, Article III.C.4 should exclude emergency communications.  ECA anticipates that such communications would be exempted in the case of any emergency incident, but urges the explicit inclusion of language to address this issue.

 

We applaud DOE’s commitment to preserve the historic resources surrounding the Park facilities.  ECA has long advocated for historic preservation and we are encouraged that DOE will make stabilization and preservation work a priority at these sites.  We request that DOE also commit to preserving the landscapes surrounding the Park facilities so that visitors will be able to understand the historic settings in which the facilities reside.

 

With regard to Article VI, ECA and local communities look forward to working with NPS and DOE to establish philanthropic partnerships necessary to support the Park.  To clarify interpretation of this article, ECA suggests the term “educational sales” be clearly defined.  While NPS should be the determiner of what should be said and shared about the Manhattan Project (i.e., ensure consistency with Park themes), the MOA should clarify that DOE and NPS are not constraining the sale or distribution of materials in facilities currently owned by DOE or its contractors.  Concerning the authority of NPS to accept and uses gifts, Article III.A.7 and Article VI should be expanded to allow for cooperative agreements to be entered into for the purposes of supporting the Park.  Similarly, DOE should define and be prepared to utilize the authorities given to it under the legislation – including to accept donations and labor to help restore, maintain, and operate the Park facilities.  We request that NPS and DOE work with the local communities to lay out the processes for accepting donations, and ensure that contributions can be made directly to the Park sites.

 

We appreciate the effort made in the MOA to delineate the critical role of NPS and DOE leaders assigned to work at each of the Park sites.  We urge the agencies to ensure these leaders develop (or maintain) strong working relationships and two-way communication with local governments and community members.  We also urge the agencies give their site leaders the authority and responsibility to implement the National Park.

 

Again, ECA is pleased to have the opportunity to submit these comments.  We look forward to the signing of the MOA and our community members intend to play a strong role in ensuring the Park is smoothly implemented and managed for current and future generations.

 

Should you have any questions or concerns, please contact Seth Kirshenberg via email at sethk@energyca.org or by phone at 202-828-2494.

 

                                                                       

Sincerely,

Chuck Smith

Chairman, Energy Communities Alliance

Councilmember, Aiken County, SC

 

cc:       

Mayor Warren Gooch, City of Oak Ridge, TN

Councilman Chuck Hope, City of Oak Ridge, TN

County Executive Ron Woody, Roane County, TN, ECA Secretary

Council Chair Kristin Henderson, Los Alamos County, NM, ECA Treasurer

 Mayor David Rose, City of Richland, WA

Councilman Robert Thompson, City of Richland, WA, ECA Past Chair

Mayor Steve Young, City of Kennewick, WA, ECA Vice Chair

Mayor Matt Watkins, City of Pasco, WA

ECA Board