"Final Supplemental Revised" EIS: Reviewing the 3rd public comment period for USP Letcher

On October 30th, 2017, the U.S. Bureau of Prisons BOP closed the public comment period on it’s “Final Supplemental Revised Environmental Impact Statement (EIS), the third round of EIS comment periods regarding USP Letcher.”

With this third EIS comment period closed, the Federal Bureau of Prisons could issue a Record of Decision (ROD) any day now, which would make the allotted $444 million federal dollars accessible to continue with the process of beginning construction of USP Letcher--money Letcher County could sorely use for a drug rehabilitation facility, to build more sustainable clean water infrastructure, or other more sustainable form of economic development. Despite an earlier request by the Department of Justice (DOJ) to eliminate the construction of USP Letcher under Trump’s proposed budget, Hal Rogers has successfully lobbied to maintain funds for the proposed prison in the House budget appropriations committee. But Hal Rogers and the BOP will face a groundswell of opposition from our community. Here is a recent interview from an LGP organizer discussing our last 2 years of local resistance and the current organizing climate.

 The past several years have seen successes of a long hard struggle to reduce reliance on prisons and reform racist sentencing disparities for drug convictions. Prison populations have been on a steady decline, but building this prison could be seen as a renewed commitment to the criminalization and mass incarceration of poor and sick people. Appalachia deserves real economic alternatives and effective drug rehabilitation facilities.

 Beyond augmenting a racist and destructive prison industry, USP Letcher will also threaten endangered species and ecological habitats in Eastern Kentucky. Check out EIS comments by LGP member Jonathan Hootman, professional bat biologist from Letcher County, along with comments by engineers and industry experts.

1. Comments by an endangered bat biologist from Letcher County, who has studied Indiana, Northern long-eared (NLEB), and Gray bats for 17 years

2. Comments on behalf of the Abolitionist Law Center (ALC) and the Letcher Governance Project (LGP) concerning the final supplemental revised environmental impact statement (“FSREIS)

3. Comments by prison industry expert and former associate warden at federal prisons, including additional back-up exhibits

4.  Comments by civil engineer with more than thirty years of experience in water resources, pollution, solid waste and hazardous waste fate, mitigation, migration and management

 While these documents are now in the EIS Administrative Record and as such could be used in potential litigation, they are also the grounds for organizers and activists to build a well-informed escalation in our efforts. If this prison is approved and funded, it will likely be challenged in court, but we know that process can move slowly, and companies chomping at the bit for these massive construction contracts may choose to move forward on breaking ground despite the legal proceedings.

If, like us, you are committed to defeating this project, we ask that you review these documents and prepare for the grassroots organizing and direct action efforts that may need to come next, if the BOP opts to disregard these positions which clearly negate the stated need and justification for this prison.

 A note on economic impacts:  LGP recently held a comment-writing party at the local library in Whitesburg; there was much discussion about potential economic benefits/detriments of building the prison. Research proves that other prisons constructed in Eastern Kentucky have not generated the degree of economic growth promised by Hal Rogers and the Planning Commission. For example, in Elliot County, where the Little Sandy Correctional Complex was constructed in 2001, the poverty rate remains at 31%, the median household income is $29,700, and the civilian labor force participation rate is only 39%.  These numbers closely parallel poverty rates in Letcher County. Letcher County deserves a just and sustainable economy, not false promises of new industry that generate profit for politicians and misuse federal investments.

LGP