Comment on Letcher County Prison Proposal by May 8

The preferred site in Letcher County identified by the U.S. Bureau of Prisons for a high-security prison is a spot at Roxana that was flattened by surface mining. Photo by Bill Estep with the Lexington Herald-Leader

The preferred site in Letcher County identified by the U.S. Bureau of Prisons for a high-security prison is a spot at Roxana that was flattened by surface mining. Photo by Bill Estep with the Lexington Herald-Leader

The Federal Bureau of Prisons has re-opened the Environmental Impact Statement (EIS) comment period for the $444 million prison that's been proposed for Letcher County, Kentucky. We need your help telling the Bureau of Prisons that they are not welcome here, that the citizens of Letcher County deserve better than a federal prison, and that mass incarceration is no solution for anyone.

Last year we hea hundreds f stories about what local people would do with #our444million instead of building a federal prison. Here are some things local people said would be a better use of that money:

  • Build cutting edge community healing facilities and needle exchange programs across the region
  • Fund makerspaces for skill sharing, community training, and re-tooling
  • Participatory budgeting to drive civic engagement & governing transparency 
  • Run fiber optic internet to homes and businesses to support digital literacy & economic growth
  • Grow local food economies and health by supporting farmers and farmers' markets
  • Create an investment endowment for keeping young people in the region

We are asking that you send your #our444million stories, ideas, suggestion, and environmental concern to the Bureau of Prisons.

We are also asking that you request the BOP to conduct a full and comprehensive environmental assessment of potential direct impacts to the Lilley Cornett Woods, an old-growth forest that is only a mile away from the proposed prison site. Lilley Cornett Woods is one of the only old-growth forests in this part of the United States, and its unique value cannot be glossed over with a few words in the BOP's EIS process.

he BOP said at the last ublic hearing on April 12 that they have not contacted Lilley Cornett Woods yet. A list of talking points related to local concerns is below. 

Click here to see the full EIS submit your comment to Isaac Gaston, Site Selection Specialist for the Bureau of Prisons, igaston@bop.gov. Or contact Tarence Ray at tarence.ray@gmail.com or Tanya Turner at tanyabturner@gmail.com for questions about how to make sure the BOP receives your comment.

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Talking Points for the BOP's Draft Supplemental Revised Final EIS

1. Impacts to Lilley Cornett Woods

  • The BOP needs to conduct a thorough and comprehensive survey of the potential impacts to the Lilley Cornett Woods, an old-growth forest that is only a mile away from the proposed prison site at Roxana.
     
  • The Draft Supplemental RFEIS only mentions potential air and light pollution to the Lilley Cornett Woods site. It does not mention potential impacts to soil and water quality, or the impacts of increased road traffic to the area.
     
  • Old-growth forests are very rare. Lilley Cornett Woods is not only a destination of recreation for residents of southeastern Kentucky; it is also used as a research station for students of Eastern Kentucky University and the Letcher County Central High School.
     

2. Utility concerns

  • The Enhanced Utility Investigation Report in the latest Draft Supplemental RFEIS mentions that the Letcher County government will have to put up $1.4 million for sanitary sewer infrastructure to the prison. The county is currently in a $1.3 million budget shortfall; we therefore have no money to pay for this infrastructure.
     
  • The Draft Supplemental RFEIS mentions that both the Letcher County and Knott County Water and Sewer Districts have accrued multiple violations for water quality over the past decade. The infrastructure of these two water districts is old, outdated, and needs serious upgrading. Not only does this endanger the health of potential prisoners and workers at the prison facility, it demonstrates that the county government is ill-equipped to deliver adequate services and resources to residents and businesses within the county.
     
  • Both the BOP and the Draft Supplemental RFEIS have been vague about what it means for the Letcher County Water and Sewer District to have “committed to” addressing the aforementioned problems. This indicates that both the Letcher County Fiscal Court and the BOP are rushing through this process, and are not listening to the very real concerns of citizens in the surrounding area.
     
  • The BOP may think it’s getting a bargain by choosing to do business with the Letcher County Fiscal Court, but its financial situation should speak for itself. Who would want to do business with an entity that is quite literally broke?
     

3. Topography, geology, and soils

  • Compacted fill should not be used for building pads. The Big Sandy Federal Penitentiary in Martin County is known locally as “sink-sink” because it was built on the compacted remains of a former strip mine. Its foundation is quite literally sinking into the earth. This is because, after mining, it is very difficult to compact the soil properly for building foundations. The soil “swells,” leaving air pockets in the soil. As the land gradually settles, it sinks.
     
  • Mine spoil should not be used as valley fills. Filling ephemeral and perennial streams with “overburden” or excavated materials creates a range of problems for the hydrologic balance of a watershed. This practice increases siltation and sedimentation in streams, which in turn harms wildlife and increases water treatment costs and needs. It also increases the likelihood of erosion on slopes, and it drastically increases the possibility of dangerous metals and acids leaching into waterways.

LGP