Responding to a Union of Concern Scientists Action Alert to generate public comments on the Environmental Impact Statement for the Department of Energy “Complex Transformation” (formerly “Complex 2030”) plan to modernize U.S. nuclear weapons capability, I submitted the following letter (with UCS-mandated closing paragraph) to Theodore Wyka, Complex Transformation SPEIS Manager:

Dear Mr. Wyka,

Thank you for the opportunity to comment on the DoE “Complex Transformation” plan through the mandatory Environmental Impact Statement public comment period. I support the plan’s initiatives to downsize the nuclear weapons production & maintenance complex, eliminating unnecessary redundancies.

However, I oppose the Complex Transformation where it seeks to re-initiate the unnecessary & destabilizing capability to develop & manufacture new types of nuclear weapons. The United States still maintains thousands of nuclear weapons from the Cold War period and has thousands more in storage, more than sufficient capacity to maintain a clear nuclear deterrent for the foreseeable future.

I concur with former Secretaries of State George Shultz and Henry Kissinger in their published assertions that the U.S. should aggressively pursue a world free of nuclear weapons: “Reassertion of the vision of a world free of nuclear weapons and practical measures toward achieving that goal would be, and would be perceived as, a bold initiative consistent with America’s moral heritage. The effort could have a profoundly positive impact on the security of future generations. Without the bold vision, the actions will not be perceived as fair or urgent. Without the actions, the vision will not be perceived as realistic or possible.”

The expansion of capacity to create new nuclear weapons called for in Complex Transformation clearly constitutes actions inconsistent with this vision of a world free of nuclear weapons & counter to our immediate interest in stemming their proliferation to other nations. Expansion sends the wrong message to other nations both by instilling a false confidence in the capacity of nuclear arsenals to increase national security and by increasing the incentives to produce them in order to counter U.S. nuclear expansion. The calculus of nuclear deterrence in a multipolar world is far more complicated than in the bipolar Cold War nuclear stand-off. We must ensure that our present actions are consistent with protecting our long-term security interests of global nuclear disarmament.

Instead of recreating the capacity to produce new, unnecessary nuclear weapons, the DOE should focus on shrinking the still-oversized nuclear weapons complex and on maintaining the safety and security of our existing weapons arsenal as the size of our nuclear stockpile is reduced.