SBCT Final EIS - Govsupport.us

Appendix D ⎯ Responses to Comments on the Draft Environmental Impact Statement29. The DEIS’ claim that Fort Polk could not accommodate the 2/25 th SBCT cannot be squaredwith the Army’s past admissions. The Army has already completed an EIS for Stryker trainingat Fort Polk and concluded that the installation should be used to home station an SBCT.The DEIS fails to explain why Fort Polk is no longer a reasonable alternative for stationingan SBCT.Response: The Army has added text to Section 1.2.1.5 to explain better the Army’s initialselection of SBCT stationing locations in the Army’s 2002 ROD and why decisionsto station the unit at Fort Polk have been revisited since 2002. Fort Polkwas in the initial group of installations considered. It was screened out in thisEIS as unreasonable because it did not meet the criteria for SBCT stationingbecause of a lack of available maneuver land. See Section 2.4.2 of this FEIS towhich additional information has been added. Specifically, Fort Polk’s maneuverarea is committed to JRTC, one of three locations where brigades completetheir final training before combat deployment. When there are JRTC unitrotations, the majority of training areas and ranges are dedicated to thoseunits. This commitment reduces the amount of training area available for anSBCT to the extent that it is not sufficient. The EIS prepared for SBCT stationingat Fort Polk, in fact, revealed many of these difficulties.30. The DEIS fails to justify its exclusion of alternative involving land acquisition to support theSBCT’s training requirements at Fort Knox, Fort Drum, Fort Polk, or elsewhere. That militaryland acquisition requires approval, funding, and a waiver of the moratorium does not excusethe Army’s failure to consider such options. The DEIS ignores that as part of the Strykerconversion in Hawaii the Army acquired about 1,402 acres on Oahu and 23,000 acres on HawaiiIsland. Without those acquisitions, the training area in Hawaii would be only 97,300acres, far below the 105,000-acre minimum for consideration as a permanent stationing alternative.Additionally, without the MMR that is currently in dispute the deficit would includeanother 4,227 acres. The DEIS also fails to back up its claim of land availability constraintswith any hard data regarding the availability of land near Fort Knox, Fort Drum, Fort Riley,or Fort Polk that could make up for the alleged shortfall in training acreage. The Army cannotmake Hawaii a viable option by purchasing land for Stryker training and then refuse to considersimilar land acquisitions elsewhere to provide the required maneuver training land.Response: As fully explained in Section 1.5, land expansion was not considered for theother sites because it would not be purchased, let alone configured for rangesby the time the 2/25 th returns from deployment in early 2009.Table 2–10 has been updated to reflect that MMR’s 4,227 acres were not includedwithin the stated acreage figures.31. Throughout the DEIS, the Army incorporates by reference numerous documents that are notreasonably available to the public. Many documents cited in the text are not found in Chapter8’s list of references and the DEIS does not informed interested members of the public howthey can track down these sources and evaluate them during the comment period. Even wherecited documents are listed in Chapter 8, the DEIS provides no information on where the publiccan find and review copies during the comment period. Thus, in the majority of cases, theArmy failed to ensure the DEIS’ sources would be “reasonably available for inspection bypotentially interested persons within the time allowed for comment” as NEPA requires.February 2008 D–13 2/25th SBCT Final EIS