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SBCT Final EIS - Govsupport.us

SBCT Final EIS - Govsupport.us

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Appendix D ⎯ Responses to Comments on the Draft Environmental Impact StatementResponse: All references were available at the Army Environmental Command. Uponmaking certain references available to requestors, the Army invited those requestorsto submit additional comments and provided them additional time todo so.32. On page 1–7, the D<strong>EIS</strong> overstates the effectiveness of the Stryker vehicle in providing protectionto U.S. soldiers. Experience in Iraq has shown that Strykers are much more vulnerablethan previo<strong>us</strong>ly assumed.Response: The experience of Strykers in Iraq has been noted in the F<strong>EIS</strong> at Section1.2.1.5. The Army is facing a resourceful and committed opponent in Iraq andm<strong>us</strong>t change tactics in response to enemy insurgents who would do U.S.Forces harm. The <strong>SBCT</strong>s have and continue to prove their effectiveness in ongoingoperations. In its 29 December 2006 Order, the District Court reviewedall the evidence that the Stryker vehicle does in fact save Soldier’s lives.33. On page 2–22, the D<strong>EIS</strong> states that under Alternative A the 2/25 th <strong>SBCT</strong> would conduct 105mm MGS qualifications on PTA range 11T. This represents a significant shift from pastArmy statements about training at that facility where the Army said <strong>us</strong>e of the training facilitywould be temporary, serving only to ready the 2/25 th <strong>SBCT</strong> for deployment by November2007. The D<strong>EIS</strong> did not analyze the impacts of training with the MGS at Range 11T. If theArmy intends to conduct such training in the future, the D<strong>EIS</strong> m<strong>us</strong>t provide a detailed analysisof the training that is proposed and its impacts.Response: Range 11T was <strong>us</strong>ed temporarily in accordance with the U.S. District Court’s29 December 2006 Court Order. If Hawaii is selected as the permanent stationinglocation for the 2/25 th <strong>SBCT</strong>, construction would commence on thePTA BAX, which would be located in part on top of Range 11T. Prior to completionof the PTA BAX range 11T would still be <strong>us</strong>ed temporarily. Beca<strong>us</strong>ethe <strong>EIS</strong> analyzes the impacts of firing with the MGS on the PTA BAX, it includesthose impacts that would occur on range 11T.34. On page 2–23, the D<strong>EIS</strong> states the <strong>SBCT</strong> would <strong>us</strong>e the WPAA for “live-fire operations.”This is a significant change from the 2004 F<strong>EIS</strong>, which stated the WPAA would be <strong>us</strong>ed foronly non-live-fire maneuvers (pages 2–12 and 2–37). If the Army intends to conduct live-fireoperations in the WPAA, the D<strong>EIS</strong> m<strong>us</strong>t provide a detailed analysis of the training that isproposed and its impacts. Given the cultural sensitivity of the WPAA, live-fire training thereclearly would ca<strong>us</strong>e significant impacts, which the Army is obliged to disclose.Response: The text in Section 2.5 of the F<strong>EIS</strong> has been updated to reflect that the Armyhas no plans to conduct live fire at WPAA.35. On page 5–22, the D<strong>EIS</strong> improperly fails to evaluate impacts associated with range constructionat KTA and KLOA. The D<strong>EIS</strong>’ claim that “[n]o <strong>SBCT</strong>-specific range construction”would be necessary at these locations cannot be squared with the F<strong>EIS</strong>, which identifies“<strong>SBCT</strong>” construction projects there (F<strong>EIS</strong> at page 2–24), or with the Modular Force EA,which said “[n]o new range construction would be required” to convert the 3/25 th into anIBCT (Modular Force EA at page 1–13). Since Alternative A would require all projects listedin S<strong>EIS</strong> Table 2–4 to be constructed, the D<strong>EIS</strong> m<strong>us</strong>t disclose the impacts of all of these projectsto comply with NEPA’s mandate to “present the environmental impacts of the proposalFebruary 2008 D–14 2/25th <strong>SBCT</strong> <strong>Final</strong> <strong>EIS</strong>

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