SBCT Final EIS - Govsupport.us

Appendix D ⎯ Responses to Comments on the Draft Environmental Impact Statementand alternatives in comparative form, thus sharply defining the issues and providing a clearbasis for choice among options by the decision maker and the public.”It appears that, throughout its discussion of Alternative A, the DEIS evaluated the impacts ofonly the five projects that are allegedly “unique to the needs of an SBCT” (DEIS at page 2–20; see, e.g., id, at 5–25, 5–29, 5–55, 5–61, 5–64. By misrepresenting the true extent of theimpacts of selecting Alternative A, which would involve construction and use of all projectslisted in SEIS Table 2–4, the DEIS violates NEPA’s core purposes: to ensure that “high quality”“environmental information is available to public officials and citizens before decisionsare made and before actions are taken” and “to help public officials make decisions that arebased on understanding of environmental consequences.”Response: The EIS has been updated to reflect that the 2004 FEIS is incorporated by referenceinto this document. Thus, the construction of non-Stryker specific projectsand other SBCT impacts are being taken into account by the decisionmaker.36. The DEIS has no basis for claiming “[t]he quantity of ammunition rounds fired during Armytraining on all Army training ranges would increase from 16 million to 20 million rounds peryear.” Even if the baseline for analysis of Alternative A were two IBCTs training in Hawaii(and it is not), the baseline would be less than 14 million rounds per year, with permanent stationingof the 2/25 th SBCT increasing ammunition use by over 6 million rounds (DEIS atpage 2–7). In fact, the baseline for analysis is one IBCT (the 3/25 th ) and one light infantrybrigade (the 2/25 th ) training in Hawaii, which would use even less ammunition.In addition, as noted previously, the DEIS fails to consider the impacts on human health frommilitary training and related activities introducing chemicals into the environment that wouldbe bioaccumulated by plants and animals that people consume.Response: The Army has updated Section 2.8 to reflect that No Action includes the livefireactivities of the 2/25 th ID (L) and the 3/25 th modular IBCT. It should benoted that there is virtually no change in ammunition required by the 2/25 th ID(L) and a modular IBCT. Both units utilized approximately 7 million rounds oftraining ammunition while conducting live-fire training to doctrinal standards.As far as bioaccumulation is concerned, the Army looks at offsite potential forcontamination under the Operational Range Assessment Program (ORAP).While still in the early stages of the assessment, preliminary results show nocontamination of groundwater or surface waters by explosive residues. Pleasesee Section 5.2.3.3 of the EIS.37. Light infantry brigades do not use unmanned aerial vehicles (“UAVs”). See FEIS at page 2–40 (UAVs are part of proposed changes to “current force reconnaissance training”). Consequently,inclusion of impacts associated with UAVs in the DEIS’ discussion of the No ActionAlternative on page 5–217 is improper.Response: The Army has modified the No Action Alternative, Section 2.8, in response topublic comment. This Alternative considers the 2/25 th ID (L) prior to its transformationand the 3/25 th as a modular IBCT. While the 2/25 th ID (L) does nothave UAVs, the 3/25 th IBCT does have 18 UAVs, and training of those UAVsFebruary 2008 D–15 2/25th SBCT Final EIS