SBCT Final EIS - Govsupport.us

Appendix D ⎯ Responses to Comments on the Draft Environmental Impact StatementD.3.2 BIOLOGICAL RESOURCES101. Hawaii, with its relatively small land area and high rate of endemism, does not seem ideallysuited as the base for the SBCT. The SBCT will cause irreparable damage to the fragile ecosystemsand native species of Hawaii. These ecosystems and species are not found anywhereelse on earth. Live fire and prescribed burns will endanger the ecosystems and native floraand fauna. Any loss of individuals of these native species will be irreversible.Response: The Army consulted with the USFWS in 2002 for transformation activities onOahu and PTA in three separate Biological Assessments. The USFWS is requiredto issue either a jeopardy or non-jeopardy opinion based on the documentsand information provided by the Army. To jeopardize the continued existenceof a species is to engage in an action that reasonably would be expected,directly or indirectly, to reduce appreciably the likelihood of both thesurvival and recovery of a listed species in the wild by reducing the reproduction,numbers, or distribution of that species (50 CFR §402.02). The outcomeof both the PTA and Oahu consultations was a non-jeopardy opinion. TheUSFWS found that the benefit to the listed species and their habitats from theArmy’s Natural Resource Program outweighed the risks associated with effectsfrom training activities. Furthermore, the Army has develop ImplementationPlans that outline the management actions necessary to ensure the longtermsurvival of endangered species on Army lands in Hawaii.102. On page 3–35, the middle of the Critical Habitat paragraph states that the Army training areaswere excluded from being designated plant critical habitat because of the essential contributionthat Army-led natural resource conservation plays in the recovery of threatened and endangeredspecies. Is there a formal agreement of this arrangement with the Fish and WildlifeService? If there is one, is there a citation to this agreement?Response: There is not a formal agreement in place between the USFWS and the Armyregarding the non-designation of critical habitat. The final critical habitat designationsfor both Oahu and Hawaii Island (68 Fed. Reg. 39624, July 2, 2003and 68 Fed. Reg. 35950, June 17, 2003) discuss these decisions in the Analysisof Impacts Under Section 4(b)(2) of the designation packages.Title 16 U.S.C., Section 1533(a)(3)(B) states that critical habitat shall not bedesignated on DoD lands if the Department of Interior determines that the integratednatural resource management plan provides a benefit for the speciesfor which critical habitat is proposed for designation.103. Impacts from Range Construction on pages 5–42 and 5–45: Expanding the area where trainingwill take place beyond that which is already in use will allow alien invasive species offlora to gain a foothold in areas where they have not. New road and trails should be discouraged.If new roads cannot be avoided then the Army should consider monitoring the new areasopened up for training to see if alien species do become established.Response: The Army monitors for new invasive species on a biannual basis on all landingzones, roads, and trails. In addition, the Army has or will construct severalwash rack facilities placed in strategic locations so that soldiers may powerwash all vehicles after training concludes, and prior to moving to the nexttraining area. This will help ensure that invasive species are not moved by ve-February 2008 D–32 2/25th SBCT Final EIS