SBCT Final EIS - Govsupport.us

Appendix D ⎯ Responses to Comments on the Draft Environmental Impact Statementhicles from one training area to another (e.g. Fountain grass from PTA toOahu training areas).Information regarding the status of invasive species and the potential projectrelatedimpacts regarding invasive species is presented in sections 5.10, 6.10,7.10, and 8.10 of the 2004 EIS. This information is summarized and, wherenecessary, updated in sections 3.1.9 and 5.2.10 in this EIS.104. On page 5–3, the DEIS states that formal consultation with the USFWS has resulted in nonjeopardyBOs for the SBCT training. USFWS Deputy Assistant Secretary Julie MacDonaldresigned May 1, 2007 amid reports of her abusing staff and tampering with science. TheUSFWS statements and studies about the SBCT made under her tenure and referenced in the2004 FEIS and 2007 DEIS should be reviewed.Response: We have no reason to believe that Ms. McDonald intervened in the consultationprocess for this action or that there were any other improprieties. We donot intend to reinitiate consultation on this issue.105. The DEIS does not disclose or otherwise indicate that detailed surveys or other studies havebeen conducted to determine if threatened or endangered species occur on PCMS. Withoutthe knowledge of whether threatened or endangered species inhabit PCMS, decision makerslack sufficient information to evaluate fully the potential effects on threatened or endangeredspecies.Response: The Army has conducted intensive biological field surveys at PCMS to maintaina working knowledge of its biological resources, even those without regulatorycompliance mandates. While the bald eagle was a listed species atPCMS when this EIS analysis began, it has since been delisted by the USFWS.Currently, no listed species or proposed species are known to occur on thePCMS. The Army is currently funding biological research at the PCMS formany species listed by state or federal agencies as species of concern or speciesat risk.106. The DEIS does not explain how the increase in training for the 2/25th SBCT on PCMS willconform to the Migratory Bird Treaty Act. The lack of information about effects to migratorybirds prevents the decision makers from making a reasoned choice among the alternatives.Response: The PCMS will remain in compliance with the MBTA. If site-specific NEPA isrequired based on the stationing decision to be made in the ROD for this SEIS,any agreements, including required coordination, consultation and/or mitigationwith the USFWS would be accomplished at that time.107. The DEIS acknowledges that training of the 2/25th SBCT could affect wildlife, but does notdiscuss those effects. The DEIS provides little or no information on how the anticipated impactswill affect individual species populations on PCMS. The DEIS also fails to disclose theamount of habitat that will be negatively impacted. The DEIS does not provide any quantitativeinformation on how training activities of the 2/25th SBCT will affect state-listed and sensitivespecies of wildlife, such as burrowing owls and mountain plovers. The DEIS fails tomake any reference to invertebrates known to occur at PCMS.February 2008 D–33 2/25th SBCT Final EIS