SBCT Final EIS - Govsupport.us

Appendix D ⎯ Responses to Comments on the Draft Environmental Impact StatementThe 2004 Transformation FEIS states impacts from construction and trainingactivities on general habitat and wildlife would be less than significant (2004FEIS Table 4–10 at page 4–70). This is consistent with the determination displayedin Table 5–13 in this FEIS and the supporting text in Section 5.2.10.The DEIS fails to justify the Army’s new claim that SBCT training in Hawaii would notcause significant impacts to biological resources. Moreover, the internal inconsistencies inthe DEIS contravene NEPA’s command to provide “a clear basis for choice among options.”Response: This FEIS reports significant impacts to sensitive species and their habitats atPTA from range construction, live-fire training, and maneuver training (Table5–13). This is consistent with the determination of significant impacts at PTA inthe 2004 Transformation FEIS (Table 8–22 at page 8–161).The expected impacts to biological resources are explained in Section 5.2.10,and correctly displayed in Tables 5–2 and 5–13. PTA is the only training areawhere significant impacts to a biological VEC (wetlands, vegetation, noxiousweeds, threatened and endangered species, and general wildlife and habitats)are expected. Impacts to the other areas (SBMR, DMR, and KTA/KLOA) areconsidered significant but mitigable to less than significant. As discussedabove, sensitive species may be impacted by wildfires, and those significantimpacts are presented in Section 5.2.4.110. The DEIS’ claim on page 5–206 that impacts to listed species under the No Action Alternativecould be mitigated to “less than significant” is inconsistent with the 2004 FEIS’ conclusionthat “fire impacts on sensitive species” (which include listed species) under No Actionwould be “significant and not mitigable to less than significant.” (FEIS at page 4–75). TheDEIS fails to justify its change from the Army’s earlier analysis.Response: Impacts to listed species from wildfire would indeed be significant for the NoAction Alternative. There has not been a change in the analysis of the No ActionAlternative. Tables 5–52, 5–55, and the text in Section 5.5.4 has been revisedto be consistent with the 2004 Transformation FEIS.111. The NPS recommends consultation with appropriately qualified resources staff on the issuesof potential biological impacts to resources. The issue of the introduction and spread of alienand invasive species and their impacts on resources and conservation biodiversity is a veryhigh priority for the NPS.Response: The Army intends to continue to coordinate with NPS. As noted in the responseto comment 68, the Army monitors for new invasive species on a biannual basison all landing zones, roads, and trails. In addition, the Army has or willconstruct several wash rack facilities placed in strategic locations so that Soldiersmay power wash all vehicles after training concludes, and prior to movingto the next training area. This will help ensure that invasive species are notmoved by vehicles from one training area to another (e.g. Fountain grass fromPTA to Oahu training areas).112. The DEIS fails to disclose the very fragile nature of the soils in the grassland ecosystem.Southeastern Colorado was devastated during the great dust storms of the depression. BothFebruary 2008 D–36 2/25th SBCT Final EIS