SBCT Final EIS - Govsupport.us

Appendix D ⎯ Responses to Comments on the Draft Environmental Impact StatementResponse: The Army feels that its description of the baseline conditions at PCMS adequatelydescribe the current environment for purposes of assessing impacts relatedto the Proposed Action. We thank you for your comment. No changes tothe document have been made but your comment has been added to the administrativerecord for this process.D.3.3 CULTURAL RESOURCES121. Mitigation for cultural resources relies on Programmatic Agreements that are not spelled outin the DEIS. The PAs do not appear to address prevention specifically, but rather depend onidentifying and cataloguing the resources after the damage has been done. This mitigation isnot strong enough to protect cultural sites adequately.Response: The Programmatic Agreement for the action in Hawaii is included at AppendixJ of the 2004 Transformation EIS. The PA for the Transformation of the 2/25 thID (L) to the SBCT relied on extensive survey and identification efforts prior toearth disturbance. Per stipulation IV.E.(5) of the PA, the primary mitigation isavoidance. Sites that were identified on the ground and/or brought to the attentionof the Army through consultation were marked off limits and the identifiedsites were taken into consideration in the design of the projects andavoided through changes to project layout. The identification efforts includedsurvey, archival research, and meetings with Native Hawaiian groups and individualsover a period of two years prior to signing of the ROD for the 2004FEIS and the beginning of earth disturbing activities. Cultural monitors wereused to aid in the protection of inadvertent discoveries.122. The Army needs to include cultural training for its personnel so they can be more sensitive tothe importance of the cultural history to native Hawaiians.Response: The Army provides training for their personnel using posters and brochures,briefings to officers and senior noncommissioned officers, and training of Soldiersin cultural awareness before military training events. For example, allCommanders of units training at PTA must follow the requirements of theUSAG-HI’s PTA External Standard Operating Procedure (SOP). This SOPidentifies areas of PTA with sensitive archaeological sites and restrictions thatUSAG-HI established to protect the sites. These restrictions include limitationson the use of vehicles, avoidance of rock structures, and limitations on diggingof fighting positions.123. The Army has failed to complete a survey of the archaeological and culturally significant featuresin the areas that would be directly affected by expansion of facilities. Without a completesurvey, construction of facilities for and training of the SBCT would destroy importantculturally significant sites, like Heiau Haleauau. By not completing the surveys, the Army hasfailed to fulfill its contractual obligations to monitor and document the effects of the SBCTon Hawaiian culture as outlined in the PA.Response: The Army completed surveys of all construction footprints prior to the awardof any earth disturbing projects in compliance with 36 CFR Section 800.4. Theidentification efforts included survey, archival research, and meetings withNative Hawaiian groups and individuals over a period of two years prior toFebruary 2008 D–39 2/25th SBCT Final EIS