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SBCT Final EIS - Govsupport.us

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Appendix D ⎯ Responses to Comments on the Draft Environmental Impact StatementResponse: The <strong>EIS</strong> does not state that all of the newly documented cultural sites havebeen avoided. Two previo<strong>us</strong>ly undiscovered petroglyph rocks were damagedduring UXO clearance at the BAX. None of the activities undertaken by theArmy at the BAX has damaged the Haleauau Heiau. Disc<strong>us</strong>sion of theHaleauau Heiau has been added to Section 3.1.4.1. Other range projects didnot impact inadvertent finds. At least two petroglyphs at the SBMR BAX weredamaged by UXO clearance. These petroglyph boulders had been embedded inthe earth and were not visible during pedestrian survey. The blades of thebulldozers did minor damage to the boulders on which the petroglyphs werelocated as shown in the photos below. The boulders were marked with fencingto protect them from further damage and currently remain in their original locationsuntil decisions are made on their long-term treatment. Disc<strong>us</strong>sion ofthe impacts to the petroglyph rocks has been added to Section 5.2.5.2.The survey standard is to make a reasonable and good faith effort to identifyhistoric properties in the area of potential effect. We made a good faith effortas documented in our record of consultation.130. While the D<strong>EIS</strong> asserts on page 5–231 that the Army is engaged in “ongoing consultationwith Native Hawaiian groups to…assure access to sacred areas,” the reality is that the Armyhas virtually eliminated opportunities for Native Hawaiians to maintain the connection to sacredsites on Army lands that is necessary to perpetuate the Hawaiian culture, inflicting significantharm.Response: In accordance with the PA, the Army has and continues to allow access to sacredsites subject to military operational requirements, security conditions,and other pertinent circumstances, such as safety.131. OHA questions whether the Army understands the importance of cultural resources to the NativeHawaiian people and the Army’s legal responsibilities under the NHPA when undertakingactions. Statements on page 5–26 indicate that the Army believes that monitoring of culturalsites after training activities have occurred to identify impacts to cultural resources andthen adj<strong>us</strong>ting protective measures is adequate mitigation. Trying to protect something aftertraining has destroyed it is not a protection plan or mitigation. Also, the D<strong>EIS</strong> does not addressa process that will provide access not only to cultural sites, but to natural resources fortraditional gathering purposes. <strong>Final</strong>ly, the D<strong>EIS</strong> is making assertions without fully identifyingthe quantity, quality, and scope of cultural components and resources in the traditionalcultural landscape. This needs to be fleshed out in more detail.Response: OHA is a concurring party to the PA, which provides for monitoring on aregular basis to identify impacts from training. As necessary, protective measures,such as flagging, fencing, berms, keeping vehicles on roads in sensitiveareas, putting up signage etc., have been and will continue to be implemented.The Army has been working diligently with the Hawaiian community to identifythe quality, quantity, and scope of cultural components on the landscape.Those components that have been shared with the Army are taken into considerationwhen projects are executed. The Army will adhere to the measures inPA, and they are incorporated in the mitigation measures presented in Section5.2.February 2008 D–44 2/25th <strong>SBCT</strong> <strong>Final</strong> <strong>EIS</strong>

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