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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 Proposed Action will not result in a large increase in maneuver activitiesat PCMS. One m<strong>us</strong>t keep in mind that the Proposed Action involves the exchangean IBCT currently stationed at Fort Carson with the 2/25 th <strong>SBCT</strong>. Theoverall increase in maneuver training impacts at PCMS would be muchsmaller than adding a whole new brigade and all of its vehicles. This m<strong>us</strong>t beunderstood in conjunction with the assessment of impacts in this <strong>EIS</strong>. The Regional404 Permit addresses measures to repair damage. It is renegotiatedand renewed every five years. Military training does not violate the terms ofthe Regional Permit. Section 3.6.1 of the Pinon Canyon Maneuver Site Transformation(USACE 2006d) details procedures and measures the Army takes toadhere to the regional 404 NPDES permits.151. On page 5–19, the D<strong>EIS</strong> fails to take a hard look at the potential for groundwater contamination.Past studies have found “significant levels of RDX,” which is “known to migrate togroundwater,” from military training at Schofield Barracks and PTA, but the Army has failedto evaluate the potential for groundwater contamination from increased training associatedwith permanent stationing of the 2/25th <strong>SBCT</strong>. The Army m<strong>us</strong>t investigate the potential forall training-related contaminants, not only explosives, to impact groundwater. Moreover,there is no j<strong>us</strong>tification for the D<strong>EIS</strong> to limit its disc<strong>us</strong>sion of groundwater to only PTA, asthe 2/25th <strong>SBCT</strong> would train at ranges on Oahu as well.Response: The statement in Section 5.2.3.3 that “due to the depth of groundwater…andthe relatively low concentrations of explosives residues in soils” has been revisedto include Oahu ranges as well as PTA. The Army has started an assessmentof offsite potential for contaminants at Schofield Barracks and Makuaunder the Operational Range Assessment Program at (ORAP). While stillin the early stages of the assessment, preliminary results show no contaminationof groundwater or surface waters by explosive residues.152. “Regulatory Administrative Mitigation 2” on page 5–174 makes no sense. There are no“standard construction BMPs” or “land management practices” in the preceding disc<strong>us</strong>sion of“Impacts from Cantonment Construction.” (See D<strong>EIS</strong> at 5–173).Response: Section 5.5.2.1.2 has been updated to include the mitigation measures.153. The statement on page 5–176 that the Helemano Trail “would be constructed under the NoAction Alternative” conflicts with the disc<strong>us</strong>sion in Chapter 2 identifying the Helemano Trailas “unique to the needs of an <strong>SBCT</strong>.” (D<strong>EIS</strong> at page 2–20). Since there would be no <strong>SBCT</strong> inHawaii under the No Action Alternative, there would be no reason to build the HelemanoTrail.Response: The disc<strong>us</strong>sion in Section 5.5.2.1, Impact 6 has been changed to reflect that noconstruction would occur at the Helemano Trail under the No Action Alternative.154. It is unclear why the D<strong>EIS</strong>’ disc<strong>us</strong>sion on page 5–179 of potential impacts on water qualityunder the No Action Alternative includes <strong>us</strong>e of the Dillingham Trail, which the D<strong>EIS</strong> identifiesas “unique to the needs of an <strong>SBCT</strong>.” (D<strong>EIS</strong> at page 2–20; see also id. at 5–180, 5–205).February 2008 D–51 2/25th <strong>SBCT</strong> <strong>Final</strong> <strong>EIS</strong>

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