SBCT Final EIS - Govsupport.us

Appendix D ⎯ Responses to Comments on the Draft Environmental Impact Statementwould not cause significant impacts — conflicts with the FEIS’ conclusion that disturbanceassociated with off-road Stryker activities would generate a net increase of about 1,602 tonsof PM10 annually, causing significant impacts (See FEIS at 8–54 to 8–55). The Army fails tojustify the DEIS’ substantial downward revision in the severity of this impact.Response: Section 5.2.11.4 of the FEIS has been updated to reflect the recalculated emissionsand impact methodology consistent with the 2004 FEIS. Several factorscombine to create the apparent discrepancy between the 2004 and 2008 analyses.The analysis in 2004 was based on several assumptions about how theStryker would conduct maneuver training, and on which areas the maneuvertraining would take place. These assumptions were used to estimate PM 10emissions from wind erosion to disturbed areas. Since the 2004 EIS, the doctrinalmaneuver-training requirement for an SBCT has been revised based onmission requirements and training experiences. In 2004, an SBCT was authorizedto execute 150,836 Maneuver Impact Miles (MIMs, See Section 2.2.5 inthis EIS and Mendoza et al. 2002 for an explanation of MIMs). That numberhas been reduced to 104,898 MIMs since the publication of the 2004 EIS, anumber that is more consistent with how SBCTs are executing training at otherSBCT stationing locations. An inflated value was used in the 2004 analysis, asthe Army had not fully shaped the doctrine or required training tasks for theSBCT at the time of the analysis. Training requirements for the SBCT is nowbetter understood, and the lesser value is used in this 2008 FEIS.Additionally, the 2004 EIS estimated 58 percent of the MIMs would be executedat PTA and the Keamuku Parcel. Actual maneuver training of the 2/25 thSBCT found that the more realistic proportion is closer to 50 percent, or52,449 MIMs, at PTA and the Keamuku Parcel.Lastly, the 2007 DEIS compared the MIMs for an SBCT to a No Action baselineof an IBCT’s authorized 49,569 MIMs. The No Action Baseline Alternativehas been adjusted to reflect a baseline of 39,320 MIMs for the 2/25 th ID(L) as is explained in Section 2.8.2.4.Therefore, the correct presentation of MIMs and the associated PM 10 emissionsfrom wind erosion of disturbed areas would calculate as:2/25 th ID (L): 13,659 MIMs at PTA, 845 tons PM 10 (No Action baseline)2004 FEIS 2/25 th SBCT: 87,749 MIMs at PTA and Keamuku, 2,447 tons PM 102008 FEIS 2/25 th SBCT: 52,449 MIMs at PTA and Keamuku, 1,463 tons PM 10Estimated increase for 2/25 th SBCT over baseline No Action: 618 tons PM 10Though the area expected to be used for maneuver training did not changefrom the 2004 to the 2008 analysis, the intensity that the land would be usedhas been reduced based on actual training experiences. The expected increaseof PM 10 from wind erosion from the 2/25 th SBCT training at PTA and Keamukuis 618 tons. Even though this estimate is lower than the 1,602 tons estimated in2004, the resulting increase in overall PM 10 level, the uncertainties associatedwith any estimate of potential wind erosion conditions, and public perceptionsof the potential magnitude of this impact, the Army considers wind erosionfrom PTA and the Keamuku Parcel to be a significant air quality impact.February 2008 D–54 2/25th SBCT Final EIS