SBCT Final EIS - Govsupport.us

Appendix D ⎯ Responses to Comments on the Draft Environmental Impact Statementwash rack facilities placed in strategic locations so that soldiers may powerwash all vehicles after training concludes, and prior to moving to the nexttraining area. In addition, prior to training events at PTA all Soldiers are providedwith environmental awareness training that addresses the issue of invasivespecies (PTA external SOP). This will help ensure that invasive speciesare not moved from one training area to another (e.g. Fountain grass fromPTA to Oahu training areas).172. On page 5–22, the DEIS misleadingly overstates the effectiveness of the Army’s IntegratedWildfire Management Plan (IWFMP). As discussed in the enclosed declarations of John MichaelCastillo, even if the IWFMP were fully funded and implemented (which is unlikely), itstill would be inadequate to prevent catastrophic fires associated with SBCT training. SeeDeclaration of John Michael Castillo, Ilioulaokalani Coalition v. Rumsfeld, Civ. No. 04-00502 DAE BMK (D. Haw. Dec. 15, 2006). with Exhibits “48” to “56;” Supplemental Declarationof John Michael Castillo, Ilioulaokalani Coalition v. Rumsfeld, Civ. No. 04-00502DAE BMK (D. Haw. Dec. 18, 2006), with Exhibit “A.”Response: The Army does not believe that it overstated the effectiveness of the IWFMP.The Army is fully implementing the IWFMP and plans to continue implementingthe IWFMP. As stated in Section 5.2.4.3, although mitigation will considerablyreduce wildfire risk, the impacts from wildfire may not be reduced to aless than significant level. The Army has taken into account all the declarationsand exhibits filed in the litigation cited. The District Court found that theclaim of increased potential for fire was not a forgone conclusion and wasspeculative at best.173. The DEIS’ claim on page 5–184 that wildfire management impacts under the No Action Alternativecould be mitigated to “less than significant” is inconsistent with the 2004 FEIS’conclusion that “fire impacts on sensitive species” under No Action would be “significant andnot mitigable to less than significant.” (FEIS at page 4–75). The DEIS fails to justify itschange from the Army’s earlier analysis.Response: Section 5.5.4.1 and Table 5–55 have been updated to reflect that impacts fromincreased wildfire risk are significant.174. The NPS recommends close coordination with the Park Service and other agencies to ensurethat wildfire emergency response planning is in place with appropriate agreements for mutualaid made current.Response: The Army is coordinating with the NPS on a number of issues and will consultwith the NPS to understand better the concerns related to wildfire emergencyresponse and planning. A good network of interagency cooperation in preventing/suppressingwildfires exists on the Island of Hawaii and the Army looksforward to continued close coordination of its natural resources management/wildlandfire programs with National Park Service personnel. In addition,in August 2007, a mutual aid agreement was established between the U.S.Army and Hawaii Department of Land and Natural Resources, Division ofForestry and Wildlife. Mutual aid agreements already exist between the U.S.Army and Navy Federal Fire Department. Interagency support and coordinationhas increased and shall continue to progress as the Army pursues commongoals and objectives in wildland fire suppression.February 2008 D–58 2/25th SBCT Final EIS