SBCT Final EIS - Govsupport.us

Appendix D ⎯ Responses to Comments on the Draft Environmental Impact Statementties. It also admits that further measures will be required but does not discuss how thesemeasures will be developed or implemented.Response: Additional training loads and MIMs (see Section 2.2.5) added to the traininglandscape will necessitate increased funding for reseeding, as well as forphysical measures such as erosion control dams, rock check dams, contourditches and terraces, hardened crossings, banksloping, etc. Soil structure isonly permanently destroyed by deep excavations, which are a tiny fraction ofone percent of the total land area. Those excavations are backfilled and reseededafter each rotation. The Army is also concerned with soil erosion because,among other things, gullies and soil erosion prevent the use of the landfor military maneuver.219. On pages 5–229 and 230, the DEIS fails to identify the “regional level” at which cumulativesoil erosion impacts are allegedly not “substantial” — despite the DEIS’ concession that,viewed in isolation, Alternative A would have significant impacts due to soil erosion — or tojustify its selection of whatever region that may be. Moreover, having failed to quantify cumulativesoil erosion, there is no way to compare that cumulative impact to “natural rates oferosion,” which likewise are not quantified, or to evaluate whether the cumulative soil erosionwould be significant after implementation of federal and state regulations (which are notidentified and whose effectiveness is not analyzed).Response: Based on the analysis in the EIS and the 2004 EIS, the cumulative impact forthis area would be significant. The EIS has been updated.220. There is no justification for the DEIS’ assumption on page 5–230 that projects will, in fact,implement BMPs needed to reduce soil erosion and minimize impacts on water resourcesfrom stormwater and other polluted run-off. Enforcement of construction BMPs and otherstormwater requirements is lax in Hawaii, and violations of federal, state, and local requirementswidespread.Response: The Army fully intends to implement the BMPs and mitigation measures includedin the Record of Decision for this EIS. The Army implements its own internalquality control measures to ensure protection of environmental resourcesregardless of enforcement by the state of Hawaii.221. The NPS requests that the Army consider the environmental impacts of soil compaction andrutting from the use of the Stryker vehicles specifically in the Pelekane and park areas usedfor the transport of vehicles and equipment as identified.Response: With respect to the Pelekane area, Stryker vehicles would only be used on thePTA Trail to move to and from the harbor and PTA and the Keamuku Parcel.The PTA Trail would be maintained in such a condition that rutting would bekept to a minimum. It is in the Army’s best interest to maintain the PTA Trailin good condition. The Army does not have any reason to anticipate impacts tosoils resulting from use of the PTA Trail.222. The DEIS needs to address processes in the soil: capturing water, storing water, cycling carbon,storing carbon, cycling nitrogen. These processes are very important to understandingthe soils in the grassland ecosystem at PCMS.February 2008 D–75 2/25th SBCT Final EIS