A Letter from US Army on Makua Environmental Assessment

Appendix H:

Responses to comments on Makua MR SEA

• Introduction
  The Draft Supplemental Environmental Assessment (SEA) for Routine Training at Makua Military Reservation was made available to the public on September 23, 2000. A public meeting was held at the Waianae Army Recreation Center on September 25, 2000. The primary purpose of this meeting was to inform the public of the availability of the draft SEA. In addition, it was to inform the public of the process for making comments and to answer any questions to assist them in crafting comments. A second public meeting was held at the same location per request of attendants on October 11, 2000. The purpose of this second meeting was to further inform the public, answer questions raised at the first meeting, and permit the community to ask questions that would assist them in understanding the SEA such that they would be able to provide substantive comments.
  During the second meeting, the public requested the opportunity to present oral comments. Those comments were taken, and are included in the responses below. As a result of public requests at these meetings, the public comment period, which was originally to have closed October 23, 2000, was extended to November 6, 2000.
  The following is a summary of issues and concerns expressed in the comments received from the public, and the Army's responses thereto.
• 1. Protect Makua - Stop the bombing!
  Although aerial bombardment from ships and aircraft was conducted at Makua in the past, the Army is not proposing to conduct any such activities in the Proposed Action, nor does it foresee any future conditions in which bombing might be conducted. The weapons to be used at Makua are listed in Table 2-1 of the SEA. The Proposed Action is the resumption of live-fire training at Makua, but at a mitigated level to reduce environmental risks. Current environmental programs, including natural and cultural resource management and wildland fire management, would be expanded to better protect rare species and other native flora a fauna, and cultural resources.
• 2. Why didn't the Army prepare an Environmental Impact Statement (EIS) rather than an Environmental Assessment (EA)?
  There were many reasons the Army opted to conduct an Environmental Assessment to evaluate the viability of the Army being able to train at the Makua Military Reservation. When the Army suspended training at Makua Military Reservation in 1998, it took additional steps to manage and preserve the environmental and cultural resources of Makua Valley. These additional steps included Section 7 consultation with the U.S. Fish & Wildlife Service for the preservation of threatened and endangered species, and a WildLand Fire Management Plan designated to reduce and potentially eliminate the risk of damage to the Makua Valley from fires of any origin. The Army also began Consultation with the Hawaii State Historic Preservation Division, the Advisory Council on Historic Preservation, the Office of Hawaiian Affairs, and representatives of the Waianae community to develop a Programmatic Agreement under Section 106 of the National Historic Preservation Act for the protection and management of cultural resources.
  It was the Army's opinion that the concentrated efforts of the Army along with the various federal and state agencies in developing environmental and cultural programs would enhance Makua Valley and ensure that the impact of training would not adversely or significantly impact the environment and its treasured resources. The Army is committed to mitigate as necessary to preserve, manage, and enhance all of the Makua Military Reservation (4,190 acres), not merely the 1034 acres of trafficiable maneuver area where the training occurs.
• 3. There was insufficient public involvement with the Leeward Oahu community.
  The Army made substantial efforts to involve the community in the ongoing activities at Makua both prior to and during development of the SEA. The Army held Open Houses at Makua, community meetings with the Native Hawaiian Community on the Waianae Coast to develop cultural resources programs, published various news articles, and conducted a Community Relations Program organized by the Army's Public Affairs Office.
  The Army conducted meetings on September 25 and October 11, 2000 to inform the public of the release of the Draft SEA and to solicit their input, comments and conserns so that these could be incorporated in developing the SEA.
• 4. The Community is denied access to cultural resources at Makua.
  The Army has been working with the Native Hawaiian community on the Leeward Coast for more than two years to allow access to Ukanipo Heiau at Makua. A programmatic Agreement for the cooperative management of the heiau was signed on October 12, 2000.
  In addition, the public has been allowed to tour cultural sites within Makua. A survey of traditional cultural places is in progress and members of the community are being allowed access to Makua to identify these sites. The presence of unexploded ordnance (UXO) throughout portions of Makua makes it unsafe to allow the public unrestricted access to the entire installation.
  Currently the amount of actual UXO at MMR is unknown. The Army has made several attempts in the past to clear unexploded ordnance on portions of Makua. The Army acknowledges the continued existence of UXO in portions of MMR and recognizes its ongoing obligation to ensure the safety of both the service member and the public.
• 5. The SEA did not adequately address community values, Hawaiian gathering rights, and religious practices and spiritual places.
  The SEA has been revised to include this information.
• 6. The SEA did not adequately address community concerns regarding increased traffic, transport of ammunition through the community and the safety of the community and schools.
  Transportation of all hazardous materials through communities will be performed strictly within safety regulations consistent with the type of ammunition transported. The Army's movement to and from Makua will be minimal.
• 7. The Army is withholding and / or disregarding information about traditional cultural places and religious and cultural practices at Makua.
  The cultural resources section has been revised and expanded to address these concerns. In addition, a survey for traditional cultural places at Makua is currently being conducted and the results will be made available to the community when it is concluded.
• 8. The Army should return Makua to the community. It should begin cleaning up the property prior to returning it at the expiration of its lease.
  Eventual disposition of Makua is not an appropriate subject to be addressed by this SEA. The Army has both a need and a legal right to use land at Makua. At such time that the U.S. Government no longer has a need for Makua, disposition and cleanup would be the subject of a separate NEPA document.
• 10. Clean up Makua.
  The cleanup of Makua cannot be accomplished concurrent with its use for training. The Army is making concerted efforts to ensure that training at Makua is safe for soldiers, and protective of the public and the overall environment. Eventual disposition of Makua is not an appropriate subject to be addressed by this SEA. The Army has both a need and a legal right to use land at Makua. At such time that the U.S. Government no longer has a need for Makua, disposition and cleanup would be the subject of a separate NEPA document.
• 11. The Proposed Action may harm threatened and endangered species at Makua.
  Resumption of limited training includes measures that incorporate additional restrictions, wildland fire management, and stabilization of endangered species. Based on these measures, the U.S. Fish and Wildlife Service stated that the continued existence of endangered species will not be jeopardized. In addition, natural resources management and a species stabilization program have been enhanced to protect all endangered species; this will result in an ecological environment superior to existing conditions.
• 12. The Proposed Action introduces into or continues the presence of hazardous materials in the soil and water at Makua.
  The proposed action, resumption of training at a reduced level, coupled with the fact that that open burning/open detonation (OB/OD) operations ceased in 1992 will minimize the amount of hazardous materials that will be introduced into the soil and eventually the water at Makua. OB/OD sites are normally the sites with highest level of soil contamination on a range. While some soil samples from the former OB/OD sites exceeded desired criteria for some substances, it is estimated through computer models that it will take at least 2000 years for these contaminants to migrate from the soil to the groundwater and reach the installation boundary. Nonetheless, in response to public concerns about the modeling used, the Army is going to coordinate with the EPA and the public to implement a long-term groundwater monitoring program to address public concerns about contamination at Makua. The Army has also prepared a separate Environmental Assessment to look at phytoremediation as a potential technology for removing hazardous chemicals from the soil at the former OB/OD site. Phytoremediation uses plants to breakdown and/or biologically uptake contaminants from the soil. This pilot project will examine the use of native Hawaiian plants in the phytoremediation process.
• 13. The OB/OD EA was not made public.
  A Draft Environmental Assessment (EA) for the OB/OD Phytoremediation Demonstration Project was prepared and distributed for public review from September 8 through October 8,2000. The review period was publicized in the State Office of Environmental Quality Control's (OEQC) bulletin, The Environmental Notice. The availability of the Draft EA for public review was also publicized in a public notice in the Honolulu Advertiser and Star Bulletin along with the announcement of a public information meeting on the proposed action. The public information meeting was held in Waianae on September 11,2000. Copies of the Draft EA were also made available for public review at the Waianae Public Library and at OEQC. The final EA documentation will also be made public when completed.
• 14. The people of Waianae deserve redress for damage caused by military activities.
  The Army's use of Makua is in accordance with applicable laws and regulations.
• 15. The public comment period was inadequate.
  The Draft SEA was originally distributed with a publicized 30-day comment period. The comment period was publicized in the OEQC bulletin, The Environmental Notice and in the Honolulu Advertiser and the Honolulu Star Bulletin. Subsequently, at the request of the public, the comment period was extended by two additional weeks. This extension was publicized in the Honolulu Advertiser and Star Bulletin.
  

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• 56. Many comments were received that may be characterized as supportive in nature. They are noted and following is a summary of their content.
  
  • If the Army cannot adequately train its personnel, it may have to leave the Islands. This would have a negative economic impact, and might lead to loss of such community support as rescue, firefighting and helicopter medical evacuation. The presence of the Army in Hawaii is also critical for defense of American and allied nation interests in the Pacific.
  • The Environmental Assessment adequately addresses the concerns of the community, and is in compliance with the Endangered Species Act and the National Environmental Policy Act.
  • Makua is the only site available on Oahu capable of conducting company-level live-fire collective training, and is also needed to support Marine Corps, Air Force, Army Reserve and National Guard training.
  • The Army has subsequently reduced the scope of its training activities to minimize impacts on the environment.
  • Conducting training at Pohakuloa or on the mainland is too expensive.