Transformation of the 2nd Brigade 25th Infantry Division [L] to a Stryker Brigade Combat Team in Hawaii (TPD0802026)

18. Page 1–6 of the DEIS states  that  Hawaii  is  a  good  site  because  it  replicates  the  terrain and conditions found in many parts of the Pacific  Rim.  The  DEIS  needs  to  evaluate  the ability of Strykers to function in jungle terrain. Aren’t the Strykers  best suited to urban combat?

Response: Strykers are designed to be versatile vehicles capable of  conducting  missions across the full spec/rum of military operations from  peacekeeping  to  combat. 71re DEIS indicated that in its original selection as a stationing location, Hawaii provided the advantages of offering training environments and terrain similar to those found  in other Pacific  Rim nations . 71ris statement  was not  in­ ended  to apply to the jungle, but rather the complex and challenging  terrain of the Pacific Rim nations, which are dolled  with urban development through constrained terrain. As stated in Section J.2. I.5, the SBCT is designed for non­ contiguous contingencies and is ideally suited for small-scale urban opera­tion.

19. Page 1- 9 of the DEIS states that sealift capability is a critical component. of strategic mobility. The EIS needs to address how this affects the choice of locations.

Response: The Army has added some additional language to Section 1.1.1.9 to clarify further how ii considered  sealift as part  of  this discussion. Strategic  deployment factors, such as aircraft and sealift, are being considered in the decision­ making process. Sealift affords the Army the opportunity to transport large amounts of equipment in the most cost effective manner. The absence of sealift does not preclude an alternative from being considered, however, it enhances aspects of strategic mobility and is considered favorably across alternatives.

20. Is the analysis presented in the DEIS really objective? Adm. Timothy Keating stated in late May that the Stryker brigade will come back to Hawaii. Also, Senator Inouye announced to the news media that he had been assured that Hawaii would get one SBCT. The Army needs to provide evidence of objectivity of its analysis and decision-making.

Response: The EIS is objective. No decision has been made on the permanent stationing ofthe2125′,,SBCT. No final decision will he made until the  Record of Decision is signed.

21 A sentence in the ..Dear Reader” letter states that public opinions for or against the Proposed Action seldom have any bearing on the criteria the agencies must use to make decisions regarding proposals . This statement, coupled with the Army’s past actions, give the  impression that the Anny will go forward regardless of public opinion.

Response: Public input about the Proposed Action and its ejfecrs are critical to  the Army’s NEPA analysis. The Army relies on information generated in the public participation process to help make sure all alternatives and impacts are properly considered. Mere expressions of support or opposition, without more detail or information, are not especially helpful. Specific questions and comments are extremely helpful and will improve the NEPA process. We should have made this clearer. We certainly were not trying to discourage public participation or implying that the Army will disregard any public comments received.

22. The Anny should not be allowed to expand the PCMS to accommodate the SBCT. The use of eminent domain to acquire land for the expansion of PCMS is not right. The Army cannot take care of the land it already has at Fort Carson and PCMS and the ground suffers irreversible damage from the training maneuvers. The land is too fragile to use for the SBCT.

Response.· This FEIS looks at installation training areas as they are today and does not consider the possibility of future land acquisition as part of the decision making process for where 10 station the SBCT The military land acquisition process is a lengthy process Jha, is very similar to military construction. To complete the process and prepare the land for training would take a minimum of five years and often much longer. A military land acquisition project must first be approved and funding must be appropriated. Environmental surveys and studies must he completed before any real estate transaction may begin. The entire process would take 100 long to meet the permanent stationing needs and requirements of the 2/25th SBCT and therefore the Army did not consider expansion of land holdings at an installation when selecting iJs Preferred Alter­ native in the Final EIS. Text, has been added to FEIS Section l.5 in response to this comment.

With regard  to  PCMS, Congress is in the  process  of  withholding  funds  for expansion-related efforts and establishing reporting requirements that must be met before an expansion decision may be made. PCMS has supported the use of tracked and wheeled vehicles for 22 years now, in accordance with the Army’s land management programs. Fort Carson has directed considerable resources toward the restoration of PCMS and takes great pride in its ability to sustain and preserve the environment while its Soldiers conduct military training. While the Stryker is heavier than the JBCT’s light and medium trucks it would be replacing, Fort Carson would use existing institutional land management programs to manage the training impacts appropriately to minimize long-term effects if it were selected/or SBCT stationing.

23 The DEIS fails to take a “hard  look”  at  potential  environmental,  archaeological,  historical, and socioeconomic impacts to PCMS. Impacts are stated as obvious generalities without any attempt at quantification or discussion or are stated in a  manner  intended  to mislead the  public into believing they are insignificant. The DEIS contains no detailed information about the frequency of training exercises at PCMS associated with the 2/2511, SBCT, the duration of proposed training exercises, the weapons and equipment  lo  be employed  in training exercises, or the numbers of troops that will train at one time. The DEIS does not disclose or make use of  the  best available scientific  information  to analyze   impacts. There is no disclosure  of  any monitoring data, n:search, or analysis  in  the  DEIS. The  DEIS  does  not evaluate  the efficacy of the proposed mitigation measures.

Response: The purpose of this EIS is to present a comparative analysis of the Proposed Action and alternatives. /1 therefore includes the level of detail 1hat is  necessary to perform that analysis and to inform the decision maker of the environ­ mental trade-offs among alternatives. Section 2.7 describes the training that would occur al PCMS and Section 5.4 includes a detailed look al PCMS impacts. Chapter 5 and Chapter 8 provide references to the  basis for  the  analysis. Chapter 5 also discusses specific mitigation measures.

Impacts were stated in terms that are more general al Colorado training locations because the Army has no monitoring data on impacts of Stryker at Fort Carson or PCMS. The Army must therefore estimate the projected impacts at Fort Carson and PCMS from other SBCT training sites. Mitigation measures implemented by the /TAM Program and by Environmental Division resource management personnel have been largely successful lo this point in time. Fort Carson and PCMS would receive more funding/or institutional programs be­ cause of the increased MlMs of the SBCT. Given the success of its institutional programs in the past, the Army concludes that it could manage the impacts of the SBCT al Fort Carson and PCMS.

24. The DEIS fails to acknowledge !hat PCMS does not have the capacity to support the training of the l125a SBCT. Before November· 2005, the Army issued reports that concluded that PCMS lacks sufficient capacity to train the number of troops currently stationed at Fort Car­son.

Response: According to Army training doctrine, there is a shortfall of training  land  at PCMS. The exact extent of this shortfall with an SBCT replacing 1he IBCT currently stationed at Fort Carson is shown in Table 2- /0 . It is important 10 note that under Alternative C of this EIS, the SBCT would replace an IBCT. and the net number of Brigades at Fort Carson  would  not  change.  The  stationing  of the 2125¹¹‘ SBCT at  Fort  Carson  would  involve a  slight  increase  in the overall amount of required maneuver training that is scheduled to take place at Fort Carson and PCMS following the implementation of BRAC legislation and GDPR.. While this shortfall poses some training risk, this slight increase can be managed as discussed in Sections 2. 7 and J.4 .6. Locations with manage­ able shorrfall of maneuver land and acceptable risk are presented in Section 1.4.

25. The DEIS docs not adequately evaluate the effects of stationing the 2125^th SBCT at Fort Richardson or Fort Carson. Should the SBCT be stationed in Alaska, an UAC, an MPMG, larger barracks, additional administrative office buildings, and nearly 30,000 square yards of vehicle parking space would have to be constructed at Fort Richardson. Similar construction would be needed at Fort Carson. The DEIS does not include any  description  of  how  and  where these SBCT-related projects would be constructed and does not analyze the effects of these activities. Instead, it merely states that if Fort Richardson or Fort Carson is selected, additional site-specific NEPA analysis would be prepared. Site-specific  effects  must  be evaluated and disclosed in this EIS, not future NEPA documents.

Response: More detail has been added to the sections discussing stationing of the SBCT in Alaska and Colorado.

26. The Anny must address inconsistencies and conflicts between this DEIS and other NEPA documents it has released. The assessment of effects for some resources in Hawaii, such as land use/recreation has changed since the 2004 Transformation FEIS to be less than significant instead of significant. Similarly, the No Action Alternative in the 2004 FEJS would cause significant effects to noise and wildfire management. However, the No Action Alterntive in this DEIS would have higher effects to cultural resources, land use/recreation, and air­ space and effects to noise and wildfire management would no longer be significant. The Growth DPEIS identifies only one significant impact (air quality) associated with stationing an SBCT in Colorado, but this DEIS claims stationing an SBCT in Colorado would result in significant  effects  to  soil  erosion,  wildlife  management,  cultural  resources, and  threatened and endangered species.

Response: The Army has remained consistent in it.s analysis presented in this EIS and the Programmatic EIS for Army Growth and  Force  Structure  Realignment  (2007). It must first be recognized that the two analyses do not evaluate the same actions. This EIS evaluates the impacts that would result when an IBCT .is ex­ changed for the 2/]J”‘ SBCT. Analysis in the PEIS evaluated the impacts that would be associated with the stationing of a whole new SBCT. Secondly, the statement that the analysis of the PEIS for Army growth only identified one significant impact in Colorado associated  with the  stationing  of the SBCT,  this is not accurate. In fact, the EIS for Army growth found that there would be significant impacts to soils, biological resources, air quality, socio-economics, and traffic. Additional significant impacts were cited at the Pinon Canyon Maneuver Site. This assessment and the PEJS are, in fact, consistent.

The Army feels that analysis presented in Chapter 5 of the FEJS adequately portrays the impacts. Section 5.2.6 presents impacts for land use and recreation associated with the stationing of the 2125′ SBCT in Hawaii. No residential areas, schools, hospitals. or businesses would be significantly impacted by the implementation of the Proposed Action in Hawaii. Impacts from construction and range use would be localized to the vicinity around the ranges. In addilion, there are only minor impacts to hunting or other recreational activities anticipated as part of this EIS evaluation. These reasons have led the Army to assess impacts to Land Use and Recreation as mitigable/e to less than significant.

The Army assesses the environmental impact of the No Action Alternative in Section 5.5 of the FEIS. This section has been updated to reflect the latest in­ formation and analysis the Army has conducted as part of this process based on the No Action Alternative presented in this EIS. The Army feels that analysis presented in Sec/ion 5.5 identifies the appropriate level of impacts associated with each VEC.

27 The Army failed to consider a reasonable range of alternatives by limiting alternative stationing locations to just Colorado and Alaska. The Growth DPEIS identifies four other installations that could station an additional SBCT: Fort Bliss, White Sands Missile Range, Fort Lewis, and Yakima Training Center. Additionally, the Growth DPElS concluded that the effects of stationing an SBCT at any one of these installation could be mitigated to less than significant. The Growth DPEIS also debunks this DEIS’ assumption that it would take five years or more to fund, design, and build the facilities needed to support the SBCT. The Growth DPEIS notes that with early Congressional approval and appropriation of funds, it is possible to expedite the military construction process to 3 years. AH these conclusions directly conflict with statements in this DEIS that are used to eliminate installations other than Fort Richardson and Fort Carson from consideration in detail.

Response : None of these installations mentioned. however, could accommodate the 2/251 when it is scheduled to return from its initial combat deployment. Each would require significant new construction that would take much more time than is available. See Section 2.4.1.

28. The Growth DPEIS refutes the Army’s claim that it must limit alternatives considered in this DEIS to only those that include aswap of an IBCT for the SBCT. The Growth DPEIS identifies I 7 installations outside Hawaii where the Army could add one or more IBCTs. Thus, there are many other locations other than Hawaii that could receive a displaced  JBCT  from Fort Richardson or Fort C arson. There is no logical reason why the displaced IBCT must move to Hawaii to take the 1125″‘  SBCT’s  place. Given  the substantial  cultural,  biological, and other environmental effects associated with military  training in Hawaii  and the shortage of available training land, housing and other facilities, the Anny could reap great benefits by relocating the 2/251h without replacing it.

Response: The Growing Army PEIS process does not contradict the Army’s alternatives analysis process put forward in this EJS. The fact that the  Grow  the  Army PEIS looks at 17 installations al which an additional  /BCT could  be  stationed hos no bearing on 1his EIS. The Grow the Army PEIS looks at  stationing  that will occur in the future and that will require new construction. As discussed in Section 2.4.1 of this EIS. new construction will take a minimum of 3 years. The earliest new construction to support BCTs as part of the Grow the Army initiative will not be available until late 2010, at the earliest. The SBCT. currently a fully manned and equipped unit, will require garrison and training facilities immediately upon completion of its deployment in early 2009. As discussed in Section 2.4.1, reducing the Army’s current force structure is not a reasonable alternative.

29 The DEIS’ claim that Fort Polk could not accommodate the  2/25U; SBCT cannot  be squared with the Army’s past admissions. The Anny has already completed  an  EIS  for Stryker  training at Fort Pol.le and concluded that the installation should be used to home station an SBCT. The DEIS fails to explain why Fort Polk is no longer a reasonable alternative for stationing an SBCT.

Response: The Army has added text to Section 1.2.1.5 to explain better the Army’s initial selection of SBCT stationing locations in the Army’s 2002 ROD and why decisions to station the unit at Fort Polk have been revisited since 2001. Fort Polk was in the initial group of installations considered It was screened out in this EIS as unreasonable because it did not meet the criteria for SBCT stationing because of a lade of available maneuver land. See Section 2.4.2 of this FE!S 10 which additional information has been added. Specifically, Fort Polk ‘s maneuver area is committed 10JRTC. one of three locations where brigades complete their final training before combat deployment. When there are JRTC unit ro101ions, the majority of training areas and ranges are dedicated to those unjis. 1his commitment reduces the amount of training area available for an SBCT to the extent that it is not sufficient. The EIS prepared for SBCT stationing at Fort Polk, in fact, revealed many of these difficulties.

30. The DEIS fails to justify its exclusion of alternative involving land acquisition to support the SBCT’s training requirements at Fort Knox, Fort Drum, Fort Polk, or elsewhere. That military land acquisition requires approval, funding, and a waiver of the moratorium docs not excuse the Anny’s failure to consider such options. The DEIS ignores that as part of the Stryker conversion in Hawaii the Anny acquired about 1,402 acres on Oahu and 23,000 acres on Hawaii Island. Without those acquisitions, the training area in Hawaii would be only 97,300 acres, far below the I 05,000-acrc minimum for consideration as a permanent stationing alter­ native. Additionally, without the MMR that is currently in dispute the deficit would include another 4.227 acres. The DEIS also fails to back up its claim of land availability constraints with any hard data regarding the availability of land near Fort Knox, Fort Drum, Fort Riley, or Fort Polk that could make up for the alleged shortfall in training acreage. The Anny cannot make Hawaii a viable option by purchasing land for Stryker training and then refuse to consider similar land acquisitions elsewhere to provide the required maneuver training land.

Response: As fully explained in Section 1.5, land expansion was not considered for the other sites because it would not be purchased, let alone configured for ranges by the time the 2125′” returns from deployment in early 2009.

Table 2-10 has been updated to reflect that MMR’s 4,227 acres were not included within the stated acreage figures.

31. Throughout the DEIS. the Army incorporates by reference numerous documents that are not reasonably available to the public. Many documents cited in the text are not found in Chapter 8’s list of references and the DEIS does not informed interested members of the public bow they can track down these sources and evaluate them during the comment period. Even where cited documents are listed in Chapter 8, the DEIS provides no information on where the public can find and review copies during the comment period. Thus, in the majority of cases, the Army failed to ensure the DEIS’ sources would be “reasonably available for inspection by potentially interested persons within the time allowed for comment” as NEPA requires.

Response: Ali references were available al the  Army  Environmental  Command.  Upon making certain references available 10 requestors, the Army invi1ed those requestors 10 submit additional comments and provided them additional time to do so.

32. On page 1-7, the DEIS overstates the effectiveness of the Stryker vehicle in providing protection to U.S. soldiers. Experience in Iraq has shown that Strykers arc much more vulnerable than previously assumed.

Response:   The  experience  of  Strykers  in Iraq has  been noted  in the  FEIS at Section 1.2.1.5. The Army is facing a resourceful and committed opponent in Iraq and must change tactics in response to enemy insurgents who would do U.S. Forces harm. The SBCTs have and continue to prove their effectiveness in on­ going operations. In its 29 December 2006 Order, the District Court reviewed all the evidence that  Jhe Stryker  vehicle does in fact  save Soldier’s lives.

33. On page 2-22, the DEIS states that under  Alternative  A  the  2/2Slh SBCT  would conduct 105mm MOS qualifications on PTA range i IT. This represents a significant shift from past Army statements about training at that facility where the Army said use of the training facility would  be  temporary.  serving  only  to  ready  the  21251 SBCT  for  deployment  by Noveber. 2007. The DEIS did not analyze the impacts of training with the MGS at Range 11T. If the Anny intends to cond11ct such training in the future, the DEIS must provide a detailed analysis of the training that is proposed and its impacts.

Response: Range  I 1Twas used temporarily  in accordance  with the U.S.  District Court’s 19 December 2006 Court Order. If Hawaii is selected as the permanent stationing location for the 2125′” SBCT, construction would  commence  on  the PTA BAX. which would be located in part on top of Range 1JT. Prior to completion of the PTA BAX range 11T would still be  used  temporarily.  Because the EIS analyzes the impacts of tiring with the MGS on the PTA BAX. it  in­cludes those impacts that would occur on range I IT.

34. On page 2-23,  the  DEIS states  the SBCT  would  use  the  WPAA  for live-fire operations.” This is a significant change from the 2004 FEIS, which stated the WPAA would  be  used  for only non-live-fire maneuvers (pages 2-12 and 2-37). If the Army intends to conduct live-fire operations in the WPAA, the DEIS must provide a detailed analysis of the training that is proposed and its impacts. Given the cultural sensitivity of the WPAA, live-fi training there clearly would cause significant impacts, which the Army is obliged to disclose.

Response: The text in Section 2.5 of the FEIS has been updated to reflect that the Army  has no plans to conduct live fire al WPAA

35. On page S-22, the DEIS improperly fails to evaluate impacts associated with range  construction at KTA and KLOA. The DEIS’  claim  that  ..[n]o  SBCT-specific  range  construction” would be necessary at these locations cannot be squared with the  FEIS,  which  identifies “SBCT” construction projects there {FEIS at page 2-24). or with the Modular Force EA, which  said  “[n]o new  range  construction  would  be  required”  to convert  the  3/251111  into  an IBCT (Modular Force EA at page  1-13). Since  Alternative  A  would  require all  projects  listed in SEIS Table 2-4 to be constructed , the DEIS must disclose the impacts of all of these pro­ jects to comply with NEPA’s mandate to •’present the environmental impacts of the proposal and alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision maker and the public.

It appears that, throughout its discussion of Alternative A, the DEIS evaluated the impacts of only the five projects  that an: allegedly “unique to the needs of an SBCT’ (DEIS at page 2-20; see, e.g., id, at 5-25, 5–29, 5–55, 5-61, 5-64.  By misrepresenting the  true extent of the impacts of selecting Alternative A, which would involve construction and use of all projects listed in SEIS Table 2–4, the DEIS violates NEPA’s core purposes: to ensure that “high quality” “environmental  information  is  available  to  public  officials  and  citizens  before decisions arc made and befo actions aic  taken” and  ”to help public officials make decisions that arc based on wider standing of environmental consequences.

Response: The EIS has been updated to reflect that the 2004 FEJS is incorporated by reference into this document. Thus, the construction of non-Stryker specific pro­ jects and 01her SBCT impacts are being taken into account by the decision maker.

36. The DEIS has no basis for claiming ..[t]he quantity of ammunition rounds fired during Anny training on all Army training ranges would increase from 16 million to, 20 million rounds per year.” Even if the baseline for analysis  of  Alternative  A  were  two  IBCTs  training  in  Hawaii (and it is not), the baseline would be less than 14 million rounds per year, with permanent stationing  of  the  2125^th  SBCT  increasing  ammunition  use  by over 6  million  rounds  (DEIS at page 2-7).  In  fact, the baseline  for analysis  is one IBCT (the 3125th    and one  light  infantry brigade (the 2/25″) training in Hawaii, which would use even less ammunition.

In addition, as noted previously, the DEIS fails to consider the impacts on human health from military training and related activities introducing chemicals into the environment that would be bioaccumulated by plants and animals that people consume.

Response: The Army has updated Section 2.8 to reflect that No  Action includes the live­  fire activities of the 2125′” ID (L) and the 3125^th modular IBCT. It should be  noted that there is virtually no change in ammunition required by the 2125′” ID (L) and a modular IBCT. Both units utilized approximately 7 million rounds of training ammunition while conducting live-fire training to doctrinal standards

As far as bioaccumulation is concerned. the Army looks al offsite potential for contamination under the Operational Range Assessment Program (ORAP). While still in the early stages of the assessment, preliminary results show no contamination of groundwater or surface waters by explosive residues. Please see Section 5.2.3.J of the EIS

37. Light infantry brigades do not use unmanned aerial vehicles (” UA Vs”) . See FEIS at page 2- 40 (UAVs are part of proposed changes to «current force reconnaissance training”). Consequently, inclusion of impacts associated with UAVs in the DElS’ discussion of the No Action Alternative on page 5-217 is improper.

Response: The Army has modified 1he No Action Alternative, Section 2.8. in response to public comment. This Alternative considers the 2125′” ID (L) prior to its transformation and the J/25′,, as a modular IBCT. While the 2125″‘ ID (L) does not have UAVs, the 3/25’^h  IBCT does  have 18 UAVs, and  training  of those UAVs would take place in Hawaii under the No Action Alternative. Changes have been made in Section 5.5. /3.1.4

38. On page .5-228. the DEIS fails to justify its elimination of Turtle Bay Resort improvements from its analysis of cumulative impacts on Oahu. The DEIS must provide far greater detail regarding the nature of those proposed improvements, and of the project-specific impacts, than was included in the 2004 FEIS.

Response: The Anny has updated the Cumulative Effects Section 5.6. The Army feels that there is adequate analysis ro inform 1he Army decision maker appropriately.

39. On page 5-228, the DEIS improperly includes road construction from Schofie]d Barracks to Helernano Military Reservation among projects that would go forward independent of a decision  to station  the 2/25¹¹¹ SBCT in Hawaii. In Chapter 2 (page 2-20), the DEIS identified the Helernano Trail as ”unique to the needs of an SBCT.”

Response: As noted in Section 2.5, road consfnlction from SBMR to HMR is an action unique to the needs of an SBCT Inclusion of this action on the list of reasonably foreseeable future actions in Chapter 5 was an oversight. This action has been removed from the list in Section 5.6.1.

40. Undoubtedly, by now, the Army has a better understanding than it did in 2004 of the specifics of the Theater Support Vessel project and associated pier use at Kawaihac Harbor. These de­ tails, as well as detailed analysis of the associated impacts, must be disclosed in the DEIS on page 5–229.

Response: There are no reasonably foreseeable plans to move forward with the TSV in Hawaii at this time. Therefore, it is not included in this analysis.

41. The DEIS is so inadequate in complying with the Ninth Circuit’s command for the Anny to prepare a legally adequate supplemental EIS that considers all reasonable alternatives. the Anny must prepare and circulate a n:vi d draft that considers all Reasonable stationing alter­ natives as well as a true No Action Alternative. Moreover, the itemized DEIS must fully and accurately disclose the impacts associated with the alternatives under review.

Response: The range of alternatives considered as well as the No Action Alternative are both legally sufficient and comply with the Court ‘s decision. The impacts are fully disclosed and adequately discussed. An additional supplemental EIS is not required.

42. We call for the inclusion of the community’s preferred alternative – the reduction of the military footprint in Hawaii and the clean up and restoration of lands to peaceful, productive, and sustainable uses.

Response: Under all action alternatives proposed in this EIS. the reduction of the military footprint (personnel and equipment) with regards lo the No Action Alternative does.notmeet  the  Purpose  and  Need  for  Action.  Reduction  of the number  of military personnel in Hawaii does not reasonably meet the Army’s needs for implementing the Proposed Action given the need for the Army to implement transformation and meet increased operational requirements. The Army does consider military training use of the land to be a productive use supporting the national defense.

43. The C-17 is an essential element of the decision to station Strykers in Hawaii. The DEIS needs to evaluate and disclose the effects of stationing C-17 aircraft and the accompanying expansion of runways.

Response: This action was taken by the Air Force independently of the Army. The Air Force performed a NEPA analysis for that action. Hickam AFB broke ground for .the C-17 on August 19. 2004. On February 8. 2006. the firs, C- 17 Globe master Ill aircraft arrived at Hickam AFB and on July 18, 2006, Hickam AFB received the eighth and final C- 17. Thus, the stationing of C- 17 aircraft at Hickam AFB is a completed Air Force action. A.s the completion of this action is considered as part of the stationing decision for the 21251    SBCT. it has been incorporated  in Section  5..6  in   cumulative  impacts discussion of pas/,  present, and reasonably foreseeable future actions.

44. On July 10, 2007, the President’s Office of Management and Budget issued a Statement of Administration Policy on S. 1547 – National Defense Authorization Act for Fiscal Year 2008 that stated : ”Stryker Brigade Combat Team Conversion: The proposal that supports the con­ version of the Second Brigade, 25th Infantry Division to a Stryker Brigade Combat Team is necessary to resolve legal challenges to the transformation of this important unit that is scheduled to deploy for operations in Iraq by the end of the year.” Specifically what “proposal” does this memo refer to? Who issued or requested this “proposal”? Is there an exemption for the Stryker Brigade being proposed? How will such a measure affect the Proposed Action?

Response·. This comment refers to  a legislative  proposal  that  would  direct  the stationing of the 1115′” in Hawaii.  The Army was commenting  on this legislative  proposal. If this proposal became law. ii would e/imina1e  the  need  for the consideration of alternative locations other than Hawaii. H.R. I 585, the enrolled National Defense Authorization Act for 1008, does not include any provisions nor has it been signed into law. The Army is proceeding as if this provision  will  not be made law. An earlier version of the House bi.II contained the following section:

SEC 1043.. PROMPT CONVERSION OF ARMY FORCES IN Hawaii

(a)   Finding – The Congress finds that the conversion in Hawaii of the 2nd Brigade of the 25th Infantry Division to a Stryker Brigade Combat Team is necessary to the national defense, supports US. foreign policy, and conforms to prior direction of Congress with regard to the reorganization of the Army into a more effective. fighting force.

(b)   Conversion – The Secretary of the Army shall convert the 2nd Brigade of the 15th Infantry Division to a Stryker Brigade Combat Team, at its t:lln’ent location , and .such conversion shall proceed to completion notwithstanding any other provision of law.

45. The EIS should include all written scoping comments and transcripts of oral scoping comments. It also should include all written and oral comments on the DEIS.

Response: The FEIS includes a summary of scoping comments in Sec1ion 1.8. This appendix includes the comment statements submitted on the DEIS and the Army’s responses to them. The Administrative Record for the analysis contains all the original comments submitted during scoping and review of the DEIS. All comments that were submitted via mail, e-mail, comment forms, and oral testimony are included in the record.

46. The Army is not complying with the order of the Ninth Circuit Court of Appeals. The Court ordered the development of a supplemental site-specific environmental impact statement to “consider all reasonable alternatives, most notably the potential for transforming the 2¹¹¹ Brigade outside of Hawaii .” The questions that this document is supposed to help decision makers answer is where the 2^nd Brigade should transform, not where a fully transformed 2/25m SBCT should be permanently stationed. The Army seems to be trying to conduct this alternative sites analysis outside of the context of the 2¹¹¹ Brigade transformation into an SBCT. Also, the word “supplemental” o.r some derivative of it is mentioned just eight times in the entire DEIS.

Response: The comment is correct that this document is supplementing the original 2004 Transformation FEIS. The 2004 FEIS included analysis of training, construction, and land acquisition actions. The stationing of the SBCT in Hawaii was a very prominent piece of the Proposed Action.

The initial transformation of the 2125’1′ was largely complete before the Ninth Circuit Court of Appea.ls issued its ruling. Since this ruling, the transformation of the 1125′” SBCT has been completed in accordance with the Court’s ruling. This was permitted to allow the SBCT to meet its initial combat deployment requirements. Given the reality that the brigade ha$ already transformed, realistic alternatives do not involve transformation of another brigade in to an SBCT. but rather  where to station lhe 2125¹¹¹ SBCT now that ii  is transformed. The EIS takes this approach, which is entirely consistent with the direction the Anny received .from /he reviewing courts.

47. OHA objects to the statement on page l-l of the DEIS stating that as of May 2007 the Brigade had completed approximately 90 percent of it training and equipment fielding in Hawaii… By November 2007, the Army requires that the SBCT be ready for deployment to meet the ongoing operational requirements of the requirements of global conflicts . This means the SBCT has essentially already been placed in Hawaii.

Response: It is true that the SBCT completed its transformation in Hawaii as was permit red by the ruling of 1he Ninth Circuit Court of Appeals (See response to comment 46 for more derails). Completion of the “transformation of the SBCT and  tis initial train-up were needed to support 1he SBCT’s current deployment to Southwest Asia. This does not mean, however, that ii cannot be permanently stationed elsewhere when the SBCT returns from deployment. Consideration of alternative stationing locations that can meet the requirements of the 1125″‘ SBCT upon its return from deployment to Southwest Asia is the focus of this EIS.

Response: It is true that the SBCT completed its transformation in Hawaii as was permit red by the ruling of 1he Ninth Circuit Court of Appeals (See response to comment 46 for more derails). Completion of the “transformation of the SBCT and  tis initial train-up were needed to support 1he SBCT’s current deployment to Southwest Asia. This does not mean, however, that ii cannot be permanently stationed elsewhere when the SBCT returns from deployment. Consideration of alternative stationing locations that can meet the requirements of the 1125″‘ SBCT upon its return from deployment to Southwest Asia is the focus of this EIS.

48. The model used to assess the effect of Stryker training in terms of an Abrams tank per mile of travel is unacceptable. Clearly, a Stryker vehicle and an Abrams tank are so dissimilar as to render this assessment singularly uninformative. Therefore, the Anny finding of a ”moderate” effect based on this modeling is not valid. The Anny must provide some real data from actual Stryker vehicles from which the Army assessed the potential impacts on soils and conditionssimilar to Hawaii.

Response: The Army’s Center for Engineering Research and Development (ER.DC) has extensively modeled and analyzed the conversion factors for calculations of maneuver impacts and assessments of maneuver damage. Calculation of Ml.Ms take into account the weight of different Army vehicles, tire or track pressure, damage during pivot steering, and many other factors. The Army has included a reference to explain better how MIMs and the Army’s Training and Testing Carrying Capacity (ATTACC) methodologies are used. This is included in the Chapter 8 of the FEJS. The use of M/Ms provides the Army with a common  way  to evaluate  the effects  of  different  vehicles  in the field  The MJMs  that would  occur  with an SECT are evaluated  throughout  Chapter  5 (as in Section 5.2.2.4  for example) and are presented in  Sections 1.5 through 2.8 The Stryker is lighter than an MI Tank and it is a wheeled rather than tracked vehicle. It obviously travels farther than an Abrams Tank for the same number of M/Ms. This method helps the Anny to avoid the comparison of ” apples and oranges” thar a straight comparison of mileage/or radically different vehicles would cause.

49. The Army needs to explain and describe what the 2125^th IBCT light would actually look like and how its operations would impact Hawaii

Response: The Army has modified the No Action Alternative in the FEIS to ensure a description of equipment and training requirements is included in Section 2.8  of the  FEIS.  In addition.  this  EIS incorporates  the  2004  Transformation FEIS by reference and additional description of the 2125″‘ ID (L) can be found in this document.

50. The Army needs to list exactly which lands and their precise acreages make up the 121,702 acres of current training lands in Hawaii shown on Table 2-10 of the DEIS. In the 2004 FEIS, the Anny only lists 96,180 acres of available maneuver lands. What changed? Also, the Army needs to explain better the formula used to produce its land deficit figures and why the benchmark for the amount of maneuver lands required for an SBCT changed since the 2004 Transformation FEIS.

Response: The table below shows the acreages that the Army used to calculate maneuver training land holdings in Hawaii. The Army has recently recalculated its maneuver land totals in Hawaii in response to Congressional inquiry  Following this inquiry, the Army has slightly revised its  maneuver  land  totals to  reflect  the most accurate information it has to dare , which are based on recent surveys of its training areas. The Army has 1Z3,868 acres of maneuver training lands in its inventories in Hawaii thatcouldbeusedtosupporttrainingofthe SBCT This does not include MMR. which the SBCT does not need to meet its training requirements and the use of which is currently not permitted.

Since  the  2004  Transformation  FEJS,  the   Army  acquired  additional land  at PTA and  South Range. The acquisition  of these lands, the initial  planning of  which had begun prior to 1he transformation of the 1/25,,,. results in the differences in maneuver land acreages under Anny ownership between the 2004 FEJS and this EIS.

The formula used to calculate  the  maneuver  land  shortfalls is based  on  a debt to equity ratio of the maneuver land shortfall at a given location divided by the total maneuver land that an alternative stationing location has on hand  to support the requirements of the 2125″‘ SBCT and any other  BCT  stationed there. Any installation with a maneuver training land deficit that  is  twice  as great as the maneuver land it has on hand is to support BCT training requirements (i.e. less than ½ the total training land needed to support doctrinal requirements) was not callied forward as a viable stationing .alternative for the SBCT and its larger training space requirements.

51. The Army needs to identify clearly how many IBCTs are in Hawaii. OHA believes that there are currently two IBCTs in Hawaii. Also, what are the cumulative effects of adding another IBCT?

Response:  There is one JBCT stationed in Hawaii, the 3/25¹  The 2125¹‘¹ SBCT deployed to Southwest Asia in November 2007 and the decision on its final stationing location is still pending. though Hawaii has been selected as the Army ·s Preferred Alternative for its stationing. The effects of adding another !BCT are discussed in Sections 5.3.17. 5.4.16, 5.5 of this FEIS . Cumulative effects are discussed in Section 5.6. The construction projects and training required to support an additional JBCT in Hawaii if Alternative B or C is selected are discussed in Sections 2.6 and 2. 7, respectively.

52. The Army refuses to consider transforming the 2^nd Brigade at an overseas host nation. Why is the SBCT stationed at Rose Barracks in Vilseck. Germany  allowed  to  be  based  on  foreign soil? Ace there any IBCTs outside the U.S. that can be exchanged with the 2/25 ¹¹¹ SBCT?

Response: As discussed in Section 2.9 of the EIS, national security and defense policy documents such as the NSS, NDS, QDR, and other documents sel forth defense policy that the U.S. should rely on  the  rapid  projeclion  and  deployment of units from within the V.S. This ensures the U.S. can fully control the availability.

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