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

Final Environmental Impact Statement

Permanent Stationing of  the  2/  25th Stryker  Brigade Combat Team

Prepared For

Headquarters, Department of the Army

Washington, DC

Prepared By

U.S. Army Environmental Command Aberdeen Proving Ground, Maryland

February 2008

Volume 2



The Anny used a screening process to identify  installations  that  could serve as  the permanent  home  sta­ tion of the ‘1125* SBCT. Important factors in developing and implementing the screening process are pre­ sented in Section  2.4,  and  the  installations  that  progressed  through  the  process are  presented  in  Section 2.4.2. The Anny analyzed 140 installations for their suitability to meet the purpose and need of the Pro­ posed Action. Army facilities, such as individual State National Guard headquarters, Army Corps of En­ gin r Research laboratories, installations scheduled for closure under the BRAC program, and Regional Readiness Centers, were excluded because they lack the physical space to accommodate the stationing of a brigade combat team. Listed below are the 137 installations that did not progress all the way through the screening process and the justification for their exclusion from further consideration as viable alternatives.

The following installations were excluded because they are primarily administrative, instructional, or test­ ing, maintenance, supply or production facilities which do not possess the training infrastructure or capac­ity to support construction of training ranges or infrastructure to support operational forces, to include the 2/25.., SBCT:

Anniston Anny Depot

Anny Research Laboratory Adelphi

Blue Grass Anny Depot

Carlisle Barracks

Corpus Christi Anny Depot

Crane Army Ammunition Activity

Defense Distribution Depot San Joaquin

Defense Distribution Depot Susquehanna

Defense Supply Center Colwnbus

Defense Supply Center Philadelphia

Defense Supply Center Richmond

Deseret Chemical Depot

Detroit Arsenal

Fort Chaffee Training Center

Fort Custer Training Center

Fort Detrick

Fort George 0 . Meade

Fort Greely

Fort Hamilton

Fort Leavenworth

Fort McPherson

Fort Monmouth

Fort Monroe

Fort Myer

Fort Shafter

Hawthorne Army Depot

Holston Anny Ammunition Plant

Iowa Anny Ammunition Plant

Joint System Manufacturing Center Lima

Kansas Anny Ammunition Plant

Lake City Army Ammunition Plant

Letterkenny Anny Depot

Lone Star Army Ammunition Plant

McAlester Army Ammunition Plant

Mickelsen Stanley R Sfg Msr

Milan Anny Ammunition Plant

Military Ocean Teniinal Concord

Military Ocean Tenninal Sunny Point

Mississippi Anny Ammunition Plant

Newport Chemical Depot

Pic.atinny Arsenal

Pine Bluff Arsenal

Presidio of Monterey

Pueblo Chemical Depot

Radford Anny Ammunition Plant

Ravenna Training And Logistics Site

Red River Anny Depot

Redstone Arsenal

Riverbank Anny Ammunition Plant

Rock Island Arsenal

Salina Smokey Hill Training Site

Scranton Anny Ammunition Plant

Sierra Army Depot

Tobyhanna Army Depot

Tooele Anny Depot

Umatilla Chemical Depot

US Army Garrison Miami

US Army Soldier Systems Center Natick

Walter Recd Anny Medical Center

Watervliet Arsenal

West Point Military Reservation

The following installations were excluded bet;ause they have not undergone substantial range moderniza­ tion necessary to support an SBCT. These installations are classified by the Anny as Category 3 training sites (i.e. lower funding priority) and have not been modernized to the extent to which they could support an operational BCT or because they arc fully engaged with mobilization and deployment of Reserve component forces and do not have the capacity to supPQrt a BCT given their current Reserve missions load;

Aberdeen Proving Ground

Camp Ashland

Camp Atterbury

Camp Beauregard

Camp Blanding

Camp Crowder Neosho

Camp Dawson -Kingwood

Camp Dodge Johnston

Camp Edwards

Camp Grafton

Camp Grayling

Camp Gruber

Camp Guernsey

Camp Joseph T. Robinson

Camp Maxey

Camp McCain

Camp Minden

Camp Perry

Camp Rapid

Camp Rilea

Camp Ripley

Camp Roberts

Camp San Luis Obisbo

Camp Santiago

Camp Shelby

Camp Smith

Camp Swift

Camp Williams

Combat Support Training Center And Camp Parks

Dugway Proving Growid

Eth.an Allen Range

Fort Belvoir

Fort Buchanan

Fort Dix

Fort Eustis

Fon Gordon

Fort Huachuca

Fort Indiantown Gap Training Site

Fort Lee

Fort McClellan Training Center

Fon McCoy

Fort Pickett Training Center

Fort William Henry Harrison Training Site

Fort Wolters Training Center

Greenlief Training Site

Marseillies Training Site

Orchard Range

Stones Ranch Military Reservation

Volunteer Training Site Catoosa

Volunteer Training Site Milan

Volunteer Training Site Tullahoma

W.H. Ford Regional Training Center

White Sands Missile Range

Yuma Proving Ground

The  following installations  were excluded  because they lack an IBCT to exchange with lhe 2/25111, a nec­essary constraint as there is insufficient time to construct the garrison infrastructure needed by an SBCT.

Fort A. P. Hill

Fort Benning

Fort BHss

Fort Hood

Fort Irwin

Fort Jackson

Fort Leonard Wood

Fort Lewis

Fort Rucker

Fort Sam Houston

Fort Sill

Fort Stewart

Fort Wainwright

Select Anny installations support airborne division or air assault division requirements and capabilities to ensure the Anny can respond rapidly to contingencies with the appropriate forces. An SBCT could not be effectively integrated with light infantry airborne divisions or air assault divisions to meet the rotational readiness requirements to deploy rapidly in a few days time from these installations. where units are col• located with the proper transport capabilities for their equipmen t. The following instaUations were ex­ cluded because they support special missions incompatible with an SBCT.

Fort Bragg            Fort Campbell

The following installations were excluded because they possess insufficient maneuver training land to support the needs of an SBCT:

Fort Drum                                                                                Fort Knox

Fort Polk                                                                                  Fort Riley

There are only seven Army installations that possess minimum maneuver land thresholds to execute the training tasks required by the SBCT and would not be screened for the stationing of an. SBCT because of maneuver land shortfalls. These installations include:

Fort Bliss, Texas

Fort Carson with PCMS

Fort Lewis with Yakima Training Center

Fort Richardson with Donnelly Training Arca

Fort Wainwright with Domelly Training Area

U.S. Anny Garrison, Hawaii

White Sands Missile Range, New Mexico

As is discussed above, Fort Bliss, White Sands Missile Range, Fort Wainwright/Donnelly, and Fort Lewis/Yakima arc screened because they lack an IBCT to be exchanged back to Hawaii.



Since the 2004 Transformation EIS (USAG•HI 2004)1  cultural resource surveys were perfonned for many of the projects identified in the EIS. Information regarding projects, reports, and surveys reflects their status as of July 2007.

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Table B-1       Cultural Resource Surveys Performed Aprll 2004-Jul 2007

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RANGE PROJECTS                                           

This appendix presents the ranges that would be required as part of the three actions alte.matives. Not all ranges are part of every alternative. Refer to Chapter 2 for a detailed description of range construction requirements for each alternative.

Graphics Code: S4

Project fl: 58144

Project Tide: Battle Arca Complex (BAX)

Project Location: SBMR

Project Size: 8,063 square feet of support structures and 2,075 acres of training area Construction Timeframe: September 2005 to December 2006

Background: Current range facilities on O’abu and the island of Hawai’i were  designed  and constructed to support either the current configuration of light infantry or armored forces previously stationed in Hawai’i. No facilities in H1wai’i provide 1 realistic battle area for mounted infantry units in need of live-fire training.

Project Description: Construct a BAX designed for company-level. weapon proficiency training. The range would also support dismounted infantry platoon tactical live–fire operations with or without supporting vehicles. Training objective features would include four course roads. 30 stationary armor targets, six moving armor target, 17-4 stationary infantry targets, 14 moving infantry targets, 17 machine gun/observation bunkers, two  grenade/breaching  obstacles,  three  helicopter  landing  zones, 18 mortar simulation devices, 8 hull-down defilades, and vehicle firing posit ions . Range operations support facilities would include a dual sex dry-vault latrine, bleacher enclosure,  covered  mess area, range operations cent.er, storage building, ammunition-loading dock, and AAR building. Supporting facilities would include site improvements, erosion control, a bivouac  (temporary  camp)  area, electrical service, and security fencing and gates. The range would be sited on the west side of Beaver Road north of Trimble Road, on the range complex and range impact area of the SBMR range area.

Estimated  Utility  Requirements: This  project  would  require  connecting  to  the  primary power distribution system. The  nearest available power (12.-47-kilovolt, three-phase)  is 980 feet (300  meters) away. A new 12.47-kilovolt, three-phase primary line would be constructed to bring primary  power to the  range  site. Once  at  the  site, primary  power  would  be  run  underground  to  feed  a pad-mounted transformer  near the control tower. All  buildings would  be supplied with underground  120/240-volt, single-phase, secondary power from the transformer. Air conditioning, estimated at 20 tons, would be provided. Heating is not required. All sewage on the site would be collected in the aerated vault latrine and removed by pumper truck, so no sewage lines or septic field would be required. Water would be trucked  to the site, so no water line, distribution systems, or  well would be required. Telephone and LAN service can be had approximately  4,000 feet from the project site at ISF. Approximately  1500 feet of aerial cable will be run from the AAR building to the UA. Cable will be attached to a new power pole line. The remaining buildings within the project requiring telecom services would be connected via an underground duct system to the AAR Building.

Graphics Code: D1

Project Number. 58161

Project Title: land Easement/Road Construction between SBMR and DMR

Project Location: SBMR route to DMR Project Size: 36 acres along 12.4 miles Construction Timeframe: After March 2009

Background: Access to DMR from SBMR is via state and county public roads, with only a single two­ lane public road connecting the two locations. Military convoys using this road slow the flow of traffic and create potentially dangerous situations when cars attempt to pass the military vehicles.

Project Description: Require a perpetual easement of approximately 36 acres (15 hectares) and construct a 15-foot-wide (5 meter) gravel road with 3-foot-wide (1 meter) gravel shoulders on both sides. The road would run 12.4 miles (20 kilometers) from SBMR to DMR and would provide military vehicle access to both installations. Work would include grading, paving, improving drainage, and installing culverts at stream crossings and guardrails at drop-offs. Storm drainage structures and lines would be installed to prevent excessive amounts of stormwater runoff from water flowing over the road and endangering traffic. Telecommunication lines would be provided alongside the new road during construction. Road grades steeper than 10 percent would be paved with asphalt or concrete and the sides would be supported with shotcrete, guardrails, retaining walls. drainage structures {for example, concrete and grass swales), and signs.

Estimated Utility Requirements: None

Graphics Code: K3/K4

Project II: 57802/57’406

Project Title: Easement/Road Construction between SBMR and HMR

Project Location:Road from SBMR to  HMR on. the route to KTA Project Size: 13 acres along 6 miles of road

Construction Timeframe: September 2004 T March 2005 (easement) to September 2005 to December 2006 (construction)

Background: Military convoys travel from SBMR to HMR on Wilikina  Drive onto Kamananui  Road, then to Kamehameha Highway to K.TA and KLOA to conduct military training exercises. Wilikina Drive, Kamananui Road, and Kamehameha Highway are only two-lane public roads, used by both local residents and tourists. The elevation/grade from SBMR on Kamehameha Highway to both training are relatively steep, and when returning from training at KTA or KLOA the heavy military vehicles are traveling well below posted speed limit designation ns. Use of the existing highway is also creating traffic-congestion and damage to the roads. Military convoys traversing this public road slow down the flow of all traffic and create dangerous situations when cars attempt to pass the large caravan. creating the potential for head-on crashes. Dirt, rocks. and debris from the vehicles are deposited on public roads, creating hazardous driving conditions to the general public. The Army is preparing to upgrade Drum Road, a military road from HMR to KTA and KLOA training areas. The new road in this project would tie into Drum Road and reduce heavy military vehicles from public roads.

Project  Description: Acquire approximately  13   acres (5 hectares)  of  land  in a perpetual  easement and construct a 15-foot-wide  gravel  road  with  3-foot-wide  gravel  shoulders  on  both  sides  that  would provide  military  vehicle  access  between  SBMR  and  HMR.  In  conjunction  with  Drum  Road,  this project would provide a road network from SB.MR  to  KTA.  The  road  would  run  approximately  6 miles (-4 kilometers) (from SBMR to HMR. It would be north of Wahiawa and would use as much of the  agriculture  roadways  as  possible.  Work  includes  grading,  paving,  drainage  improvements,  culverts at stream crossings, guardrails, shotcrete, retaining walls,  concrete  swa.les.  grass  swales,  signage,  and storm drainage Structures and lines to preclude excessive  amounts  of  storm  runoff  from  water  flowing over the road  and  endangering  traffic.  Work  will  also  include  provisions  for  telecommunication  lines to  run  alongside  the  new  paved  road.  Road  grades steeper  than  10  percent  will be  paved  with asphalt or concrete. Supporting facilities includes provisions for information systems.

Estimated Utility Requirements: Approximately 6.5 miles (4 kilometers) of fiber cable will be direct buried between SBMR, McNair Gate and Pupukea Road leading to Heleman6. Additionally, a direct buried cable wit] be installed along Pupukea Road and a duct system will be installed to building Pl at Helemao6. Also, a duct system will be installed from McNair gate to Building 886 on SBMR .

Graphics Code: P1 Project#: 57197

Project Title: Battle Area Complex (BAX) Project Location: Poh.akuloa Training Area

Project Size: 11,808 square feet of structures and 2,075 acres of training area Construction Timeframe: May 2007 to May 2008

Background: No facility of this type exists in Hawai’i, and the light infantry  brigades  of  the  z..i Brigade cannot accomplish required mounted combined arms live fire exercises.  No  ranges  exist  for gunnery training for the MGS, Interim Armored Vehicle infantry carrier vehicle,  or  Interim  Armored Vehicle reconnaissance vehicle. Facilities on O’ahu and the island of Hawai’i were designed and constructed to support either the current light infantry configuration or armored forces previously stationed in Hawai’i. Implementation of evolving Department of the Army and TRADOC Combat Doctrine and Training Strategies in Hawai’i will affect the ability to train the SBCT and 25th ID(L) using existing range facilities. The unique vehicle design and expected mission requirements of this medium force arc not met by current range facilities. The combination of the types, den$ities, and distance to targets, obstacles, and landing zones are not available on standard range designs.

Project Description: Construct a BAX designed for live-fire, maneuver gunnery training  and qualification requirements of the weapons systems for the: proposed SBCT and the division’s legacy Force at PTA on the island of Hawai’i. This range will also support company level mounted and dismounted combined arms live-fire exercises, dismounted infantry platoon tactical live-.fire operations, with or without supporting  vehicles, as  well as Army aviation. close air support, artillery, and air defense artillery gunnery and live-fire maneuver gunnery training operations. The  project  will be sited along Lava Road, approximately five miles from the entry  into the PTA  and  approximately half a mile south of BAAF. The range project will be oriented south toward the existing impact  area and built over Range 12 on the eastern portion of PTA. The training assets at Range 12 will be demolished so the new layout can be overlaid and accommodated. The  primary features  of  the range will include four course roads with crossover capability, 30 reconfigurable stationary armor  targets (SA1), six moving armor targets (MA1),  174  configurable  stationary  infantry  targets  (SIT),  14 moving infantry targets (MTI), 17 machine gun/observation bunkers,  two  gunnery/breaching obstacles, 18 monar simulation devices (MSD), 16 hulldown defilades, three landing zones, vehicle firing positions, grenade/breach facades/trench complexes, military vehicle trails, and service roads. Other range operations facilities will include observation tower, range control center, AAR facility, operations/ storage building, ammunition breakdown building, ammunition loading dock, latrine, bleacher enclosure, covered mess, bivouac concrete pads, and flagpole. All tuge1S will be fully automated; the event specific target scenario is computer driven and scored from the Range Control Center. The reconfigurable stationary infantry target and reconfigurable stationary armor target will be solar powered, radio-controlled targets with target coffins. The range operating system will be fully capable of receiving, transmitting, and capturing digital traffic to/from the using participants. This captured data is compiled and available to the unit during the AAR. Storm drainage, service roads, site improvements, and berms will be provided as necessary. Range support facilities include electrical service; paving, walks, curbs and gutters; site improvements; and demolition.

Estimated Utility Requirements: Primary power would come from 12.47-kilovolt lines extended overhead from the weather tower to the downrange pad-mounted transformers in the power centers. Range targets would be fed underground using 480-volt, three-phase, or 240-volt single-phase

Graphics Code: PS Project fl: 57417

Project Title: Ammunition Storage Area Project Location: PTA

Project Size: 6.750 square feet

Construction Timeframe: After March 2009

Background: PTA has eight ammunition storage igloos. These igloosJ operated at capacity; are too small to accommodate additional training requirements that would arise upon conversion of the 2•:Brigade to an SBCT.

Project Description: Construct three earth-covered ammunition igloos totaling 6,750 squa.re feet at the ammunition storage facility. An ammunition holding area for duly distribution of  ammunition would be constructed to safely hold loaded vehicles. Work would also include installing pole-mounted security lights, floodlights above each entrance, and telephone and computer systems. Supporting facilities would include utilities, electric service, stormwater drainage, paving, and access roads.

Estimated Utility Requirements: Electrical power requirements are estimated at 4873 VA and energy consumption at 32,564 kilowatt hours per year. Telephone and LAN service can be had approximately 5,660 feet from the project site at the PTA cantonment area. An existing aerial pole will provide the pathway to the location. An underground duct system will connect the pole to a new administrative building. Three igloos within the project site would be connected via an underground duct system to the administrative building. Water supply needs are estimated at 18,000 gallons per year.

Graphics Code: PS

Project II; 56994

Project: Title: Range Maintenance Facility Project Location: PTA

Project Size: 16,011 square feet

Construction Tim frame: After March 2009

Background: Rang Division Hawai’i is responsible for command and control of operations at all Army training areas on the island of Hawai’i, primarily PTA. Range control and maintenance operations are housed in eight temporary building dispersed throughout the PTA cantonment area, leading to inefficiencies, excessive travel, reduced response times, and miscommunication between different range elements. Most of these facilities s are Quonset huts built in 1957, with characteristic curved roofs that render much of their interior space useless. Electrical and mechanical systems are antiquated and require excessive maintenance funding. The shop facilities lack adequate ventilation and operating sprinkler systems. As a health and safety issue, all welding must be conducted outside by order of the fire department. Dispersal of maintenance activities has reduced the quality of service provided to range users due to inefficient split functions. The poor quality of the facilities also worsens the difficult task of recruiting qualified laborers at this remote location.

Project Description: Construct a Consolidated Range Maintenance Facility for PT A on a previously developed site within the installation’s cantonment area. The project will include administrative space for range maintenance, a carpentry shop, a welding shop, target and raw material  storage, and parking for personally operated vehicles and other vehicles and equipment. Supporting facilities  include  potable water system, septic system, electric service and 150-kVA, three-phase transformer. paving, w:tlks. parking, security fencing, information systems, and site improvements. Access for the handicapped will be provided to all areas. Thru buildings (f17, Tl9 and T20) will be demolished and replaced by the proposed complex.

Estimated Uti1ity Requirement Existing electrical lines are approximately 100 feet north of the project site, and these resources are expected to continue to be available. Power requirements to operate building systems and equipment would include single-phase, 250.amp service in the administrative   space,   three-phase/four-wire,  250.amp   service   in   the   carpentry   shop,.  and   three­ phase/four-wire, 400-amp service in the welding shop . A 150-kilovolt transformer would also be required. Air conditioning, estimated at 10 tons, would be provided for administrative space only . Mechanical ventilation would be provided in the warehouse and shop areas. Water would be connected  to an existing line approximately  150 feet north of  the proposed sit e. Sewage would be collected  and  treated  by a standard septic system,  including septic tank  and  leach  fields, to be located immediately to the west of the site. Telephone service can be had approximately 1,000 feet away at building 106. LAN service can be had approximately 1,150 feet away at building 179. A lOO•foot underground duct would be installed from the Range Maintenance Building to the l3A to provide connectivity for this project.



DRAFT ENVIRONMENTAL IMPACT STATEMENT                                                               

The    DEIS  was  available  for  public  review  and  comment   from  July  20,  2007  through  October 30,

2007. The document (hard copy or CD) was distributed  to recipients primarily in Alaska, Ollorado, and Hawaii. It also was available on the Internet for review or down loading . During the review  period, a variety of agencies, elected officials, businesses, organizations, and  individuals submitted  letters, facsimiles, and e-mails containing comments on the  DEIS.  In  addition,  nine  public  meetings were held in Alaska (2), Colorado (2), and Hawaii (5) where people provided verbal statements that were recorded. The following section summarize the public’s comments on the DEIS and the Anny’s responses to those comments.


Table D-1 through Table D-3 below present public involvement at the nine meetings held during the comment period for the DEIS. The number of attendees reflects the count of people who signed in. The number listed as oral comments reflects the total number of times statements were made at the microphone, and not the number of different individual speakers. Several individuals spoke more than once per meeting, and/or at more than one meeting.

In addition to comments collected at the public meetings, 228 comments were received by mail, fac­ simile, and email.. Of those, 212 pertained to the Proposed Action in Hawaii, I l pertained to the Pro­ posed Action in Colorado, two were not location-specific, and three were from Federal agencies commenting on the project as a whole.


Respondents submitted a variety of comments on the· DEIS. The Amly reviewed the comments and arranged them into groups with comment concerns. Then, a primary comment statement was prepared for each group of comments. Finally, a response was generated for each comment statement. Overall, the comments primarily focused on the NEPA process, alternatives, biological resources, cultural re­ sources, water resources, wildfire, air quality, and cumulative effects, though comments in other areas were received, and the Anny has responded to them.

Table D–4, which follows the section on comments and responses, identifies the individuals, businesses, organizations. and agencies that responded to the DEIS. The table lists each respondent alphabetically and identifies the comment statement or statements attributed (O the letter, e-mails, facsimile, or verbal statement.

The identifiers for the comment statements arc associated with each comment statement in the section immediately preceding the table. The actual letters, e-mails, facsimiles, and transcripts of verbal statements are available for public review in the administrative record.

Table D-1       Summary of Meetingsin Hawaii on the Draft. Environmental Impact Statement

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Table D-2       Summary of Meetings In Alaska on the Draft Environmental Impact


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Table D-3        Summary of Meetings In Colorado on the Draft Environmental Impact Statement

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This section presents the comment statements developed by the Anny and their responses. The comment statements are numbered sequentially from I to 228 to facilitate references to them in Table D–4. However, they are organized  in this section to follow the discussions of resource areas in the  EIS.

Following the discussion of resource areas, comments and responses regarding alternatives, the NEPA process, editorial changes, and other related issues have been included .


1 . What assurance does the public have that the mitigation identified in the DEIS will be implemented and adequately funded? Considering constraints  on  the  federal  budget,  how  will the Anny fund mitigation measures over the life of the project  and  the measures themselves? The Army must ensure that the funding exists to implement and maintain the mitigation measures identified in the EIS because the levels of  impact  described  in  the  DEIS  depend upon implementation of the identified mitigation.

Response: The Army NEPA regulation requires Chai mitigation measures be funded. Essentially, mitigation measures that are adopted in 1he Record of Decision be­ come part of the Proposed Action. All parlor of the Proposed Action must/ be funded in order for the action as a whole to proceed.

2. The Army needs to consider alternatives that involve the temporary stationing  of  the  2/251 SBCT in Hawaii and then moving the SBCT to another site  when  permanent  facilities  are ready. The DEIS’ assertion that temporary stationing would require that all projects under Alternative A be built in Hawaii is baseless. The Anny successfully converted and trained the 2/251  SBCT for deployment as an SBCT using only the facilities already in existence in Hawaii and those SBCT-specific facilities that the Court allowed the Anny to complete. Finally, a. review of the schedule for construction  of  new  facilities  reveals  that  nearly  all  of  the  pro­ jects  that  the  Anny  claims  are  vital   to  train  an  SBCT  were  not  even  scheduled  to  begin  construction  witil after  the  2/251   was scheduled  to complete  its conversion  and  be available for deployment as an SBCT.

Response: The 2125th was able to be deployed in 10()7 only because it was able to utilize training facilities in 1he Continental U.S. to meet 1he balance of those training requirements that the Army was not able to meet in Hawaii. Training facilities for the SBCT were not built and the unit had to make do with these other training facilities to conduct training away from home station. While this had to be done lomeeJ deployment schedules, this lack of ability to train the SBCT to training readiness standards for its deployment at home staJion is not considered sustainable or feasible for the Soldiers and Families of the 2125h’SBCT. Anny deployments have t ed and stressed Soldier and Family relationships Army-wide. The need to conduct additional training away from home-station added a month to the amount of time Soldiers were required to spend away from their Families prior to a 15-month deployment overseas. Section 2.9G clearly discusses why temporarily stationing Soldiers in Hawaii and moving them lo another location when facilities are ready is not a viable alternative.

3. The No Action Alternative included in the DEIS is not the true No Action Alternative. The No Action alternative is the 2/25tlt as a Light Infantry Brigade, not an IBCT. Accordingly, training would be conducted pursuant to pre-transformation standards, with lower levels of munitions expended and fewer maneuvers performed. The No Action Alternative improperly includes numerous, significant changes from the conditions that existed before the illegal conversion of the 212s• to an SBCT in Hawaii. These changes include facilities specifically modified for Stryker training and several land easement and acquisition projects that have al­ ready occurred. Under the No Action Alternative, these easement and acquisition projects should be returned to the private ownership they had before the Army illegally proceeded with Stryker conversion. Also, the No Action Alternative has to be a feasible alternative.

Response: Tine No Action Alternative is reflected in Section 2.8. This No Action Alternative reflects an appropriate baseline that includes training as a light infantry brigade with conditions as they existed prior to the preparation of the Army ‘s .SEJS. 11,is matter was subject to litigation and as part of that litigation, the court permitted specific construction projects to proceed and appropriate training to ensure the 25111 was properly training D$ an SBCT. The appropriate baseline for the No Action Alternative is provided in Section 2.8.

4. How will the Army move the Strykers between Islands’? Is the Anny going to use new theater support vessels (high-speed vessels with a 15-foot draft and a top speed of 40 knots) or the Superfrry to transport troops, Strykers, and other equipment between Oahu and Hawaii Is­ land? If the Army is going to use the Superferry, the terms of the contract need to be released to the public and the DEIS needs to disclose the impacts.

Response: For the foreseeable future, the Anny methods for the transport of Stryker vehicles do not include the theater support vessel. The concept of the theater sup­ port vessel has evolved into what is now being called the Joint High Speed Vessel (JHSV). This concept is still in development by the DoD. The project has not been funded at this time. If the JHSV is funded ii would take a mini mum of 4 years lo build one JHSV. This would be allocated to the Army; Navy, or Special Operations forces. The action is currently not funded and it is not known where a JHSY (formerly TSV) would be positioned if it were funded by DoD in the future.

The Army’s primary method of transporting the SBCT from Oahu lo Hawaii Island is the Logistics Support Vessel (LSV). If LSV’s are not available, the Army would  use private contract  vessels for inter-island  transport. When the Army  uses  private  contract  vessels, typically  barges, it is  required  to  request bids from multiple vendors, and no particular vender is assured a contract for transport.  The Army does not know if the Superferry would ever bid on such a contract or if it could even be configured to carry military equipment with the chains and bracing needed to transport Stryker vehicles. No contract currently exists or is being formulated between the Army and the Superferry for trans­ porting the SBCT. The Army has no deliberate intent Jo solicit bids to use the Superferry. It is therefore not a reasonably foreseeable Army action that re­ quires impact analysis in this EIS.

5. The Hawaiian Islands are too small to provide the maneuver and training space needed by the 2125th SBCT. The EIS should state whether Hawaii has adequate training land without the recently acquired 25,000 acres. Installations with more training lands arc better suited as the permanent station for the 2/250, S BCT. Why were more locations not considered?

Response:     As discussed  in  Section 2.4.2, the  Army did not arbitrarily exclude or eliminate any potential alternatives from consideration  in its assessment of alternative for permanently  stationing  the 212511‘   The Army initially considered  the fall spectrum of Army installations as potential sites. Many Army facilities. such as Army ammunition production facilities and Army National Guard or Reserve Component training sites, were eliminated because they did not meet one or more of the screening criteria (see Appendix A). The installations that were ultimately determined to be reasonable alternatives met all of the screening criteria. Section 2.4.2 fully discloses the maneuver acreage of sites that have been considered as part of this process. Large training and maneuver areas are needed to train SBCT units and their equipment. Reasonable alternatives for permanently stationing the 2/25’A SBCT are Hawaii, Colorado, and Alaska.

6. The Army considered too few alternative locations for the permanent stationing of the 2/25th SBCT.

Response: As discussed in SecJion 2,4.2, the Army did not arbitrarily exclude or elimina1e any potential alternatives from consideration in its assessment of alternatives for permanently stationing the 2125thThe Army initially considered the full spectrum of Army inslallations as potential sites (see Appendix A). Many Army facilities, such as Army ammunition production facilities and Army National Guard or Reserve Component training sites, were eUminated because they did not meel one or more of the screening criteria. The installations that were ul­ timately determined Jo be reasonable alternatives met all of the screening cri­ teria. Sec/ion 2.4.2 fully discloses the maneuver acreage of sites that have been considered as part of this process. large training and maneuver areas are needed lo train SBCT unils and their equipment. Reasonable alternatives for permanently stationing the 2/25th SBCT are Howaii, Colorado, and Alaska.

7. What are the proposed uses of Stryker’s in Makua Valley?

Response: Section 2.5 explains that altainmenl of operational readiness by the 2125″‘ is not dependent on the use of MMR. While the MMR is an integral part of USAG-H/  training  capabilities  and  historically  used  by  other  services,  .the units of the 2125’,. could perform dismounted live-fire training at other ranges. The SBCT might use MJl,{_R if the range were available following completion of the Makua FEIS and ROD for use of that range.

8. How can the Anny justify basing the 2/25111 SBCT in Hawaii when the DEJS shows that  Hawaii has more significant effects than either the Alaska or Colorado alternatives?

Response: The Army must balance environmental impacts and other considerations in determining its stationing decision. These other factors include training and operational requirements, training ranges, maneuver lands, deployment operation facilities, maintenance and garrison operations facilities , Soldier and Family quality of life, and strategic location and deployment capability . These considerations are described in Section /.2.1 of the FEJS and will be discussed in detail in the ROD.

9. Will you supply more compete data, especially in Chapter 5. Data on the effects of soils erosion, effects of Stiykcr movements on the roads, cost analyses of all alternatives, contamination of streams, cumulative effects seem incomplete.

Response: The information provided in Chapter 5 of this EIS is adequate for 1he Army decision  makers  to decide  on the  permanent  home  station  of the  2!25h ‘.  This EJS supplements  a  detailed  site-specific  analysis  was  conducted  for  Hawaii and completed in 2004 that has been updated to reflect current conditions and projected impacts.

10. The analysis of the effects for the IBCT that would come to Hawaii under alternatives B and C is insufficient. Effects of stationing the 4125th IBCT or the 414th IBCT in Hawaii should be fully evaluated in this EIS to provide a complete picture of the effects at all locations. This includes the additional facilities and commensurate increase in training days, ammunition expended, and maneuver impact miles that would be required in Hawaii to accommodate the IBCT. The DEIS ignores the potential effects of the addition of 400 soldiers and their families would have on housing, schools, traffic, and so forth. The DEIS state:, that the exchange would involve implementing 11 training range and training support infrastructure: construction projects but fails to provide any meaningful discussion of the effects of these projects.

Also, the DEIS does: not consider or evaluate  the additional  facilities  that  the  4125th IBCT would require Because it is an airborne wut (rigging facilities, airborne deployment facilities, and parachute training areas and drop zones).

Response: The discussion of the effects for the JBCT that would come to Hawaii under Alternatives Band Chas been updated.

11. The EIS should disclose a backup plan in case no permanent station is ready to receive the 2/25th SBCT upon its return from tour in 2008.

Response: The three alternatives evaluated in this EIS are the only reasonable alternatives thot the Army could implement to meet the purpose and need for the permanent stationing of the l /25′h SBCT. Currently. the Army anticipates the re/urn of the 2/25th SBCT from deployment in early 2009.
12. The DEIS states that decisions regarding transformation , national security strategy, and other decisions made in the NSS, NOS, and QDR are  not  revisited  in  the  document.  Were  EISs done for these?

Response: No EISs were prepared for these documents. The NSS, NDS, and QDR are high-level notional security policy documents applicable across all military departments and ore not major federal actions with the potential to result in significant impacts on the human environment. In addition, these strategies and policies do .not’result in direct, indirect, or cumulative impacts capable of meaningful evaluation of value to a decision maker. Their implementation through Army Transformation, Army Growth and Restructuring, and installation-specific realignment and closures under the Base Realignment and Clo­ sure 2005 law have oil been supported by NEPA analyses. Thus, we made no changes to the EIS in response to this comment.

13. Please provide a table that compares the projected increases for all elements of the SBCT and IBCTs Wider consideration in all locations. The elements include numbers of officers, soldiers. vehicles (by types). weapons, ranges, support facilities. and areal extent of new land.

Response: Tables that provide the information requested in this comment are included throughout the alternatives discussions in Chapter 2. Please refer to Chapter 2 to review the tables.

14. On page 1-10, the DEIS states that {Force] requirements must be taken into account when the decision on where to station the 2125th permanently is made.. .many of these force requirements arc classified. As far as possible, indicate the points at which classified information is influencing the decisions.

Response: ‘There is no classified information in this EIS that has been used to support the stationing decision/or the 2/25tlt SBCT

15 On page 2-18, the DEIS states that this EIS does not analyze the training impacts of SBCT at MM R. On page 2- 23, it states that aH required uses of MMR are being addressed in a separate NEPA document. Is this segmentation? The March 2005 Draft EIS for Military Training Activities at MMR indicates training requirements for MMR would increase with the stationing of an SBCT at Schofield Barracks. This DEIS needs to address the direct, indirect, and cumulative effects to MMR that would result from stationing an SBCT or rBCT at Schofield Barracks and the resumption of military training at MMR.

Response: Section 2.5 explains that attainment  of operational  readiness  by  the 2125″‘  is not dependent on the use of MMR. While the MMR i.s an integral part of USAG-HI   training capabilities   and  historically   used   by  other  services,  the units of the 2125th could perform dismounted Jive-fire training at other ranges. The SBCT might use MMR if the range were available following completion of the Makua FEIS and ROD for use of that range. Any potential usage would remain within the levels and frequencies described within the MMR EIS  when it is completed. Please note the Makua EIS process is ongoing. The Army believes this EIS adequately addresses appropriate impacts.

16 . The  DEIS states on  page 2-22 that ranges include potentially  brigade level live-fire capability at PTA. Where arc the impacts of this analyzed in the document?

Response: The DEIS indicated that the SBCT could potentially conduct live-fire exercises at the brigade level. However, there is no training requirement to do so and the Army does not  project  that the SBCT would ever conduct  a live-fire exercise with the entire BCT at PTA. Section 5.2 presents the results of the analysis of impacts of live fire training conducted to attain training readiness. The impacts would not differ at PTA if the Army conducted one training exercise for the entire SBCT versus muhiple separate training exercises for its battalions. Section 5.2 covers the impacts projected lo occur under either scenario. Since the Army does not project the need to conduct live-fire training at the brigade level, however, this text has been changed in Chapter 2 to delete discussion of potential brigade live-fire training exercises.

17 The DEIS needs to address the deployment time from the various locations. Opinions vary on whether Hawaii or Alaska offers a quicker deployment time to Southeast Asia and the DEIS should answer the question . Also, the DEJS should address the lack of cargo aircraft in Hawaii that are capable of transporting Strykers compared to the U.S. mainland.

Response: The Army discusses the advantages in deploying to Southeast Asia from Hawaii in Section 2.4.3 along with the other factors leading to Hawaii ‘s selection as  the  Army’s Preferred  Alternative.  The Army recognizes  that  Alaska  and Hawaii both offer strategic deployment advantages for stationing forward deployed forces in the Pacific Rim. Hawaii, however, is much closer to countries of the South Pacific, and could respond much more rapidly than troops stationed in either Alas/ca or Colorado. In addition, Hawaii provides the Army with key strategic redundancy to Alaska in times of inclement weather and low winter temperatures preventing air deployment as is also discussed in Section 2.4.J.

Deployment  time and other strategic deployment  factors,  such as aircraft  and sealift, are being considered in the decision-making process. Exact tables of times and distances and the locations and numbers of aircraft available for deployment would represent classified information and would not be used in making the .stationing decision for the 212S’

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 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 2125th 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 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 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  2125th  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 3125th 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:


(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 2nd 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  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 2125th 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.

Chart Graph Placeholder

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 212511 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 2nd 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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