|From:||Lenny Siegel <email@example.com>|
|Date:||Tue, 11 Jan 2011 16:18:34 -0800 (PST)|
|Subject:||[CPEO-MEF] Newport Chemical Depot (IN) comments by Hoosier Environmental Council|
December 18, 2010 Ms. Cathy Collins Engineer Newport Chemical Depot PO Box 160 Newport, IN 47966RE: Comments on Environmental Assessment and Draft Finding of No Significant Impact for Disposal and Reuse of Newport Chemical Depot
Dear Ms. Collins,The Hoosier Environmental Council submits the following comments on the EA and draft FNSI referenced above.
Finding of No Significant ImpactA finding of no significant impact is not appropriate for the proposed action, given the absence of key reuse information in the Environmental Assessment, and the provisions of the Newport Chemical Depot Reuse Authority's (NeCRDA) Reuse Plan which allows the destruction of an important natural resource present at the facility. Therefore, the Army should find that there will be significant environmental impact from the disposal and reuse of the property, and prepare a full environmental impact statement.
1. A high intensity reuse option has been proposed for a portion of the facility which would have major impact on the environmental resources at the Newport facility and surrounding area. This proposed reuse project involves construction and operation of a coal liquefaction plant. This would be a major industrial facility, with potential impacts to air quality, water quality, disturbance or destruction of forest, wetlands, and prairie, and a dramatic change in the nature of the property. This possible type of reuse activity was mentioned in the NeCRDA's reuse plan, but is inconsistent with the low intensity reuse and medium-low intensity reuse alternatives evaluated in the Environmental Assessment. The EA states, "Achieving conversion and redevelopment goals would, at build-out, most closely resemble an Medium-Low (ML) scenario." (Page 3-10).
Such a major industrial facility would be accurately characterized as either a medium-high intensity, or high intensity reuse, both of which were deemed "impractical" in the EA (page 3-6). The EA states, "No land use conflicts would be expected from implementing the reuse plan." (page 4-6). A major industrial operation such as a coal liquefaction plant would not only conflict with other planned uses within the Newport property, but also with the low-intensity land use practices and economic activity occurring in the surrounding areas. Desirable and compatible economic development, such as high-tech or life-sciences industries would be unlikely to locate nearby a major polluting industrial facility.
2. Neither the NeCRDA reuse plan, nor the Army's disposal action, provide for protection of the 336 acre black soil tallgrass prairie area, which is a rare and biologically valuable natural area deserving of permanent protection. Instead, the reuse plan includes most of this prairie area in an agricultural and forestry designation, meaning it could be plowed and planted to row crops in the future. The EA acknowledges this, stating, "some loss of the restored prairie areas would be expected." (page 4-36) Contrary to the EA's statement, "tallgrass prairie" is not an agricultural reuse.
It is illogical, and inconsistent with a goal of the NeCRDA reuse plan, to include a high quality natural area such as this black soil tallgrass prairie area in a reuse category that may allow its destruction. It is unimportant that this prairie area is restored prairie, because it represents, now and in the future, a rare and important natural community that is worthy of preservation. Given that this prairie area constitutes less than 5% of the total Newport area, and that more than 3,000 acres would remain for business and technology reuse, it is wholly reasonable and prudent to permanently protect this area.
The Army's disposal action should require that this prairie area be included in the "natural areas and open space" reuse classification, or otherwise assure its permanent protection through an easement or other encumbrance.
3. The EA's evaluation of public benefit conveyance outcomes is limited and incomplete. The Army should conduct a thorough review of the Notices of Interest applications, and reach an independent conclusion on the merits of these requests and whether they should be granted.
ConclusionThe EA for the disposal and reuse of Newport Chemical Depot is inadequate for the following reasons: a limited analysis of public benefit conveyances as reuse alternatives; the failure to fully evaluate the disposal action's effect on an important natural resource, the tallgrass prairie area; and, the lack of evaluation of major industrial reuses that are being considered for the Newport property by other interests. These deficiencies result in the Army's Environmental Assessment failing to provide a sufficient level of NEPA analysis. The Army should reach a finding of significant impact for the Newport Chemical Depot disposal action and prepare a full environmental impact statement which evaluates industrial reuses and their compatibility with the medium-low and low intensity reuses contemplated by the NeCRDA reuse plan and EA. The EIS should also include a disposal alternative which provides for full protection of Newport's important natural areas and habitats-- forests, prairie, and wetlands.
Sincerely, Tim Maloney Senior Policy Director Hoosier Environmental Council 3951 N. Meridian St., Suite 100 Indianapolis, IN 46208 -- Lenny Siegel Executive Director, Center for Public Environmental Oversight a project of the Pacific Studies Center 278-A Hope St., Mountain View, CA 94041 Voice: 650/961-8918 or 650/969-1545 Fax: 650/961-8918 <firstname.lastname@example.org> http://www.cpeo.org _______________________________________________ Military mailing list Military@lists.cpeo.org http://lists.cpeo.org/listinfo.cgi/military-cpeo.org
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