Tuesday, September 28, 2010

Proposed AF Fly-overs in Northern NM and Southern CO part of expansion?

PCEOC has a number of concerns with the LATN Environmental Assessment (EA) that has been published by the Air Force, proposing low altitude training flights of C-130 and CV-22 Osprey in Northern New Mexico and Southern Colorado.  Our concerns and questions are related to the following areas:

•    We are concerned that this EA (EA requires NO public meetings etc.. and is the simplest process required by NEPA) represents the segmentation of a larger foreseeable project; the militarization of Southeastern Colorado and the creation of Department of Defense facility for Joint Forces training through the expansion of the Pinon Canyon Maneuver Site.

•    We are concerned about Noise Pollution and associated disruptions to wildlife, recreation and ranching activities and that flights at 200 feet will jeopardize buildings, livestock, and other man-made obstructions.

We are concerned, based upon our previous experience, with the credibility and value of the whole NEPA process. The original EIS which established the Pinon Canyon Maneuver Site in the early ‘80s was poorly done. It didn’t even conclude with an official Record of Decision which would have given us an understanding of why that decision was taken.  So we view the current EA with a large dose of cynicism.

The land within and surrounding PCMS represents the cultural heritage and history of our region as well as the entire western United States in significant ways.  We are deeply concerned with the increased training burden upon the region that LATN would represent.  The EA does not even include a complete description of procedures to protect archeological, paleontological and other cultural resources at PCMS.

And it is not just general cultural and historic assets that are at risk. It becomes very personal when peoples homes, lands, including  birth places, wedding sites and burial grounds are involved. Numerous historic and family cemeteries exist within the proposed flight area.

It’s a sad day for America when good, hardworking, patriotic American ranchers have to defend their homes and their way of life against an invasion by its own military in the form of low altitude flights.

We are concerned that this EA segments a larger proposal, treating the proposed action within this EA as if independent from planned future actions, including plans to expand the Pinon Canyon Maneuver Site.  We believe that this segmentation is contrary to the intent of NEPA. We concerned that this EA will attempt to avoid an honest examination of the full scope of planning for the PCMS by splitting the project into smaller projects. We are concerned that by excluding known subsequent phases and associated project components from the EA, decision makers may not be provided with all necessary information to make a fully informed determination about the proposed action. We are afraid that the segmentation of this project may cause it to appear to be unrealistically acceptable to the reviewing agencies and the public.
All known phases of the future planned expansion of PCMS should be considered in the determination of the significance of the LATN proposal. While future phases of expansion at PCMS may be uncertain as to precise design or timing, their environmental significance should nonetheless be examined as part of this action by considering the potential effects of total PCMS build-out.

We believe that segmentation is occurring in the proposed action being considered within the EA for the following reasons:
•    Purpose: There is a common purpose between the LATN EA and the Expansion; namely the increased training burden imposed upon Pinon Canyon Maneuver Site. .
•    Time: The actions; Increased training load at PCMS and LATN are being considered at the same time. Even as this EA is being developed, the Department of Defense waiver, permitting the Army to acquire an additional 418,000 acres, as well as congressional authorization to expand PCMS remain active.
•    Location: There are common geographic locations for the proposed additional LATN,  and the Expansion. 
•    Impacts: These actions; additional training load imposed by LATN and Expansion, share a common impact that if reviewed as one project by decision makers will result in a significantly more adverse impact than if reviewed in segments. 
•    Ownership: These segmented aspects of PCMS development are being undertaken by the same lead agency, the Department of Defense. There is good reason to assume a comprehensive awareness to assume the existence of, and relationship between the two projects.
•    Planning: The EA to conduct low-altitude training in Southern Colorado is obviously a segmented component of an identifiable overall plan. This proposal  fits into the development of subsequent phases and the approval of LATN would prejudice the objective consideration of alternatives in subsequent phases.
•    Utility: The current EA and the Expansion represent interrelated phases of one project and should be considered functionally dependent on each other.
•    Inducement: The approval of LATN will put additional pressure upon the Army to Expand and induce legislative decision makers in relationship to future expansion legislation.

Pinon Canyon Expansion Opposition Coalition

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