Carol Van Strum is the author of "A Bitter Fog: Herbicides and Human Rights" a book documenting the use of Agent Orange in the Pacific Northwest. She has written exposes on chlorine and dioxin contamination in feminine hygiene products for Greenpeace, as well as book reviews on environmental, history and children's books for the Washington Post, USA Today and the New York Times.
Below is a letter by Carol, responding to the Navy's Environmental Impact Statement on its proposed expansion of the Northwest Weapons Training Range Complex (NWTRC) along the Pacific NW Coast, where she lives.
Naval Facilities Engineering Command Northwest
1101 Tautog Circle, Suite 203
Silverdale, Washington 98315-1101
ATTN: Mrs. Kimberly Kier – NWTRC EIS
Re: Preliminary comments on NWTRC EIS/OEIS
This letter presents my preliminary comments on the draft U.S. Navy Northwest Training Range Complex Environmental Impact Statement/Overseas Environmental Impact Statement, volumes 1 & 2, hereinafter referred to as the EIS.
I consider these to be preliminary comments because I was unaware of the EIS or the Navy's proposed actions until two weeks ago, when I learned via word of mouth of the public meeting held January 30, 2009, too late to be able to attend, particularly as the meeting was held some 45 miles from my home.
Due to the Navy's gross failure to inform the public, Oregon's Congressional delegation has asked the comment period on the EIS to be extended to April 11, 2009, but as there is so far no response to the congressional request, I prepare these comments after only a cursory review of the EIS.
The Navy EIS fails to meet the requirements of the National Environmental Policy Act (NEPA) in at least five major respects, any one of which warrants withdrawal of the entire EIS and cancellation of the actions proposed therein.
1. Failure to identify past, current and future activities in the waters off Oregon and northern California, which comprise most of the area involved in the EIS.
Because the EIS purports to discuss environmental impacts of Navy activities in an area encompassing the entire Oregon coastline, territorial waters, and beyond, its failure to identify those activities precludes meaningful comment and invalidates all conclusions of no significant impact, rendering the entire document invalid.
A "no action" alternative should, as the name implies, mean no action. In Navy parlance, however, the Navy's deceptively named "No Action" alternative reveals that "no action" actually means to continue activities which the Navy claims to be already conducting off the Oregon coast; however, the EIS nowhere identifies what those current activities are, where they are occurring, for how long they have occurred, or what environmental impacts of those activities have already accrued; furthermore, the EIS nowhere identifies any previous environmental assessment or environmental impact statement describing/identifying these current and past.
The question of past and current Naval activities is highly significant. For example, the EIS acknowledges that past and present activities off the Oregon coast have involved the use of rounds comprised of depleted uranium. Uranium, depleted or otherwise, is an exceptionally persistent material in the environment. The EIS revelations of Navy use of depleted uranium thus raise very serious concerns about how long the Navy has been using depleted uranium rounds in the Pacific Ocean, how much was used per year, where that use has occurred, and what environmental impacts have already accrued from such use, such as uptake by fish and synergistic effects with other wastes and products from Naval exercises. The EIS mentions none of these issues.
As current activities off the Oregon coast are not covered in this or any environmental impact statement or assessment, such activities are therefore unlawful and the Navy should immediately desist from all activities of any kind in waters from the Oregon coast to the 250-mile limit until such time as valid environmental documents, addressing all current and past activities and their effects, have been prepared and adequately made public to the people of Oregon.
2. Total failure to support a finding of no significant impact for Oregon and northern California waters.
The EIS states that its proposed action "may have coastal effects" in the state of Washington, but that "For the States of Oregon and California, the Navy has determined that its Proposed Action will have no coastal effects." (The coastal zone extends 3 nautical miles seaward from the shoreline.)The EIS absolutely nowhere describes either what the proposed action is or will be in Oregon and California coastal waters, or what the effects of the unnamed proposed action will be in those waters. For example, see Table 4-2, pp. 4-3 to 4-7, "Past, Present and Planned Future Projects in the Offshore Area," which does not include a single project identified for Oregon or northern California.
For further example, the word "Oregon" occurs on some 106 pages in Vol. I of the EIS, and on 23 pages of Vol. II; on at most only five (5) of those pages does the phrase "no significant impact" also occur, and on none of these five pages are any specific actions or locations mentioned.
The Navy EIS determination that the Proposed Action will have no coastal effects in Oregon and California is therefore arbitrary, capricious, and entirely unsupported by any evidence whatsoever. The entire EIS should be withdrawn for that reason alone.
3. Repeated assumptions of no impact based on absence of data, and repeated findings of no significant impact unsupported by either data or references.
Throughout the entire EIS, the Navy exhibits a blatant don't look, don't tell policy toward environmental effects, using an absence of data to justify an assumption that no effects occur.
"The study area for consideration of impacts on marine plants and invertebrates includes the open ocean west of Washington, Oregon, and northern California....Aircraft overflight and training activities are assumed to have no impacts to marine communities, because impacts of sound on plants and invertebrates are unknown and difficult to quantify."
Similarly, the EIS repeatedly states a finding of no significant impact totally unsupported by data or even references, e.g., Tables ES-3 Summary of Effects – Geology and Soils; and ES-4 Summary of Effects – Air Quality, which typically conclude, with no data, first that the impacts would be the same as Alternative 1 (for which no specific activities, locations, or impacts were described for Oregon or California), and second, that no significant impacts would therefore occur.
4. Blatant failure to examine obvious and feasible alternatives such as reducing or eliminating all testing and training actions in the area.
The EIS fails to examine or consider such obvious and feasible alternatives as reducing or eliminating all training and testing activities in the ocean and territorial waters off Oregon and northern California; or conducting such exercises in other areas of the ocean, such as islands being submerged by rising waters due to global warming, or areas infested by pirates that would provide excellent practice for Naval anti-piracy activities.
5. Monumental failure to notify the public or concerned parties from the outset, precluding meaningful review and comment at any stage of EIS development.
From the outset, the monumental failure of the Navy to notify the public or concerned parties of its proposed actions totally precluded meaningful public participation, review, and comment. The Navy's sole public notice of the 2007 notice of intent/scoping phase of this EIS was placed in a single Oregon newspaper, the News Guard, a small weekly in the coastal town of Lincoln City read by very few people outside the immediate vicinity of Lincoln City, thus depriving most of the state and entire coast of any notice whatsoever.
According to the EIS, notice of publication of the current draft EIS was placed in the same paper in December, 2008, announcing a public meeting January 30 in South Beach (not Depoe Bay, as the EIS states).
However, the editor of the News Guard emphatically reported that the paper received no such notice whatsoever and knew nothing of the public meeting until after it occurred. Although the Navy placed small, almost invisible, unreadable ads in a Newport newspaper prior to the meeting every person who attended – including the Newport paper's reporter -- stated that they learned of it only through word of mouth.
Thus a meeting and publication of vital importance to the entire state and especially its 362-mile coastline, was to all intents and purposes a well-kept secret, regardless of Navy protestations to the contrary.
The EIS and the proposals the Navy has devised should therefore be withdrawn and the entire process started over from scoping notice on. For the above reasons, I advise the U.S. Navy to withdraw its EIS and correct the grave shortcomings of both its content and the process of public notice identified above before bringing its proposals forward again.
Carol Van Strum