Comment Opposing HAMET Training on BLM Land in Royal Gorge, Colorado
Peaceful Skies Coalition
Re: Scoping comment Bureau of Land Management Royal Gorge Field Office,
To Bureau of Land Management:
Peaceful Skies Coalition (PSC) is submitting comments on the Plan of Development, High Altitude Mountain Environment Training (HAMET) submitted to the Bureau of Land Management by Fort Carson and the US Army Corps of Engineers, Omaha District. Limited HAMET activities have been carried out in this area in the past on US Forest Service land under a Casual Use Agreement.
Due to the tremendous increase in scope of the proposal and the controversial nature of the addition of forty-three helicopter landing zones (HLZ) and an exponentially greater number of flights for high altitude training, the Bureau of Land Management needs to reject the Plan of Development as submitted by Fort Carson and prepare an Environmental Impact Statement. The coalition does not agree that this project affords the BLM the authority to bypass the National Environmental Policy Act (NEPA) to approve this as an “easement” under by Title V of the Federal Land Policy Management Act of 1979, as amended.
As stated in the CFR Title 43: Public Lands: Interior
PART 46—IMPLEMENTATION OF THE NATIONAL ENVIRONMENTAL POLICY ACT OF 1969:
- 46.100 Federal action subject to the procedural requirements of NEPA.
(a) A bureau proposed action is subject to the procedural requirements of NEPA if it would cause effects on the human environment (40 CFR 1508.14), and is subject to bureau control and responsibility (40 CFR 1508.18).
In order for the public to provide informed comment on the Royal Gorge HAMET, the public needs to be provided all information about adjacent and other proposed federal projects; whether those on public lands, private lands, or military land and airspace. A bioregional approach is essential to an accurate impacts analysis. The lands within the boundary area comprise only a part of the larger bioregion. Avian flyways, watersheds, wildlife migratory pathways, air and water quality and other natural systems extend well beyond the boundaries of the proposed HAMET boundaries.
Special attention should be paid to the severe drought and fire danger, both within and adjacent to the proposed HAMET. Extraordinary protection of the public lands must be the highest priority of public land managers. Mitigation and remediation will be next to impossible to accomplish with the lack of water. A high degree of stress is already affecting the resiliency of the land and the species that live in and around the region.
Cumulative impacts have not been presented for this proposed expansion project. Cumulative impacts must include all activities in the area, not only those in a narrow geographical location. As stated above, the study should consider entire bioregions, not just the area within the proposed HAMET boundary. The Federal courts have ruled that the government “cannot isolate a proposed project, viewing it in a vacuum.”
As the NEPA analysis is prepared, establishing the proper geographic scope or boundary for a cumulative impacts analysis is extremely important because the proposed action will have direct, indirect, and “additive” effects on resources far beyond the immediate area. By way of example, for resident or migratory wildlife, the appropriate geographic area for the cumulative impacts analysis will be the species habitat or breeding grounds, migration route, wintering areas, or total range of affected population units. Consideration of other state, private, and other federal actions as well as natural occurrences or events that have taken place, are taking place, or proposed to take place that will similarly impact the region’s wildlife populations and habitat, and human communities.
We hope you find these comments to be helpful, informative, and useful in your efforts to bring this expansion into compliance with the NEPA and other substantive statutes. Peaceful Skies Coalition requests that Carol Miller, an officer of the coalition, be placed on the recipient list for notices of any developments in the HAMET proposal as it moves forward.
If you have any questions or comments, or wish to discuss the issues raised in this comment please do not hesitate to contact the Peaceful Skies Coalition representative.
Carol Miller, Peaceful Skies Coalition