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Comment Opposing Helicopter Training in the Lincoln National Forest of NM
Peaceful Skies Coalition
July 19, 2016
Re: Scoping comment
High Altitude Mountain Environment Training Strategy (HAMETS) Helicopter Operations Project
To Travis Moseley, Forest Supervisor:
Peaceful Skies Coalition (PSC) is submitting comments on the Scoping phase of the proposed Lincoln National Forest High Altitude Mountain Environment Training Strategy (HAMETS) Helicopter Operations Project hereinafter referred to as LNF-HAMET. The Forest Supervisor of the Lincoln National Forest has been designated as the responsible party to manage the consideration of this proposal by Fort Bliss Army Base.
The Commenter requests that Carol Miller, President of the Peaceful Skies Coalition, be placed on the recipient list to receive notice of any developments in the NEPA process as it moves forward. The Commenter further requests that these comments be included as part of the administrative record.
Peaceful Skis Coalition believes that this proposal should be withdrawn because, among the other problems with the unacceptably cursory scoping document, Fort Bliss has failed to establish a need for this project. Fort Bliss is the second largest Army base in the world. The largest, White Sands Missile Range abuts Fort Bliss and ecologically, they are effectively a single entity. There is more than enough sufficient area between the two bases to conduct the proposed training.
This HAMET proposal, like others on which the PSC has commented, better demonstrates the inefficiencies and lack of communication among bases than it does a need or justification for any Helicopter Landing Sites (HLZs) in the Lincoln National Forest. The current number of HAMETs across our public lands, illustrates the need for leadership at the top of the Department of Defense. It is time to stop the financial and environmental wastefulness resulting from the duplication and triplication of training zones, especially those on state and federal public lands. Peaceful Skies Coalition is joined by community organizations across the country that have become aware of Pentagon efforts to dangerously expand training into the last remaining public lands. These communities are organized and committed to protecting and defending our public lands.
Unacceptable Risk of Fire Danger
Across the state of New Mexico, no public lands are suitable for High Altitude Mountain Environment Training, the type proposed by Fort Bliss to conduct in the Lincoln National Forest, home of the original Smokey the Bear. Lincoln National Forest has suffered tremendous forest fires over the decades. Despite being subject to various forest management and treatment practices, uncontrolled fires continue to threaten the forest, eco-systems and affected communities.
Right now, as this comment is being written, “Three fires erupt in Otero County” is a recent headline in the Ruidoso News. The article states that “Sixty-seven structures, 16 vehicles and 14 recreational vehicles were destroyed or damaged in Timberon as of early Friday, and one engine from the Timberon Volunteer Fire Department was burned.” (July 15, 2016)
Extraordinary protection of the public lands must be the highest priority of public land managers. Special attention should be paid to the severe drought and fire danger present within the State of New Mexico. Mitigation and remediation will be next to impossible to accomplish with the shortages of water and climate change. A high degree of stress is already affecting the resiliency of the land and the species that live in and around the region.
Controversial Proposal Requires an EIS – Endangered and Threatened Wildlife
The only reference to a protected species in the Scoping letter is this one sentence about the Mexican Spotted Owl: “HLZs within 500m of Mexican Spotted Owl Protected Activity centers will not be utilized for HAMETS training during the 1 March to 30 August time period.
The purpose of scoping is to get public input for inclusion in the development of further environmental assessments. With only the single mention of the Mexican Spotted Owl, the public is misled into seeing the area as non-critical habitat. This is obfuscation.
A stark contrast to the one sentence in the Scoping letter is presented in the Lincoln National Forest document Southern Sacramento Mountains Restoration Project, CFLRP Proposal, Lincoln National Forest, 2011. This more comprehensive document describes the area as critical habitat (emphasis added):
- The proposed area is significant socially, ecologically, and economically. Socially, it represents one of the largest contiguous blocks of Wildland Urban Interface found in southern New Mexico. Ecologically, the area contains the largest number of Threatened and Endangered species (namely, Mexican Spotted Owl or Strix occidentalis lucida) per acre within the Southwestern Region. (page 7)
- [calls for] less damage to the Sacramento Checkerspot butterfly (page 9)
- Areas within the SSMRP currently designated as Mexican Spotted Owl protected activity areas, or northern goshawk nest areas can also be de facto old growth target areas. (page 9)
Source: Southern Sacramento Mountains Restoration Project, CFLRP Proposal, Lincoln National Forest, 2011 http://www.fs.fed.us/restoration/documents/cflrp/2011Proposals/Region3/Lincoln/LNFCFLRPProposal.pdf
More information about the endangered, threatened and protected species in the Sacramento Ranger District should have been included in the Scoping letter. Proximity of protected areas to the proposed HLZs should have been shown on the map included in the Scoping letter.
Adjacency of Current and Other Proposed Federal Projects
In order for the public to provide informed comment on the proposed LNF-HAMET, the public needs to be provided all information about adjacent and other proposed federal projects; whether those on public lands, private lands, military land, waterways, or airspace. A bioregional approach is essential to an accurate impacts analysis. The lands within the boundary areas 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 LNF-HAMET boundaries.
MAPS Included in the Scoping Document are Intentionally Deceptive
The LNF-HAMET scoping document contains only one map with very low resolution and no information with regard to state and federal lands, public facilities such as schools and hospitals, towns and cities, and other important landmarks. This out-of-focus map reduces communities and lives into terrain belonging to the military. The map shows only where landing zones are proposed but no information about human, range animal or wildlife impacts.
Many better maps of the area are available online but the included map was selected. Peaceful Skies Coalition again requests that all NEPA actions by or on behalf of the Department of Defense require informational maps in each and every NEPA document.
Federal Agencies Must Establish a Comprehensive Baseline for proposed NEPA Actions
The Forest Service should know that Peaceful Skies Coalition, has repeatedly and again with this comment, called on the DoD to establish a proper baseline upon which to base all DoD impact analyses. A “trends analysis,” is mandated by law to assure an independent assessment of the environmental impacts of all activities affecting the various resources over an extended period of time. By failing to properly define the baseline and from the baseline engage in a trends analysis, it is not possible to track any effects and changes that occur over time.
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 consisting of breeding grounds, migration routes, wintering areas, and the total range of affected population units. NEPA documents are required to include other state, private, and 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.
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, President, Peaceful Skies Coalition