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Comment Opposing Helicopter and HAMET Training on Public Lands in Washington

July 29, 2015


Re:      Scoping comment

Proposed Off-Base Helicopter Training Areas (HTA-HAMET)

To Base Commander Hodges:

Peaceful Skies Coalition (PSC) is submitting comments on the Scoping for Off-Base Helicopter Training Areas, hereinafter referred to as HTA-HAMET. The Aviation Division, Directorate of Plans, Training, Mobilization, and Security at Joint Base Lewis-McChord (JBLM) proposes to establish three off-base helicopter training areas (HTAs) and one mountain training area (MTA).

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 Commenters further request that these comments be included as part of the administrative record.

Controversial Proposal Requires an EIS

It is the position of the PSC, that because of the extraordinarily controversial nature of this proposal, the HTA-HAMET will require a full Environmental Impact Statement. Because of the inclusion of National Forests, State Lands, a National Park and a Wilderness Area this scheme requires the highest level of public involvement and analysis of environmental impacts. An EA for this proposal will not satisfy NEPA requirements, neither statutorily nor compliance with settled case law. PSC believes that this proposal should be withdrawn because among the other problems with the scoping document, JBLM has failed to establish a need for the project. This proposal better demonstrates the inefficiencies and lack of communication among bases than it does a need or justification for any of the three proposed HTAs or the HAMET. The current proposed proliferation of HTA’s across our public lands illustrates the need for leadership at the top of the Department of Defense to stop the duplication and triplication of training zones, especially those on public lands both state and federal. On December 19, 2014, PSC commented on a scoping document for a proposed HAMET on BLM land (Royal Gorge Field Office) initiated by Fort Carson. A significant part of the justification was to expand the space available for high altitude training, citing the needs of the army as a whole and the ability to train units from other bases, including service members from JBLM. Now however, only several months later, with this proposal, the public learns that JBLM wants its own HAMET.

Special Protection of Wilderness Areas

National Wilderness Preservation System of federal lands consists of places “where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain,” (CRS, 2011)

JBLM does not explain how it intends to gain permission to access the Alpine Lakes Wilderness Area and its surroundings. The Congressional Research Service report, Wilderness Laws: Statutory Provisions and Prohibited and Permitted Uses, 2011 identifies rare instances where Congress has statutorily permitted military training in specific wilderness areas. Alpine Lakes Wilderness Area has not been exempted. CRS only addresses low altitude overflights. Land-based military training with the extreme over-reach proposed in the HTA-HAMET threatens the entire purpose of National Wilderness Preservation through its potential to set a dangerous precedent for further military use of wilderness lands.

In order for the public to provide informed comment on the proposed HTA-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 HTA-HAMET boundaries.

MAPS Included in the Scoping Document are Intentionally Deceptive

The HTA-HAMET scoping document contains twelve maps. Not one map (zero) contains any information with regard to state and federal lands, public facilities such as schools and hospitals, towns and cities, and other important landmarks. This is consistent in every map; page 7, page 19, page 20, page 23 and pages 26 – 33, not one provides any information about what is on the ground in each proposed HTA. These maps turn our communities and lives into terrain belonging to the military with lines drawn around the proposed training areas as if they were fences or walls.

The maps make no demarcation of state lands, national forest, national park, or wilderness area. Deceptive maps such as these are designed to mislead the public. The proposed HAMET (MTA) would turn pristine and spectacular land, lakes, rivers and waterways into a series of polluted, noisy military landing bases. This must not be allowed.

Peaceful Skies Coalition again requests that the Department of Defense require informational maps in each and every NEPA document.

Department of Defense Must Establish a Comprehensive Baseline for proposed NEPA Actions

Peaceful Skies Coalition, repeatedly and again with this comment, calls 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.

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 Washington. Forest fires are raging in the state as this comment is being prepared. 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.

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. 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.

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