Guam – Guam Fisherman’s Co-Op President Manny Duenas is recommending “no action” on Guam for the proposed firing range complex for the Marines.
In his formal submission ahead of tonight’s deadline to comment on the proposal, Duenas writes that Tinian should be the preferred choice.
“The Island of Tinian is willing to accept the Live-Firing of weapons in the M-50 class and greater,” writes Duenas and “the Field Exercises with the use of mechanize vehicles that too could be accommodated as the Tinian terrain would suffer from less environmental impacts than if conducted on Guam”
Alternatively, Duenas suggests that the existing firing range on Andersen Air Force Base “should be designated as the Primary Range where training with the M60 or weapons of smaller caliber to include anti-personnel devices can be conducted.” Or he suggests an “Indoor Firing Range.”
Duenas is also critical of the scoping process saying it “only demonstrates the genuine lack of effort on the part of the Military to listen to the concerns of the Community regarding the Proposed Action.”
He argues that the due date for the comments [TONIGHT] comes at a time “when the Community has a major Cultural and Spiritual Celebration [Easter].”
In addition, the SEIS documents “are quite lengthily … so it would take the average person weeks to digest the information in order to offer an informed comment.”
Duenas emphasizes that the Guam Fisherman’s Cooperative Association [GFCA] “supports the needs of the Military (as many of our members have proudly served) however the needs of the community must not be disregarded,” he writes.
Read Fisherman’s Co-Op President Duenas’ letter in FULL below:
April 6, 2012
Joint Guam Program Office
P.O. Box 153246
Santa Rita, Guam 96915
Public Comments regarding the Supplemental Environmental Impact Statement for a Live-Fire Training Range Complex on Guam to support the Guam Military Relocation:
First, the Process by which the Military conducts the Public Scoping Meetings is little to be desired. The Scoping Sessions seem to establish a semblance of compliance with the EIS Process. However, it only demonstrates the genuine lack of effort on the part of the Military to listen to the concerns of the Community regarding the Proposed Action. The US EPA which is the caretaker of the EIS Process along with the President’s Council on Environmental Quality conducts these Forums in the preferred manner where the Public is provided the information and then allowed to voice concerns. Again, we humbly request that all future “EIS or SEIS Public Scoping” Processes be modified to follow the true intent of “Public Participation”. This is an extremely important aspect of this Federal Mandate as this process evokes and satisfies the “Spirit of the NEPA Process” and a “Dog and Pony Show”.
Further, it seems that for each SEIS or EIS Scheduled Process the due date falls on or near the time when the Community has a major Cultural and Spiritual Celebration. In the previous “Build-up” EIS process while the community was granted an additional 45 days to “Comment” it was during the months when the greatest amount of time for “Family and Cultural” activities (All Souls Day to Three Kings) and in this case, “Holy Week”. Recognize that SEIS and EIS documents are quite lengthily (which is contrary to the NEPA document guidelines set forth by CEQ (150 pages max.) so it would take the average person weeks to digest the information in order to offer an informed comment. Again, please be cognizant that by that time the aforementioned community events too often assume its position of priority. One must recognize that comments if any, are too often trying to meet the deadline.
Lastly on the issue of Process, attempts to access the Website has been futile via computer. Lacking true information on the SEIS we can only hope our concerns remains “on Point”. However we would also like to raise the issue that all “Guam Land-Based Live-Fire Ranges” should all be in one SEIS/EIS Document in order to maximize an orderly discussion on the Cumulative Impacts by all the Ranges. The Surface Danger Zones and the lack of Public Outreach still remains an issue. Cumulative Effects by all other Local, Federal and Military actions on the Marine most especially the Fishing Community continues to remain unconscionable.
On the issue of the Proposed Actions:
We recommend the “No Action” Alternative until the following “Alternative” is added for consideration and evaluated. We all recognize that the alleged “Guam Military Relocation” has been scaled back. There is no urgent need to further this exercise without further thought or consideration as in the Apra Harbor dredging concerns.
Additional Alternative for consideration:
The Island of Tinian is willing to accept the Live-Firing of weapons in the M-50 class and greater. Should the case in point be the Field Exercises with the use of mechanize vehicles that too could be accommodated as the Tinian terrain would suffer from less environmental impacts than if conducted on Guam. We recall as part of the plan amphibious vessels are to be stationed on Guam which could include transporting the personnel to Tinian as part of their training. Further we too often criticize our small community of weekend off-road enthusiast about their impacts to our environment. What would be said when the Military field Exercises begin on our pristine southern mountains and valleys? We are all cognizant in any exercise there is a high probability of an accident occurring.
The Firing Range at AAFB should be designated as the Primary Range where training with the M60 or weapons of smaller caliber to include anti-personnel devices can be conducted. In addition, an Indoor Firing Range used to accommodate the same weaponry and with proper design perhaps the inclusion of the M50 and anti-personnel devices. It is environmentally sound where by all impacts from exercises are controlled; sulfur, projectiles and other metals can be recovered…recycled.
Also various climate effects can be employed such as windy conditions, torrential rain, bright sunlight, hot weather, night firing and so forth. The “Proposed Build-up” included an 8,000 man auditorium at NCTMS. Imagine what a 200 man Indoor Live-Firing Range could be used as; thus lessening the need for additional structures minimizing environmental damages and the need for a larger “Footprint”. Further, there are blank munitions for all caliber weapons which could be used during the Field Exercises (which allows for realistic fire event without mishap) in addition “High Tech” laser guided simulators can also be employed.
Please be cognizant that a 50 caliber machine gun fires over 40 pounds of projectiles a minute. No one has determined or forecasted the amount of metals introduced into our fragile environment in any given year. Given that not all will train on the 50 Cal. Of the 5000 personnel one can assume at least 500 personnel at 40 pounds (20K) of projectile is a quite a bit of sulfur and metal entering the environment.
Further the environmental impact of Kahoolawe (1/4 of Guam in size) in Hawaii despite one hundred million dollars spent on the “Clean-up” has not been resolved. Like Kahoolawe, the “cultural and traditional” aspect must not be ignored in the many proposed sites on and around Guam. Recognize that Kahoolawe is designated to be held in trust for future a Native Hawaiian Sovereign entity and all the while what would be the Legacy for the Chamorro; contaminated soil, fresh water (Contaminated wells on AAFB), air and ocean? At the end of the day we continue to be as the Admiral who testified before Congress, which we find more disturbing (after the Congressman who said metaphorically that “Guam will tip over”) where the Admiral stated “We own Guam”. Sadly, the following is an excerpt from the Senate hearings on the Ratification of the Terms of the Treaty of Peace after the Spanish-American War in which exhibited a minority radical sentiment:
“This Treaty will make us a vulgar, commonplace empire, controlling subject races and vassal states, in which one class must forever rule and other classes must forever obey.”
—Senator George Frisbie Hoar
In closing, for the record, the GFCA supports the needs of the Military (as many of our members have proudly served) however the needs of the community must not be disregarded by such. The people of Guam have been appreciative and have treated all guests with high regards we only expect the same in return. We humbly request that this “Proposed Alternative” offered be considered before any further Action. Kindly recognize that 18 million dollars is proposed to be used to construct a new and improved Sumay Cove Marina, 20 million dollars for a Dog Kennel and additional billions of dollars for an improved standard of living on the bases. Therefore we are confident that money can be sourced and used to construct an Indoor Firing Range to consolidate all Land-Based Firing Ranges. Interestingly enough providing for a “win-win scenario” that is if that is what is desired. Should you or your staff have any questions of concerns please feel free to contact our organization. Until then, we remain
Manuel P. Duenas II