The Grey Papers – US EPA on the DEIS

What are the government agencies saying about the buildup? What did the DEIS say about the buildup?
Read The Grey Papers. Short. Straight. In Their Own Words.
compiled by We Are Guåhan

This issue: U.S. Environmental Protection Agency

Download: The Grey Paper – US EPA on the DEIS here.

A full copy of US EPA’s comment can be found at:
http://www.epa.gov/region09/nepa/letters/Guam-CNMI-Military-Reloc-DEIS.pdf

Summary:

• There will be up to a 13.1 million gallon shortfall of drinking water per day for people living off-base in 2014.
• 85% of Guam relies on our aquifer for drinking water, yet the DEIS fails to guarantee the protection of our aquifer from bacteria and toxic contaminants.
• DoD has not identified where the $1.1 billion needed to improve Guam’s water and wastewater systems to handle the buildup will come from.

Quotes from EPA’s Comment:

EPA on Drinking Water

1. “The water supply shortfall predicted is substantial.  The DEIS projects that the shortfall in water supply from GWA will begin in 2010 with the largest anticipated shortfall of at least 6.1 million gallons per day (mgd) occurring in 2014.  This shortfall will occur even with GWA’s planned expansion of 7 mgd through the installation of 16 new wells.  If GWA expansion does not occur, the shortfall could be as high as 13.1 mgd in 2014.”  EPA Comment, p. 4.
2. “Should significant impacts to utility infrastructure be left unmitigated, water outages or low pressure conditions could occur which could lead to illness and effect firefighting, and wastewater discharged from a treatment plant can enter the environment where human exposure may occur through the potable (drinking) water supply, recreation (swimming, snorkeling, etc.), or eating shellfish.”  EPA Comment p. 83.
3. “There is uncertainty regarding the sustainable yield of the NGLA, and DoD has not completed an updated assessment.  Rather, DoD is relying on an administrative review of a 1992 study that estimated the sustainable yield of the NGLA at 80.5 mgd.”  EPA Comment p. 11.
4. “The proposed actions include many threats to the NGLA, and without sufficient detail regarding these threats, it is not possible to determine whether this valuable resource will be adequately protected from contamination during and after the build-up.”  EPA Comment p. 11.
5. “The DEIS relies upon GWA to finance and execute major capital improvement projects to upgrade its wastewater infrastructure.  The DEIS does not evaluate GWA’s financial capacity and rate payer’s ability to pay its other water and wastewater needs, which total approximately $900M, plus costs for upgrading the NDWWTP to full secondary treatment (estimated at approximately $200M).”  EPA Comment p. 20.

EPA on Our Reefs

1. “Impacts to coral reefs on the scale proposed in the DEIS are unprecedented in recent CWA 404 permit history.”  EPA Comment p. 33.
2. The DEIS does not demonstrate that significant impacts to [the Haputo Coral Reef Ecosystem] can be mitigated to less than significant.”  EPA Comment p. 40.

EPA on Noise & Pollution

1. “The DEIS appears to underestimate the significance of noise impacts.”  EPA Comment p. 85.  “The analysis calculates the number of acres that will experience increases in noise impacts for ongoing operations, but does not translate this into an estimate of the number of individuals that will be affected . . . so the extent of noise impacted individuals is not known.”  EPA comment p. 86.  “The noise impacts from the Anderson AFG ISR Strike DEIS alone were substantial, with the analysis showing that 2,310 people off-base will be exposed to sound 65 dBA . . . and above, with 552 potentially highly annoyed by the change, representing roughly ten times more people experiencing these impacts [than] at present.”  EPA Comment p. 85.
2. “While the [Environmental Justice] analysis identifies ‘traffic’ as a significant impact, it does not disclose the air quality and health impacts from significant traffic congestion during the construction phase .”  EPA Comment p. 83.  “There is evidence that environmental justice communities are more vulnerable to pollution impacts than other communities.  Disadvantaged, underserved, and overburdened communities are likely to have pre-existing deficits of both a physical and social nature that make the effects of environmental pollution more, and in some cases, unacceptably, burdensome.”  EPA Comment p. 83.

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