Introduction & Background
The following comments are submitted by Senator Therese Terlaje, Chairperson of the Committee on Health, Tourism, Historic Preservation, Land and Justice for the 35th Guam Legislature regarding the 2019 draft Supplemental Environmental Impact Statement (SEIS) to the 2015 Mariana Islands Training and Testing (MITT) Final EIS.
Many fundamental concerns raised previously on the 2015 MITT and in the Scoping Period for the 2019 SEIS remain in the current Draft SEIS proposed here. Rather than a point-by-point analysis of the many sections of the SEIS, highlighted here again are the larger context issues that continue to remain significant to our people, environment and everyday livelihood in our region.
While the 2019 MITT Draft Supplemental EIS/OEIS provides key updates to the 2015 MITT FEIS/OEIS, the Navy states “proposed training and testing activities are similar to activities conducted in the Mariana Islands for decades” [https://www.mitt-eis.com; emphasis added]. The justification that these activities have been ongoing for decades does not legitimize these continued actions. While the Navy defines the MITT range as its “Study Area,” I object to this way of being imagined, recognized and treated in the area of global geopolitics. As stated in previous comments submitted by this government, the Marianas is our regional living grounds, our ancestral habitat for centuries before it ever became a study area for military testing and training, and it is our intent to maintain it as such for our generation now and in the future.
The hallmark of self-determination must be the safeguarding of a non-self-governing people’s right to its own natural resources and the right to participate freely in any decision-making concerning those limited resources. It is also critically important in this time of climate change that Guam, a small island, be allowed to protect its existing resources that will increase the absorption of carbon dioxide, increase the protection of shores against rising tides, and maintain its biodiversity as a hope for the future wellness and economic independence of its community.
Studies have found over 100 contaminated sites on Guam. Almost all of these are from U.S. military activity and dumping, and result in the people of Guam’s continued exposure to many cancer-causing agents, including radiation from nuclear testing, Agent Orange, and polychlorinated biphenyls (PCBs).
One third of Guam that the U.S. military controls and uses for its continued activity, expansion, and nuclear storage, includes areas above the aquifer, adjacent to the fresh water lake, and along the coast, while designated cleanup sites are ignored.
Guam has sought but been denied in U.S. compensation programs for radiation exposure despite high levels of cancer rates and findings by the Board on Radiation Effects Research (BRER) Committee that the people of Guam were exposed as downwinders of the U.S. nuclear testing in the Marshall Islands from 1945 to 1962. Similarly, the U.S. denies Agent Orange use on Guam during the war despite the accounts of military personnel admitting to staging, transporting, and spraying the herbicide on Guam.
In addition to the establishment of the Mariana Islands Range Complex (MIRC) and the MITT ranges, the U.S. military is underway in its establishment of a Live-Fire Training Range Complex (LFTRC) on Guam near Ritidian/Litekyan, the site of a 3500-year-old ancient village. The Live-Fire Training Range requires the removal of approximately 187 acres of some of the last remaining primary limestone forests, and the habitat for several endangered species found only in Guam and within the CNMI.
Pursuant to the 2015 MITT, the National Marine Fisheries Service permitted 12,580 detonations of various magnitudes per year for 5 years, 81,962 takings of 26 different marine mammal species (including whales and dolphins) per year for 5 years, damage or kill of over 6 square miles of endangered coral reefs plus an additional 20 square miles of coral reef around FDM through the use of highly explosive bombs, and that live fire or sonar activity be conducted 365 days a year for 5 years. This excessive authorization to take, or harm, mammals is unjustified and negatively impacts Guam’s ability to preserve its environment, and to benefit from the diversity of species and the potential of these natural resources.
The LFTRC expands the military footprint over a current wildlife refuge and cuts off public access to the people of Guam for 273 days out of the 365 days of the year. The building of U.S. military bases and infrastructure has placed a high demand for cliffside property best suitable for quarrying and mining of limestone.
The history, the values, and prosperity of indigenous CHamorus are uniquely tied to the land, landscape and ecosystems of Guam. Undoubtedly, our land and water resources allow us to build a sustainable economy, health, cultural practices, and overall quality of life and provide our greatest insurance to withstand climate change, However, as outlined here, our lands and waters are increasingly blocked from access, and under threat of contamination and destruction of habitat.
It should be made clear, the indigenous people of Guam have never freely agreed nor requested, voted, or negotiated that our land and waters be subjected to radiation, nuclear waste, PCBs, Agent Orange, Agent Purple, and other contamination; or that our fishing grounds and farmlands and ocean resources be taken away or restricted; or that homes be relocated; or that firing ranges be built over or adjacent to ancient villages and sacred burial grounds, all in support of U.S. military testing or military training.
Concerns & Key points
- Cumulative Impacts – Per NEPA and CEQ regulations, “The range of actions that must be considered includes not only the project proposal but all connected and similar actions that could contribute to cumulative effects. Specifically, NEPA requires that all related actions be addressed in the same analysis (CEQ Publications, Cumulative Effects, https://ceq.doe.gov/publications/cumulative_effects.html; CEQ Considering Cumulative Effects Under the NEPA (Council on Environmental Quality, 1997).
Comment: Given this, cumulative impacts/effects of the Proposed Action must also take into account past and current actions that include the cumulative effects of radiation, nuclear waste, PCBs, Agent Orange, Agent Purple, and other contamination; or that our fishing grounds and farmlands and ocean resources be taken away or restricted; or that homes be relocated; or that firing ranges be built over or adjacent to ancient villages and sacred burial grounds – all of these in addition to the impact of global climate change in our region.
- Global climate change is outlined in Table 4.2-1: Past, Present, and Reasonably Foreseeable Actions:
Predictions of long-term negative environmental impacts, some of which have begun to occur at present, due to climate change include sea level rise; changes in ocean surface temperature, acidity/alkalinity, and salinity; changing weather patterns with increases in the severity of storms and droughts; changes to local and regional ecosystems (including the potential loss of species); shrinking glaciers and sea ice; thawing permafrost; a longer growing season; and shifts in plant and animal ranges, fecundity, and productivity. A special report by the Intergovernmental Panel on Climate Change discussed the long-term warming trend observed since pre-industrial times (Intergovernmental Panel on Climate Change, 2018), and how higher than the global annual average temperatures are being experienced in many land regions and seasons, (4.0 Cumulative Impacts, page 4-20).
Comment/question: Both Alternative 1 and Alternative 2 indicate “new at-sea activities,” currently ongoing activities, an “increase in tempo of some training and testing activities, including additional Fleet exercises and associated unit-level activities.” How do these actions contribute to long-term negative environmental impacts on our region, including rise in sea levels, changes in ocean surface temperature, acidity/alkalinity, and salinity, changing weather patterns with increases in the severity of storms and droughts; changes to local and regional ecosystems (including potential loss of species); and shifts in plant and animal ranges, fecundity, and productivity?
- Seismic surveys/Use of sonar: Waters near the Study Area in the Territory of Guam and the Commonwealth of the Northern Mariana Islands.
Seismic surveys are typically accomplished by towing a sound source, such as an airgun array that emits acoustic energy in timed intervals behind a research vessel. The transmitted acoustic energy is reflected and received by an array of hydrophones. This acoustic information is processed to provide information about geological structure below the seafloor. The oil and gas industry uses seismic surveys to search for new hydrocarbon deposits. Also, academic geologists use them to study plate tectonics and other topics. The underwater sound produced by these surveys could affect marine life, including marine mammals. For example, the potential exists to expose some animals to sound levels exceeding 180 decibels referenced to 1 micropascal root mean square, which would in turn potentially result in temporary or permanent loss of hearing (Bureau of Ocean Energy Management, 2011).
Comment/question: What is the purpose of the Navy’s proposed use of seismic surveys in the waters surrounding the Marianas? Does this relate to the military’s plans for mining in our region? While the Navy may have authorizations and processes in place to cause temporary or permanent harm to the ocean environment and marine life, our people for generations historically and culturally, continue to value all aspects of oceanic marine life and ecosystems. This interconnectedness of land, ocean and air is what we depend on for our livelihood and way of being.
A biologist of the Fisheries Section of the Guam Department of Agriculture further stated, “sonar, vessel interactions, explosive detonation in the water, all of these have the potential to impact marine mammals. One of the concerns from the EIS is that for all of the marine mammals that are mentioned, I don’t think there’s a single one that has the most current information available listed with it. We have information on strandings, on sightings, on whales sighted giving birth that were not mentioned in the EIS anywhere. And I’m not certain where that information was gotten from, but all of this information that was provided to our federal partners as well as that we have available, was not mentioned in the EIS.” He also stated, “We do have additional stranding records. We have additional records of marine mammals identified giving birth in the region. One of particular concern is the mention of the Agat offshore mine detonation site. That’s almost precisely where we have photographic evidence of sperm whales giving birth which are both marine mammal and endangered species listed organisms. Though it’s not listed anywhere in the EIS that incidents like that. Another area of concern is vessel strikes. Vessel strikes with marine mammals are addressed in the EIS but we have a greater incidence of vessel strikes with sea turtles on Guam. We’ve had at least five sea turtles killed by vessel strike in the last seven years on Guam that we’ve been able to identify. It’s difficult to identify the vessel that did strike the turtle. Nearly all of these occurred in inner Apra Harbor which is pretty much closed to all activity except military vessel activities. So the implication is that it could be military vessel strikes that are causing the sea turtle mortality. Another area in the EIS is mentioned… a large area to southeast of Guam Whiskey 517 is an area it was mentioned. It was very closely related to some offshore fishing banks where we documented a fair amount of fishing activity. In the last two years those banks have been off-limits about 120 days, an average for the last two years which is about a third of the year for activity and primarily for fishing activity. Now they do fall just outside the range that is delineated but we’ve had fishermen report that when they get down to the banks there are military vessels that are telling them to not enter while activities are going on even though they’re outside the area.” [https://www.youtube.com/watch?v=qDmKc1hr8w4]
- Per Resource-Specific Cumulative Impacts: By CEQ guidance (Council on Environmental Quality, 1997), the following cumulative impacts analysis focuses on impacts that are “truly meaningful.” The level of analysis for each resource is commensurate with the intensity of the impacts identified in Chapter 3 (Affected Environment and Environmental Consequences) and the level to which impacts from the Proposed Action are expected to mingle with impacts from existing activities. A full analysis of potential cumulative impacts is provided for marine mammals, sea turtles, and marine invertebrates. The rationale is also provided for an abbreviated analysis of the following resources: sediments and water quality, air quality, marine habitats, marine birds, marine vegetation, fishes, cultural resources, terrestrial species and habitats, socioeconomic resources, and public health and safety.
Comment: Let the record show that the focus on “impacts that are truly meaningful” by the CEQ privileges the missions of the DoD and is not truly meaningful and commensurate with the historical and cultural experience of war in the region of the indigenous CHamoru people.
Additionally, I support the concerns of the Guam Coastal Management Program of the Bureau of Statistics and Plans in their submitted comments and in their testimony during an April 15th public hearing at the Guam Legislature on the impacts of detonations of the 2019 MITT on the coastal zones of Guam.
The administrator for the Guam Coastal Management Program stated, “we want to ensure that military expended material will not pose contamination threats as material breaks down. This is not only a direct impact as the detonation occurs but any particles that may be consumed by organisms that can affect the food chain. We’re not looking at just the moment but what could happen after the activity takes place. We are concerned about any kind of seafloor detonations within our coastal zone and this doesn’t matter if there’s no corals on hard bottom or substrates. With or without the presence of coral we know that the hard bottom substrate is an important area where coral polyps can settle and we want to be sure that that habitat is protected.” [https://www.youtube.com/watch?v=qDmKc1hr8w4]
- Per sections on Sediments and Water Quality, Air Quality, the 2015 MITT Final EIS/OEIS, indicated that training and testing activities under each alternative could result in local, short- and long-term changes in sediment and water quality. However, chemical, physical, or biological changes remained within standards, regulations, and guidelines. The short-term impacts arose from explosions and the byproducts of explosions and combusted propellants. The analysis in the 2015 MITT Final EIS/OEIS determined that it was unlikely that these short-term impacts would overlap in time and space with other future actions that produce similar constituents. Therefore, the short-term impacts did not contribute to cumulative impacts [emphasis added].
The long-term impacts arose from unexploded ordnance, non-combusted propellant, metals, and other materials. Long-term impacts of each alternative are cumulative with other actions that cause increases in similar constituents. However, the contribution of Alternative 1 or Alternative 2 in the 2015 MITT Final EIS/OEIS to long-term cumulative impacts was determined to be negligible
[emphasis added]
because of the following:
- Most training and
testing activities are widely dispersed in space and time.
- Where activities are concentrated (i.e., Farallon de Medinilla [FDM]), marine habitat conditions observed over multiple years through dive studies indicate that ecological services that maintain water quality have not been inhibited at FDM.
- Most components of expended materials are inert or corrode slowly.
- Numerically, most of the metals expended are small- and medium-caliber projectiles, metals of concern comprise a small portion of the alloys used in expended materials, and metal corrosion is a slow process that allows for dilution.
- Most of the components are subject to a variety of physical, chemical, and biological processes that render them benign.
- Potential areas of impacts would be limited to small zones immediately adjacent to the explosive, metals, or chemicals other than explosives. Under this SEIS/OEIS, the contribution of proposed changes in training and testing activities under Alternative 1 or Alternative 2 would still be negligible based on the reasons presented above. While all of the additional projects since 2015 may be measurable and result in long-term and widespread changes in environmental conditions (e.g., nutrient loading, turbidity, salinity, or pH), any changes in sediment and water quality would be subject to applicable standards and guidelines. Given that impacts on water quality as a result of the proposed training and testing activities would be considered negligible, the incremental contribution to cumulative impacts on water quality would also be negligible [emphasis added].
Regarding Air Quality, the 2015 MITT Final EIS/OEIS indicated that training and testing activities conducted under each alternative resulted in increased criteria pollutant emissions and hazardous air pollutant emissions throughout the Study Area. Sources of the emissions included vessels and aircraft and, to a lesser extent, munitions. Potential impacts included localized and temporarily elevated pollutant concentrations; however, recovery occurs quickly as emissions disperse [emphasis added]. The analysis in the 2015 MITT Final EIS/OEIS concluded that the impacts of Alternatives 1 or 2 were cumulative with other actions that involve criteria air pollutant and hazardous air pollutant emissions. However, the incremental contributions, from implementing activities in accordance with the 2015 MITT Final EIS/OEIS Record of Decision (ROD), to cumulative impacts were low for the following reasons:
- Most training and
testing activities-related emissions are projected to occur at distances
greater than 3 nautical miles (NM) from shore.
- Few stationary offshore air pollutant emission sources exist within the Study Area, and few are expected in the foreseeable future.
- International regulations by the International Maritime Organization required commercial shipping vessels to switch to lower-sulfur fuel near U.S. and international coasts beginning in 2012 (National Oceanic and Atmospheric Administration 2011).
- The Department of Defense released the Operational Energy Strategy: Implementation Plan, which reduced demand, diversified energy sources, and integrated energy consideration into planning (Department of Defense 2012). Since then, the Navy has released the 2016 Operational Energy Strategy, which builds on the successes of the 2012 Operational Energy Strategy (U.S. Department of Defense, 2016).
Under this 2019 draft SEIS/OEIS, the contribution of proposed increases in training and testing activities under Alternative 1 or Alternative 2 would still result in negligible additional impacts [emphasis added] based on the reasons presented above. In addition, the International Maritime Organization is set to impose a new 0.5 percent sulfur cap on marine fuel emissions (International Maritime Organization, 2017). Construction-related activities associated with the additional other projects in the area could generate increased air emissions; however, air quality in the region would remain below de minimis levels due to the quick dispersive nature of emissions. Based on the analysis presented in Section 3.2 (Air Quality) of this SEIS/OEIS and the reasons summarized above, the incremental contribution of Alternatives 1 or 2 to cumulative impacts on air quality would be negligible
[emphasis added]
.
In addition to the cumulative effects of criteria and hazardous air pollutants, greenhouse gas emissions would increase under the Proposed Action. Greenhouse gases contribute to climate change, which are felt on a global scale, rather than having localized affects. Although the Proposed Action would result in an increase in greenhouse gas emissions, the Secretary of the Navy has released energy goals that aim to reduce the overall impact that the department has on climate change. Some of those goals involve using alternative energy sources for 50 percent of total consumption needs by 2020, having 50 percent of Navy and Marine Corps installations be net-zero emissions by 2020, and reducing petroleum use in the commercial fleet by 50 percent. These activities would more than offset the small increase in greenhouse gas emissions that would result from the implementation of Alternative 1 or 2.
Comment: The negligible short-term and long-term cumulative impacts outlined are dismissive of many of the unresolved issues that our islands continue face, especially with regard to high rates of rare cancers, skin disorders, respiratory issues and heart disease. There is a kind of injustice in having to read through actions and impacts deemed negligible and minimal given that we have seen and continue to see the cumulative ill-impacts of military actions on our environment, in effect, on the livelihood of our people.
Additionally, I support the 12 concerns raised by the Guam Environmental Protection Agency in their submitted comments and in their testimony during an April 15th public hearing at the Guam Legislature regarding the lack of data on cumulative impacts of the 2015 MITT on the environment on Guam, the lack of details in how the 2019 MITT intends to meet all of the requirements of Guam Environmental Protection Agency rules and regulations during the permitting process, and the lack of discussion regarding the environmental impact of previously used ammunition and/or degradation products on the marine ecosystem in the proposed study area.
The administrator of the Guam EPA’s Environmental Monitoring and Analytical Services stated, “At minimum, a yearly report should be produced summarizing all activities identified in the MITT. There is no current mechanism to evaluate if the activities and quantities identified in the MITT are met or exceeded. Report should also address any impacts to stressor types.” Additionally, he states, “Neither the 2015 MITT nor the 2019 Supplemental MITT have a discussion on the rational for an increase from a 10 lbs. underwater mine charge to the new standard of a 20 lbs. charge for the listed mine detonation activities. What is the justification for the increase? This needs to be further explained and justified.” [https://www.youtube.com/watch?v=qDmKc1hr8w4]
- Per Marine Habitats, the 2019 MITT Supplemental and 2015 MITT Final EIS cite continued detonations at existing underwater detonation areas such as Piti, Agat and Outer Apra Harbor.
Comment/question: How long have these areas been deemed underwater detonation areas? What permits continue to authorize the use of these areas as such? When do these permits expire? What are the plans for clean-up of these sites? When can we anticipate full restoration such that marine habitat and ecosystems will be able to flourish once again? What is needed for full restoration to be possible?
- Regarding cumulative effects of all Department of Defense actions in the Mariana Islands, including CNMI Joint Military Training EIS – The CNMI Joint Military Training EIS would establish a series of live-fire and maneuver ranges and training areas within the CNMI and include amphibious operations on Tinian. The proposed action for the CNMI Joint Military Training EIS is to expand existing ranges and training areas and construct new ranges and training areas within the CNMI. The resources evaluated that could contribute to cumulative impacts include geology and soils, water resources, air quality, noise, airspace, land and submerged land use, recreation, terrestrial biology, marine biology, cultural resources, visual resources, transportation, utilities, socioeconomics and environmental justice, hazardous materials and waste, and public health and safety. The Navy is drafting a revised EIS that would reduce impacts on resources as a result of the proposed action. The analysis of cumulative impacts contained in this chapter addresses cumulative effects of all Department of Defense actions on the Mariana Islands, including the CNMI Joint Military Training EIS.
Comment/question: Cumulative impacts for the proposed action, as well as all DoD actions in the Mariana Islands should already be configured in the impact analysis on and for these resources. This is how cumulative impact must be analyzed given that our islands are constantly subjected to DoD proposed actions.
Will the revised EIS that would reduce impacts on resources as a result of the proposed action be published in the Final EIS, and will the people of Guam be able to comment on this?
- Regarding cumulative impact on reduced fishing access, recreational fishing, commercial fishing and transport between the Mariana Islands from the restricted areas –Access to certain areas of the Study Area around islands and in the open ocean is temporarily restricted during potentially hazardous training and testing activities to ensure the safety of the public and military personnel. Danger zones may result from other Department of Defense actions in Guam and the Mariana Islands such as the Guam and Commonwealth of the Northern Mariana Islands Military Relocation and CNMI Joint Military Training. These other actions would occur mainly on land and around Tinian. As a result of the training and testing activities associated with this SEIS/OEIS, areas within 3 NM of FDM are permanently restricted to maintain public safety. Even when hazardous activities are not occurring at FDM, the potential occurrence of unexploded ordnance in waters surrounding the island is a constant threat to public safety. Transiting between Guam, Saipan, Tinian, or other islands located to the south of FDM and the Islands Unit (Northern Mariana Islands) would potentially be impacted by limiting access to the 12 NM danger zone around FDM. Considering that an average of 3.8 trips per year has occurred over the past 30 years (as stated in Section 3.12.3, Public Scoping Comments), the probability of military activities interfering with trips to the Islands Unit is low. Furthermore, the military will announce when FDM is not in use in addition to notifying mariners of planned activities at FDM, which will enable mariners to better plan trips to the Islands Unit. Further analysis can be found for recreational and commercial fishing and transport in Section 4.4.12 (Socioeconomic Resources).
Comment/question: We have grave concerns of any language that indicates potential threat, temporary restriction, impacts of possible results from danger caused by DoD actions. That approximately 120 military actions (3.8 trips per year has occurred over the past 30 years) have occurred without true consent of the people of the Mariana Islands for the past 30 years is more than enough interference, especially to the people of the NMI. That permanent restriction in the 3 NM area surrounding FDM is considered a cumulative impact is incorrect and misleading. It should be stated upfront that this is a DIRECT IMPACT: “Even when hazardous activities are not occurring at FDM, the potential occurrence of unexploded ordnance in waters surrounding the island is a constant threat to public safety.”
Finally, any actions resulting in reduced access to fishing, recreational fishing, commercial fishing and/or permanent access to areas of transport between and around the Mariana Islands adds to our already limited access resources; thus we are not able to approve of this inaccessibility or permanent restrictions. For more explanation, refer to Introduction & Background section of this Comment and to comments from the Guam Department of Agriculture in the Seismic survey/Use of Sonar section of this Comment.
- Regarding cumulative impact on historic sites on Guam, the 2019 MITT draft SEIS indicates that “no additional submerged cultural resources have been identified around Guam. As such, the information presented in the 2015 MITT Final EIS/OEIS is still valid and the most current.”
Over 540 cultural resources associated with Guam are considered eligible for or listed in the National Register of Historic Places including 8 individual resources listed in the National Historic of Historic Places, 6 listed in the Guam Register of Historic Places only, and 348 pre-contact sites, 3 multicomponent sites, 117 historic archaeological sites, 18 buildings, and 66 structures.
The training constraints map identifies 13 No Training areas (eight on Guam and five on Tinian) and 35 Limited Training areas (20 on Guam and 15 on Tinian), refined from the previous Military Operations Area constraints map boundaries (U.S. Department of Defense 2009). Limited Training areas are defined as pedestrian traffic areas with vehicular access limited to designated roadways and/or the use of rubber-tired vehicles. No pyrotechnics, demolition, or digging is allowed without prior consultation with the appropriate Historic Preservation Office.
Comment/questions: I share the concerns of the Guam State Historic Preservation Officer, Guam Preservation Trust, and Guam Historic Preservation Review Board in their submitted comments and in their testimony during an April 15th public hearing at the Guam Legislature that the list of cultural resources referenced in the SEIS does not fully incorporate all the cultural resources that may be impacted. The Guam SHPO in her submitted comments mentioned that there are 119 submerged resources rather than the 84 stated in the 2015 MITT EIS. She further stated that a systematic submerged resource survey around Guam must be conducted prior to any authorization of proposed activity. Guam SHPO also noted that in the 4 years since the 2015 EIS was implemented, more cultural resources have been located, excavated, and recorded that are eligible and/or listed in the National Register of Historic Places. A systematic literature review and resurvey of areas surveyed 20 or more years ago will result in many more than the 540 cultural resources listed in the 2015 MITT.
Additionally, the 2009 MIRC Programmatic Agreement expires in December 2019. What document will be used in the interim before a new agreement is negotiated, and will any of the activities be held in abeyance until an agreement is executed?
- Should there be no other opportunity following the Draft SEIS/OEIS for public comment, let the record show that I am requesting Avoidance and No Adverse Impacts and that the Proposed Action in the Final EIS/OEIS and the ROD should outline the revisions towards this effort.
Conclusion
We are faced with these processes said to protect our environment and livelihood, and yet are based on references and resources over 20 years old, and data and research that does not show the whole picture. Let the science and these processes show the true cumulative impacts of past military activities, including PCB’s, depleted uranium, Agent Orange, radiation exposure in addition to the harmful and threatening impacts of the proposed actions on our community.
Guam’s regulatory agencies – Department of Agriculture, Coastal Management Program of Bureau of Statistics and Plans, Guam Environmental Protection Agency, and the State Historic Preservation Officer have all expressed and outlined significant concerns with the proposed actions in the 2019 MITT draft SEIS and their potential impacts on Guam’s natural and cultural resources.
Until the cumulative impacts can accurately represent the experience of injustice and irreversible harm on the people, lands, air and oceans, I urge that the issuance of federal regulatory permits and authorizations under the Marine Mammal Protection Act and Endangered Species Act to support military readiness requirements within the MITT Study Area beyond 2020 be permanently ceased and that the No Action Alternative be chosen.
Thank you for the opportunity to submit comments for the 2019 MITT Draft Supplemental EIS/OEIS.
Si Yu’os Ma’åse’
Therese M. Terlaje