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LUCERNE VALLEY ECONOMIC DEVELOPMENT ASSOCIATION (LVEDA)
To: Naval Facilities Engineering Command, Southwest
ATTN: 29 Palms EIS Project Manager
1220 Pacific Highway
San Diego, CA 92132-5190
From: Chuck Bell, Pres.
P.0. Box 193
Lucerne Valley, CA 92356
760 964 3118 chuckb@sisp.net
Date: 5/26/11
RE: 29 PALMS – TRAINING LAND ACQUISITION/AIRSPACE ESTABLISHMENT EIS
LVEDA’s Mission Statement:
Provide a forum for discussion and action on important community issues –
promote infrastructure improvements – work with County and developers to promote
development that is both “economic” and compatible with our rural lifestyle,
environment and resource availability.
LVEDA fully supports and appreciates our military and its mission – helping to
maintain our Republic and safety. The following focuses on the inadequacies of
the DEIS – primarily related to economic impacts.
CONFLICTING OBJECTIVES: The Expansion’s “MEB-sized training” purpose – requiring
a tremendous amount of new acreage - conflicts with recent statements/news
articles re: military objectives – a major discrepancy - thus lacks credibility
as a viable or necessary “project” – one with a myriad of significant,
unnecessary impacts – in sink with the “No Action” alternative.
Sec. Gates: The nation does not need a second land army, Gates said, but rather
forces that can deploy quickly and sustain themselves for a short period of
time.
Also see Gates: Time has Come to Re-examine Future of Marine Corps by Kevin
Baron of Stars and Stripes and Defense Chief Gates Orders Review of Marines'
Role by David S. Cloud of The Los Angeles Times.
Lt. Gen. George J. Flynn - Commanding General of Marine Corps Combat Development
Command – (Mar. 2, 2011):
Two of the recommendations from the Force Structure Review are:
A reduction in force structure from 202,000 to 186,800 when conditions in
Afghanistan warrant (and)
Reduction in ground combat forces, to include a reduction in infantry
(regimental headquarters from eight to seven; infantry battalions from 27-24); a
reduction in cannon artillery battalions (nine to seven; but a reorganization of
batteries to support distributed operations), and a reduction in armor (10
companies to 8).
FT. IRWIN ALTERNATIVE: NEPA requires that every feasible alternative needs to be
“on the table” and assessed – including the option for joint or separate
exercises at Ft. Irwin – particularly enhanced by its recent expansion and its
vehicular connectivity. In-house rejections of any viable alternative – for
whatever reason – still require full public review and analysis. Its absence
nullifies the adequacy of the DEIS.
EAST VS. WEST: Elimination of the eastern alternative area from Sen. Feinstein’s
recent Desert Protection Act makes it a viable option – selection of which would
eliminate the significant impacts and tremendous burdens on communities
associated with the western proposal – particularly Alt 6 – and would likely
result in quicker implementation – assuming any expansion is really required.
MITIGATION COSTS: A western expansion will require significant costs for
tortoise mitigation - which may not even be available in the w. Mojave by the
time Congress makes its decision - but certainly at a much higher cost than
potential bighorn sheep mitigation in the alternative eastern area. The DEIS
lacks the required descriptions of mitigation/compensation areas and projects.
OHV DISPLACEMENT: The EIS totally fails to assess the full environmental
implications of Alt. 6. The JV OHV Area is the largest and most established in
the nation and cannot be replaced. It provides the space for long-distance race
courses no other s. Calif. facility offers. It has become an "icon" not just for
off-roading, but for a myriad of other recreational and resource-related
land-uses. The other OHV Areas in the Mojave Desert cannot accommodate JV's
current use. Even with the small portion of the open area remaining In the
Anderson Dry Lake areas adjacent to Camprock Rd. - displacement will result in
more local, private land trespass and incursion into environmentally sensitive
and protected BLM areas – especially the adjacent Ord Mt. Desert Wildlife Mgt.
Area (ACEC).
Alt. 6’s current configuration will likely preclude access to the JV OHV area’s
eastern race courses – thus diluting the very integrity of the “joint use”
concept – forcing more use and resource destruction in the remaining northwest
portion of the open area – not adequately described or mitigated in the DEIS.
It is critical that BLM maintains its land-use jurisdiction over any expansion
area – particularly the “joint use” portion - issuing DOD a R/W or easement for
its use – not allowing it to become fully under military authority - thus giving
BLM and the public involvement and discretion WHEN (more likely than ”IF”) DOD –
for whatever reason – decides in the future that “joint use” is no longer
practical and wants full control.
SOCIO/ECONOMICS: With Alt. 6’s substantial reduction of the JV OHV Area and its
current function - Lucerne Valley would definitely suffer a significant loss of
revenue from OHV-related traffic - major filming/commercials - mining - general
recreation - etc. for the Lucerne Valley Market/Hardware (shopping center) - 3
gas stations - our restaurants - a multitude of other businesses, etc. The
"profit margin" for our businesses is already a "stay-open/break-even"
situation. Loss of current weekend business - 10% and greater total revenue for
some - would be the "straw on the camel's back" that would force them to shut
down. Our very survival as a community is at stake.
The DEIS totally ignores the fact that Lucerne Valley is a state-designated
“Economically Disadvantaged Community” – certainly describing our current
economic status that would be especially vulnerable to the disruption caused by
Alt. 6’s or any other western expansion. The DEIS’ “mitigation” of job and sales
tax creation (only benefiting the 29 Palms region anyway) absolutely fails to
acknowledge or mitigate significant adverse impacts to Lucerne Valley and our
viability as a “community” – with so-called “mitigation” having no nexus to our
impact – the impact not even considered a “significant” finding - blatantly
disregarding our “on the ground” reality and the basic requirements of an
adequate NEPA process and document.
Even a direct monetary compensation to the Lucerne Valley “community” wouldn’t
fully mitigate our ultimate losses. However, DOD could at least ameliorate the
effect. Current use of the OHV area is generally split between the Anderson Dry
Lake staging areas in the northwest portion and the Soggy Dry lake segment at
its southern end. With the likely loss of extensive OHV use in the southern
areas - the only usable portion of the JV OHV area remaining would be its
western (Anderson area) segment – or what’s left of it – with traffic able to
access it utilizing Rabbit Springs Rd. directly off Hwy 18 to Camprock Rd. –
bypassing the town’s commercial corridor. The very least DOD can do to partially
alleviate both loss of OHV-related commerce and the impact to the County’s
marginally maintained Rabbit Springs Rd. (with numerous residences, etc.) -
would be to have Caltrans and the County designate Rabbit Springs Rd. for “local
use only” – directing OHV-related traffic east through Hwy. 18 and the town’s
commercial corridor – then east on Hwy 247 (both of which are state highways and
better maintained) – enhancing more commercial activity – and provide funding
for an east-bound left-turn pocket off Hwy 247 north onto Camprock Rd. to
facilitate turning movements and safety.
IRON ORE MINE: The recently approved (Hahm) iron ore mining operation within the
eastern portion of the expansion area ABSOLUTELY MUST be considered a joint-use
– allowing it to operate to its fullest capacity – with no access restrictions,
etc. A “buyout” is not mitigation/compensation for our society that cannot
afford any further dependence on foreign sources of our basic necessities –
critical for our local cement industry – with the only feasible alternate
sources in Utah or further east – or more likely China. It would be absolutely
irresponsible for DOD – the Marines – which totally depend on iron and steel for
its “stuff” – to close down this viable and economically critical mine.
ORD MT. CATTLE ALLOTMENT:: A significant portion of this active cattle allotment
is within northern JV – included in the western expansion area - potentially
rendering the Allotment economically useless – with no specific or quantified
remedy stated in the DEIS.
NOISE: The DEIS dismisses the effects of intensive noise impacts on Lucerne
Valley and surrounding communities – and does not fully describe the full range
of related aircraft activity in the expanded air space.
Note: There seem to be discrepancies in the text and summary tables re: findings
of significance.
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