Citizens are gathering information on the likely environmental impacts of FASTC at Ruthsburg. The list below identifies the kinds of impacts that are legally significant. Please furnish any information you have on any of these impacts to Jay Falstad no later than March 9. You can also post it below as a comment. The lawyers retained by Queen Anne’s Conservation Association will incorporate the impact information into their March 12th submission under the NEPA “scoping” process. Thank you for your help.
FASTC ENVIRONMENTAL IMPACTS
(This List of environmental impacts from FASTC at Ruthsburg is organized to track the “significance factors” identified in NEPA Regulations. See Explanatory Note below at the end of the List for a fuller discussion.)
0. “Context: the locale”
? Baseline information about characteristics of region: 5, 10, 15, 25 mile radius
1. “Impacts . . . may be both beneficial and adverse. A significant effect may exist even if the Federal agency believes that on balance the effect will be beneficial.”
? Scope of foreseeable commercial and residential development caused by FASTC
2. “The degree to which the proposed action affects public heath or safety.”
? Health
a. Toxics from storage and firing of ordnance
? Safety:
a. Traffic accidents and road conditions
b. EMS
c. Law enforcement
d. Ridgely Airport
3. “Unique characteristics of the geographic area such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas.”
? Unique characteristics of the geographic area (Eastern Shore)
? Historic or cultural resources
a. Historic homes
b. Native Americans
c. Adkins Arboretum
d. Crossroads rural village
? Park lands
a. Tuckahoe State Park (including riding, camping, etc.)
b. Existing or planned hiking/biking trails in vicinity
? Prime farmlands
a. Carbon, nitrogen, filtering, other
b. Soil types, production data
c. Preservation of agricultural economy
d. Horse farms, raising, training, riding, racing, equestrian sports
e. White House Bay Strategy against farmland loss
? Wetlands
a. Jurisdictional wetlands
b. Delmarva bays
? Wild and Scenic Rivers
a. Tuckahoe – recreational uses
b. Stormwater, other watershed impacts
? Ecologically critical areas
a. Chesapeake Bay watershed status under Bay Strategy
b. Eastern Shore – cumulative development impacts
4. Degree to which effects are highly “controversial” ( = controversy over significance)
? Noise
? Vibration
5. Uncertain effects; unique or unknown risks
? Security for high-visibility, consolidated federal antiterrorist training center (as compared with lower-visibility, geographically dispersed centers)
6. “The degree to which the action may establish a precedent for future actions with significant effects”
? Cumulative impacts of future additional consolidation/expansion at Ruthsburg (“mission creep”)
7. “Significance cannot be avoided by terming an action temporary or by breaking it down into small component parts.”
? [see no. 6]
8. “The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places or may cause loss of significant scientific, cultural, or historical resources.”
? Highways – Eastern Shoreway (301)
? Structures [see no. 3]
? Scientific resources
a. Tuckahoe Dark Skies
? Cultural, historical resources [see no. 3]
9. “The degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973.”
? Birds
? Butterflies
? Mammals, especially DFS
10. “Whether the action threatens a violation of Federal, State, or local law or requirements imposed for the protection of the environment.”
? Violation of QAC Comprehensive Plan and Chapter 18 agricultural zoning
? Threatened violation of QAC Adequate Public Facilities Ordinance (schools)
11. Alternative locations
? Existing security training facilities
? Closed military bases
? “Other” DSS training facility within 150 miles of US Capitol allegedly referenced in December 3, 2009 Solicitation
12. Waste of stimulus (ARRA) funds
? High per-acre cost of Ruthsburg prime farmland
? Partial consolidation: loss of claimed efficiencies
? Jobs losses at consolidated facilities
? Intrusion of political considerations into siting decision
? Distortion of NEPA process by ARRA timeline
Explanatory Note:
GSA is seeking to conclude the current environmental assessment (EA) with a finding of no significant impacts (FONSI) from FASTC, thereby avoiding preparation of a full environmental impact statement (EIS). This effort by GSA cannot succeed if it is established that there are likely to be significant direct, indirect, or cumulative environmental effects (= impacts) from FASTC.
Evaluation of whether FASTC “significantly” impacts the environment directly, indirectly, and/or cumulatively requires consideration first of “context” (locale) and then of ten categories of “intensity” factors specified in 40 CFR 1508.27(b).
The foregoing Task List is organized to start with context and then track the ten categories of intensity factors. It concludes with two further categories of related information.
(“Indirect” effects include FASTC impacts later in time or more removed in distance that are “related to induced changes in the pattern of land use, population density or growth rate, and related effect on air and water and other natural systems, including ecosystems” (40 CFR 1508.8). “Cumulative” impacts are those resulting from adding FASTC impacts to “other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions”(40 CFR 1508.7).)
Don’t forget FASTC’s proximity to Eastern Neck National Wildlife Refuge, easily within the 25-mile radius of Ruthsburg, and its habitat for endangered Delmarva Fox Squirrel, as well as being an important wintering area for thousands of waterfowl.
Plus Eastern Neck NWR is mostly surrounded by the lower Chester River, a historic oystering and crabbing location currently experiencing severe degradation of its waters.
There are many reasons as to why this facility should not be located in the Ruthsburg Area.
First of all we have Bald Eagles that nest nearby, and use this farm, as with many farms around, to hunt. Secondly, there is a State Park that is directly across the road from the proposed site of the facility. This park is used by Thousands of people each year, from camping to birthday parties, school trips, equestrian events, fishing, canoeing, hiking, bike trails, and Arboretum. All of these things will be severely impacted by this type of facility being built here.
To say nothing of the increased traffic, noise, and who knows what else that will come with it. We are a quiet borough, that is very community oriented. We have a community center also directly across the street from the site of this facility. This building is used by memebers and rented to non-members. This is how we pay our bills for this building. Who is going to want to rent this building for wedding receptions, birthday parities, family reunions, dinners for different businesses, etc, if there is bombs and such going off across the street. I am sure that there was SOME investigations done before this site was choosen, but, I am not sure that the RIGHT kinds of investigations were done. Many of us have lived here our entire lives, and have done such because of the sense of community. This type of facility would vastly change our sense of community and our way of life.
Not to mention the impact on the flora and fauna that abound in this area. You take away almost 3000 acres of land for the Bald Eagles to hunt on, and they will leave the area as they are very territorial birds.