As noted in the May edition of Rock the Earth Notes, we have continued to participate in the public comment process over the functional expansion and intensification of troop training at the Piñon Canyon Maneuver Site in southeastern Colorado. In late May of this year, the Army issued its Record of Decision (ROD) for the Piñon Canyon Maneuver Site. Unfortunately, the deficiencies contained within in the Environmental Impact Statement (EIS) remain as the “preferred alternative” designated by the Army in the ROD is the very same troubling alternative designed in the EIS process — despite over 100 specific public comments against this alternative.

The Army admits the implementation of the ROD “is expected to result in direct, indirect, and cumulative impacts, to include potentially significant impacts to soils, vegetation, wildlife, and water resources.” The Army ROD can be found HERE.

The ROD establishes: increased training intensity levels; updates and intensifies brigade training and equipment requirements; enables the environmentally destructive “Stryker” family of vehicles to train at PCMS; and adds “enhanced readiness training” to include new activities and infrastructure at PCMS which will similarly negatively impact a number of conservation, cultural and natural resources.

Rock the Earth, along with numerous agencies and the impacted public, submitted comments throughout the lengthy process from draft to final EIS. Unfortunately, the Final EIS failed to make any significant changes as a result of these comments. In April, Rock the Earth filed a subsequent comment letter to the Army noting that several significant and critical areas targeted in our original letter to the Army were still inadequately addressed. During the final comment period of the final EIS, Rock the Earth’s comments focused on National Environmental Protection Action (NEPA) deficiencies in areas that included:

– A failure to protect and mitigate damage to natural and cultural resources;

– A failure to provide for adequate public participation; and

– A failure to adequately evaluate environmental justice issues.

In the final ROD, the Army acknowledged the comments of Rock the Earth and identified one comment concerning our environmental justice concerns that presented potentially new information: “Rock the Earth’s comments contained the assertion that the FEIS failed to include certain areas bordering PCMS as potential minority communities for purposes of environmental justice analysis.”

The Army’s lengthy response to the RtE comment included that “the Army does not assume impacts would “stop” at the PCMS border, only that most of the anticipated impacts (such as noise and fugitive dust, for example) would occur on and immediately adjacent to the installation. Because impacts from the proposed action are concentrated on PCMS and immediately adjacent to the installation rather than disbursed throughout the entire state, the Army maintains that it was reasonable to utilize county data for comparison to the affected census tract, which represents as closely as possible the smallest geographic units for which Census data was available.”

Rock the Earth strongly disagrees that the very limited data set utilized to determine whether communities of color would be impacted by the intensified activities was reasonable. Further, Rock the Earth (along with numerous commenters to the FEIS) also asserts that significant and critical environmental and public engagement issues noted in our comments to the Army are still inadequately addressed.

Rock the Earth is currently in discussions with a number of environmental conservation groups as well as other communities that will be impacted by the ROD. We are putting together a lawsuit to challenge the ROD, with an eye on bringing litigation by the year’s end.

For more background or the latest developments on this issue, please see the Rock the Earth Piñon Canyon Project Page.