Experts in the fields of geochemistry, hydrology, soil science, air pollution, and civil engineering have roundly criticized studies the U.S. Army plans to carry out at Makua Military Reservation (MMR) on O`ahu to address community concerns about contamination associated with live-fire training at MMR. In response to an Army request for comments on the study work plans, the experts all came to the same conclusion, agreeing with University of Hawai'i soil scientist Dr. Goro Uehara that, as currently designed, the proposed studies "will not enable decision makers to render a verdict on the impact of military activities on long term environmental health."
The Army must conduct the contamination studies under a settlement reached on October 4, 2001 in a federal court lawsuit brought by Malama Makua (represented by Earthjustice) that challenged the Army's failure to prepare a comprehensive Environmental Impact Statement (EIS) under the National Environmental Policy Act for live-fire training exercises at MMR. In the settlement, the Army agreed to prepare an EIS and, as part of the EIS process, to "[c]omplete studies of potential contamination of soil, surface water, and ground water, and of potential impacts on air quality" and to "evaluate whether there is the potential for any contamination to be transported beyond the boundaries of MMR that may contaminate the muliwai, or any marine resource or wildlife on or near Makua Beach." Settlement at 6(a). In addition, the Army agreed that, before carrying out these studies, it would "provide a 60-day public comment period on the scope and protocol of these studies."
"Under the settlement, the purpose of the comment period is to give experts and the public a chance to point out flaws in the work plans before the Army spends the time and money to carry out the studies, when the Army still has the chance to get it right," explained Earthjustice attorney David Henkin. "We hope the Army will correct the problems the experts have identified, so that, in the end, the studies will provide complete and accurate information about contamination risks, which is what the community has been seeking for years."
A major flaw in the ground water and surface water contamination studies is timing. While the settlement gives the Army until October 2004 to complete the EIS, the work plan seeks to finalize the EIS one and one-half years early (by April 2003), at which time only half of the planned ground water sampling would be completed. William Meyer (hydrologist and former head of the U.S. Geological Survey's Hawai'i District Office) noted that the proposed schedule reflects "a nearly complete disconnect between time allocated for the collection of field data and the planned use of this data for characterizing field conditions in the MMR."
Regarding the surface water contamination study, Mr. Meyer observed that, given MMR's arid conditions, "[i]t is highly possible that there will be no runoff events prior to the release of [the final EIS] or that what runoff events that do occur will not be of a significant nature." University of Hawai'i geochemist Dr. Eric De Carlo agreed: "The study cannot achieve its objectives in absence of data obtained from stream sampling."
The experts also criticized the proposed soil contamination study. Dr. De Carlo stressed that the soil sampling plan is "inadequate to characterize MMR" and "that the locations of said sampling will not provide an objective evaluation of the extent of contamination throughout MMR." Moreover, the work plan calls for full analysis of only 10% of the samples. Civil engineer Mary Masters reflected the experts' consensus that "[t]he limited number of samples for complete analysis is insufficient to characterize the type and extent of contamination."
Air pollution expert Dr. Andrea Ferro faulted the Army's Air Sampling and Analysis Plan for excluding potentially significant "sources of air pollutants directly related to the training conducted at MMR," such as controlled burns, grass cutting, road grading, and soil re-suspended by low-flying helicopters. Dr. Ferro emphasized that, "[t]o estimate the impact of future controlled burns and accidental fires, air monitoring should be conducted for the upcoming controlled burn for the Makua Valley floor." Dr. Ferro's comments were in response to the Army's refusal to monitor air pollution generated by the burn of the entire valley floor scheduled for September 2002.
Dr. Ferro also criticized the Army's proposal to exclude from air quality monitoring potential pollutants such as dioxins, furans, herbicides, pesticides, chemical components from ordnance formerly used at MMR (which training and training-related fires could re-suspend), and PM-2.5 (particulate matter with an aerodynamic diameter less than 2.5 mm, a federally regulated air pollutant).
David Henkin, Earthjustice, (808) 599-2436, ext. 14
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