The Northwest Warfare Training Range Complex EIS

The Northwest Warfare Training Range Complex Environmental Impact Statement (NWTRC-EIS) has been on my sonar for a while now. It seems as if the Navy would like to make the entire ocean a “warfare training range.”

While I have written many comments over the years to the US Navy on their proposed ranges (see: USWTR and GOA) we did not prepare comments to this document for a few reasons. First, there seems to be a reasonable measure of public disturbance on this so it has higher visibility than some of the others (and thus not calling for as much of our attention) but also the Navy is getting really good at making the public comments and review process really cumbersome on these things.

The first DEIS I worked on was the 2002 LFA-SURTASS Draft Overseas Environmental Impact Statement. This was sent out in two bound volumes with citations, cross references, and responses to the public comments in the second volume. The comment process went relatively smoothly and the Navy had to curtail much of their proposed activities as a consequence. The Navy manager for the project, Joe Johnson literally said “We’ll never do that again.”

Since that time they have found many creative ways of making the federally mandated NEPA process increasingly impossible, including  releasing the comment draft over the Christmas holidays, making the document incredibly huge (1000 pages) so as to bury critical operational comments under vast amounts of filler, and now this added feature of releasing the entire document on-line in dozens of separate chapters, so you have to keep all of these documents open and keep track of where you are as you attempt to craft an intelligent narrative response to their proposal.

In the case of the NWTRC-EIS, as far as our work is concerned, they won. I have financed my earlier comments out of our general operating expenses, but when the NWTRC-EIS was released for comments I just did not have the resources to take the two weeks and work up a comprehensive response to it.

Even NRDC, which is the other organization (other than OCR) that files a comprehensive set of comments on these things filed a simple letter and asked for sign-on from the eNGOs (see attached).

Thanks for your interest.