EPA: X-Base Hwy.  FEIS "Inadequate"

Thanks to the Whidbey Environmental Action Network wean@whidbey.net, the following are key excerpts from a copy of a letter from L. John Iani, Regional Administer of EPA, to Daniel M. Mathis, Division Administrator, Federal Highway Administration. For those who do not speak 'bureaucratese,' the short translation is: until and unless US EPA signs off (finds the EIS "adequate"), neither Federal land or money can be used for this $60-$200 million highway.

"The U.S. Environmental Protection Agency (EPA has reviewed the Final Environmental Impact Statement (FEIS) for the Cross-Base Highway in Pierce County, Washington. We are submitting comments on the FEIS pursuant to our responsibilities under the National Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act.

"The issues posed by the proposed Cross-Base project are difficult ones. During my tenure as Regional Administrator, my staff and I have tried to work with our partners to bridge the multitude of issues raised by this project. As a result, I have met with staff from our partner agencies, listened to representatives of environmental organizations, talked to those who will be most affected by this
project, and walked the site to see it for myself. I am very concerned that after years of collaboration, we still find ourselves faced with a project without a clear plan for mitigation.

"In our letter of August 13, 2002 we recommended actions needed to establish an adequate NEPA process, including improvements to the environmental analysis, disclosure of impacts, public participation, and mitigation to offset project impacts. Upon reviewing the FEIS we find that issues remain and conclude that this Final EIS is still not adequate to meet the information and disclosure
requirements of NEPA.

However, we believe that an adequate mitigation plan ca be negotiated with the Federal Highway Administration (FHWA) and the project sponsors. We are willing to continue working with the project proponents together with our partner agencies to resolve these issues.

"Need for a Detailed, Specific, and Adequate Mitigation Plan"

"In our comment letter of August 13, 2002, on the Supplemental Draft EIS, U.S. EPA, as well as the U.S. Fish and Wildlife Service (USFWS) and Washington Department of Fish and Wildlife (WDFW) requested a mitigation plan that would be contained within a mitigation agreement signed by the resource agencies and project proponents. We, and the other resource agencies, also stated that a
greater than 1:1 ratio of suitable habitat replacement was needed.

"We agree with WDFW and USFWS that the conceptual mitigation in the FEIS is inadequate. We ask that the project proponents work with the resource agencies to develop a signed mitigation agreement that meets the needs stated by the USFWS (November 4, 2003) and WDFW (November 14, 2003). This process should also include agreement on developing an assessment of habitat losses and species impacts that will be supported by the resource agencies.

"While we realize that there are project constraints, we are confident that open, cooperative, and collaborative efforts among the project proponents, the military, resource agencies, and non-governmental organizations can result in a solution that is significantly more sensitive and responsive to these issues. We invite you to work with us towards that end."

Sincerely,
L. John Iani, Regional Administrator
US Environmental Protection Agency