FORA's Draft EIR - Public Comments By FOTP

[CGumbi@aol.com]

Subject: FORA's Draft EIR - Public Comments By FOTP

here is my comments on the Draft EIR for FORA's "Base Reuse Plan" 

Regards, 
Curt
============================================

11 October 1996

Fort Ord Toxics Project
P.O. Box 3115
Carmel, CA 93921-3115

Fort Ord Reuse Authority
100 Twelfth St., Bldg. 2880
Marina, California 93933

SUBJECT: DRAFT EIR PUBLIC COMMENT - BASE REUSE PLAN

Dear FORA.

1. The Fort Ord Draft EIR Fails to disclose the environmental effects
stemming from exposure to unexploded ordnance (UXO). Figure 4.6-4 of the
DEIR is incomplete and fails to fully disclose the suspected presence of UXO
throughout the former Army base. For example figure 4.6-4 of the DEIR does
not show numerous known, and suspected UXO sites located north of the main
entrance gate to the base. Remarkably, the UXO map contained in the Fort Ord
Infrastructure Improvement Project - Environmental Assessment/Initial Study,
April 1996, figure 9, pages 44-45, show numerous known and suspected UXO
sites north of Fort Ord's main entrance gate.

2. The DEIR is inadequate for failure to discuss exposure to chemical 
weapons material (CWM) and Chemical Agent Identification Sets (CAIS). The
Non-Stockpile Chemical Material Program - Draft Survey And Analysis Report,
2nd edition, 9 August 1995, on page CA-1states that CAIS were used on Fort
Ord. 

 "Chemical agent identification sets (CAIS) were used at Fort Ord Prior 
to1974 for field training of troops" and "At many installations around the
country, CAIS were buried [during field training] and later encountered
during construction-related activities; however no records of such practice
or of subsequent CAIS discovery have been found at Fort Ord." 

Additionally, on page ( i ) of the same report the Army also states: 

 "Except for buried CWM, information concerning the locations and 
quantities of NSCM [non-stockpile chemical materials, (i.e. CAIS)] is 
well documented. Although documentation surveys, interviews, and site 
investigations have been conducted, much information concerning buried 
CWM [CAIS] remains unknown."

This is evidence that environmental exposure to CAIS on the former Army base
should be treated as a significant effect of the FORA Base Reuse Plan.

I request that you acknowledge receipt of my comments.

Respectfully submitted,

Curt Gaudy
Executive Director
Fort Ord Toxics Project