[CPEO-MEF] Newport Chemical Depot (IN) comments by Hoosier Environmental Council

[Lenny Siegel <lsiegel@cpeo.org>]

December 18, 2010

Ms. Cathy Collins
Engineer
Newport Chemical Depot
PO Box 160
Newport, IN 47966

RE: Comments on Environmental Assessment and Draft Finding of No 
Significant Impact for Disposal and Reuse of Newport Chemical Depot

Dear Ms. Collins,

The Hoosier Environmental Council submits the following comments on the 
EA and draft FNSI referenced above.

Finding of No Significant Impact

A finding of no significant impact is not appropriate for the proposed 
action, given the absence of key reuse information in the Environmental 
Assessment, and the provisions of the Newport Chemical Depot Reuse 
Authority's (NeCRDA) Reuse Plan which allows the destruction of an 
important natural resource present at the facility. Therefore, the Army 
should find that there will be significant environmental impact from the 
disposal and reuse of the property, and prepare a full environmental 
impact statement.

1. A high intensity reuse option has been proposed for a portion of the 
facility which would have major impact on the environmental resources at 
the Newport facility and surrounding area. This proposed reuse project 
involves construction and operation of a coal liquefaction plant. This 
would be a major industrial facility, with potential impacts to air 
quality, water quality, disturbance or destruction of forest, wetlands, 
and prairie, and a dramatic change in the nature of the property. This 
possible type of reuse activity was mentioned in the NeCRDA's reuse 
plan, but is inconsistent with the low intensity reuse and medium-low 
intensity reuse alternatives evaluated in the Environmental Assessment. 
The EA states, "Achieving conversion and redevelopment goals would, at 
build-out, most closely resemble an Medium-Low (ML) scenario." (Page 3-10).

Such a major industrial facility would be accurately characterized as 
either a medium-high intensity, or high intensity reuse, both of which 
were deemed "impractical" in the EA (page 3-6). The EA states, "No land 
use conflicts would be expected from implementing the reuse plan." (page 
4-6). A major industrial operation such as a coal liquefaction plant 
would not only conflict with other planned uses within the Newport 
property, but also with the low-intensity land use practices and 
economic activity occurring in the surrounding areas. Desirable and 
compatible economic development, such as high-tech or life-sciences 
industries would be unlikely to locate nearby a major polluting 
industrial facility.

2. Neither the NeCRDA reuse plan, nor the Army's disposal action, 
provide for protection of the 336 acre black soil tallgrass prairie 
area, which is a rare and biologically valuable natural area deserving 
of permanent protection. Instead, the reuse plan includes most of this 
prairie area in an agricultural and forestry designation, meaning it 
could be plowed and planted to row crops in the future. The EA 
acknowledges this, stating, "some loss of the restored prairie areas 
would be expected." (page 4-36) Contrary to the EA's statement, 
"tallgrass prairie" is not an agricultural reuse.

It is illogical, and inconsistent with a goal of the NeCRDA reuse plan, 
to include a high quality natural area such as this black soil tallgrass 
prairie area in a reuse category that may allow its destruction. It is 
unimportant that this prairie area is restored prairie, because it 
represents, now and in the future, a rare and important natural 
community that is worthy of preservation. Given that this prairie area 
constitutes less than 5% of the total Newport area, and that more than 
3,000 acres would remain for business and technology reuse, it is wholly 
reasonable and prudent to permanently protect this area.

The Army's disposal action should require that this prairie area be 
included in the "natural areas and open space" reuse classification, or 
otherwise assure its permanent protection through an easement or other 
encumbrance.

3. The EA's evaluation of public benefit conveyance outcomes is limited 
and incomplete. The Army should conduct a thorough review of the Notices 
of Interest applications, and reach an independent conclusion on the 
merits of these requests and whether they should be granted.

Conclusion

The EA for the disposal and reuse of Newport Chemical Depot is 
inadequate for the following reasons: a limited analysis of public 
benefit conveyances as reuse alternatives; the failure to fully evaluate 
the disposal action's effect on an important natural resource, the 
tallgrass prairie area; and, the lack of evaluation of major industrial 
reuses that are being considered for the Newport property by other 
interests. These deficiencies result in the Army's Environmental 
Assessment failing to provide a sufficient level of NEPA analysis. The 
Army should reach a finding of significant impact for the Newport 
Chemical Depot disposal action and prepare a full environmental impact 
statement which evaluates industrial reuses and their compatibility with 
the medium-low and low intensity reuses contemplated by the NeCRDA reuse 
plan and EA. The EIS should also include a disposal alternative which 
provides for full protection of Newport's important natural areas and 
habitats-- forests, prairie, and wetlands.



Sincerely,

Tim Maloney
Senior Policy Director
Hoosier Environmental Council
3951 N. Meridian St., Suite 100
Indianapolis, IN 46208


--


Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org



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