Ventana Wilderness Alliance
NEPA & CEQA Comment Letters

January 11, 2001

Larry Jones (Code N45F)
Building 307
Fallon Naval Air Station
4755 Pasture Road
Fallon, Nevada 89496

RE: FORT HUNTER LIGGETT BOMBING TARGET: SCOPING COMMENTS

Dear Mr. Jones:

Thank you for allowing the Ventana Wilderness Alliance this opportunity to comment on the air to ground training target area proposed for Fort Hunter Liggett in Monterey County, California. For a variety of reasons including the presence of sensitive botanical areas, sensitive archaeological areas, and the recreational conflict inherent to jet aircraft overflights denigrating Wilderness values in the adjacent Ventana and Silver Peak Wilderness areas, we strongly request that the air to ground training target area not be established at Fort Hunter Liggett. If our request is not honored, then please address the following concerns in the NEPA document prepared for this proposal:

• Consider the alternative of No Action.
• In the document prepared for this proposal, please consider all possible alternative sites to FHL, including but not limited to Camp Pendleton, Fort Irwin, Fallon Nevada, El Centro and any other appropriate places. Please clearly explain why this site was selected over other possible sites. Describe how this training requirement has been met previously and why previously used sites are no longer suitable.
• Please identify in the document prepared for this proposal all applicable Military Operation Areas (MOA) that will be used by all aircraft bombing the proposed target site. Identification of MOAs should include maps showing the MOA and its relation to the target site and in compliance with all FAA mapping standards. Please show specific in bound and out bound flight paths on the MOA maps including aircraft altitude at intervals of five nautical miles.
• Please describe the "Practice Ordnance" to be dropped on the proposed target and provide the size, weight and quantity to be dropped from each sortie. Please identify how many flights will occur per year, month and day and times of day flights will occur.
• Describe and discuss the noise and visual impacts of overhead or nearby jet-fighter flights on the adjacent Ventana Wilderness and Silver Peak Wilderness areas. Essential elements of this analysis should include the impacts of aircraft overflights on the natural integrity of the area, their effect on opportunities for peaceful solitude and high-quality recreational and wilderness experiences, their effect on camping, fishing, hunting, birding, wildlife viewing, or other forms of recreation, and how the Navy will assure compliance with the federally mandated minimum flight altitude of 2000' feet above ground surface over designated Wilderness Areas. Also, please detail what steps will be taken to mitigate these impacts.
• Consider the impacts of low-flying aircraft and bombing activities on ranches and residences adjacent to or nearby FHL. Describe the methods that will be used to monitor and minimize these impacts.
• Describe and discuss how the seasons of use will accommodate the social and physical needs of threatened, sensitive, and endangered species as well as management indicator species (examples of social and physical needs include fawn and fawn rearing seasons, nesting, winter and summer range, adequate habitat diversity, hiding and thermal cover, etc.).
• Describe and discuss impacts on the resident tule elk herd whose range territory includes the proposed target area.
• Describe and discuss impacts on the breeding bald eagles whose range territory includes the proposed target area.
• Survey and determine (during the appropriate time of year) if federally listed fairy shrimp exist in the major vernal wetland that weaves its way through Stony Valley. If they are found there, please detail how this vernal wetland will be protected from impacts of the proposal.
• Survey and determine (during the appropriate time of year) if the federally listed arroyo toad exists in the area of the proposal. If they are found, please detail how they will be affected by the proposal and what measures will be taken to protect them.
• Survey and determine (during the appropriate time of year) if the federally listed kit fox known to inhabit FHL exists in the area of the proposal. If they are found, please detail how they will be affected by the proposal and what measures will be taken to protect them.
• Discuss how the proposal will affect plans by the Department of Fish and Game or the US Fish and Wildlife Service to use the Ventana Wilderness and other portions of the surrounding Los Padres National Forest lands for the continuing release and re-introduction of the endangered California condor.
• Please include a determination as to whether a formal Section 7 consultation with the US Fish and Wildlife Service is required under the Endangered Species Act, and if so, include the details of that consultation in the NEPA document.
• Describe how the California Department of Fish and Game's Deer Herd Management Plan will be implemented in the analysis area and in what ways, if any, the bombing is inconsistent with the management plan. Post-project foraging resources for deer, including square feet of basal area of oak and other forage species should be included, as well as the potential for improvements in these habitat values.
• Discuss any Federal or State Sensitive or California Native Plant Society listed rare plants as well as candidate plants including those currently or historically known to occur and those with the potential to occur (based on habitat, distribution, etc.) within the analysis area and whether recent surveys have been made for these sensitive plants during the appropriate period for botanical identification. Include whether or not the survey protocol has been met and what impacts you foresee to sensitive plants as a result of this proposal. Please also discuss what mitigation measures you will implement to protect sensitive plants.
• Describe and discuss maximum bombing saturation levels and seasons of use that ensure that the phenological needs of native plants in the affected areas are met over extended periods.
• Describe any special circumstances involved in the approval or planning of this proposal regarding:
  • steep slopes
  • highly erosive soils
  • threatened or endangered species or their critical habitat
  • flood plains
  • wetlands
  • vernal pools
  • domestic-supply watersheds
  • wilderness areas
  • research natural areas and botanical areas
  • Native American religious or cultural sites
  • archaeological sites
  • historic properties
• Reveal whether or not an archaeological survey has been completed within the analysis area and, if so, when the survey was conducted and what was found. We also request that historic and cultural sites be avoided at all costs and that methods of avoidance and mitigation be fully explained in the NEPA document prepared for this proposal. We further request that local Native American community members be contacted regarding this proposal in compliance with law and policy.
• Conduct a cumulative watershed effects (CWE) analysis for the watersheds in the proposal area and present this data in the NEPA document.
• Describe the condition of the watersheds in the proposal area in terms of CWE, land disturbance history, noise levels, sensitive habitat, and other issues. In addition, please disclose when, and how many, surveys have been conducted in these watersheds and whether or not these field surveys suggested upgrading the risk of cumulative watershed effects in the affected watersheds. We also request that you consider the cumulative impacts of past, present, and future projects (including those on private land) within these watersheds and discuss ways to minimize or eliminate these impacts.
• Describe and discuss all bombing-related impacts on water quality in the analysis area including sediment, increased nutrient loads and chemical contamination that can contaminate drinking water and harm aquatic ecosystems. Also, please describe how these impacts can be eliminated or minimized within the proposal area.
• Describe and discuss all bombing-related impacts on air quality in the proposal area, including those from jet engine exhaust the jettisoning of surplus fuel loads at altitude. Also, please describe how these impacts can be eliminated or minimized within the proposal area.
• Describe the monitoring program being developed for this proposal, to include monitoring implementation, effectiveness, validation and documentation. Please include how this program will be funded, what criteria will be used to determine resource protection objectives, and how, when and where these criteria be measured. Also include what records will be kept, and what decision points are in place if objectives are not being met.
• Describe and discuss the effects of the proposal on the Nacimiento Fergusson Road and other publicly accessible roads in the area, including how often and for how long they will be closed, and what steps will be taken to ensure public safety thereon.
• Describe and discuss how the proposal will affect the pending presence of the National Park Service on Fort Hunter Liggett, and include details of the consultations held with NPS as part of the project analysis.
• Prepare and include orthophoto quads or maps (7-1/2') for the entire area affected by the proposal (i.e. the area within earshot of the jets), not just the target site itself. On these maps please show ecological units and existing vegetation, structural and nonstructural improvements (both existing and proposed), seasonal and perennial water sources, recreational areas, and other features significant to management.

These comments are also submitted in behalf of the California Wilderness Coalition 2655 Portage Bay East, Suite 5, Davis, CA 95616.

Thank you for this opportunity to comment. Please mail a copy of the draft NEPA document for this proposal the Ventana Wilderness Alliance and also to the California Wilderness Coalition so that each organization may offer further input.

Sincerely, VENTANA WILDERNESS ALLIANCE

Steve Chambers, President

Copies:
Congressman Sam Farr, California 17th Congressional District
Paul Spitler, Executive Director, California Wilderness Coalition