January 2008 SCOPING INPUT TO THE EIS

COMMENTS FOR SCOPING INPUT TO THE EIS OF THE U.S. ENVIRONMENTAL PROTECTION AGENCY: SITE DESIGNATION OF AN OCEAN DREDGED MATERIAL DISPOSAL SITE OFF APRA HARBOR, GUAM Historic Ocean Disposal: List and describe previous instances of ocean disposal off Guam or examples in other similar tropical areas and describe the resulting impacts of such disposals.  As part of benthic baseline investigations, include obtaining photos of impacts at old disposal sites (e.g., 3 miles off Orote Island). Types of Materials to be Disposed: Characterize the range of types of dredged materials produced on Guam that may be allowed to be disposed in the designated site.  Testing criteria that must be applied before approving the materials for disposal must be described in the EIS. Quantities to be disposed: If quantities projected from tentative future projects can be estimated, provide these.  At least estimate these for the Port of Guam deep draft expansion plans and Navy aircraft  carrier berthing plans. Frequencies of Use: If the numbers of projects that plan to use this site over future years can be estimated, the numbers and lengths of activity periods at the site should be projected. Methods of Disposal: Describe proposed methods for ocean disposal at the site.  Include  practices that would be required to be followed  to minimize the plumes generated and make sure the material is placed in a stable manner (assuring there is minimal segregation of size fractions, which could lead to  instability problems later, since the site  is along an earthquake prone island arc).  Projected effluent plumes should be described.  .   Qualified User Parties: Besides the Navy and Port Authority of Guam (PAG), what other businesses and entities may be allowed to use ocean disposal at this site?  Can private foreign businesses dredging on Guam be allowed to use the site?  What economic considerations can be applied to control such private party use to better support beneficial uses?  Also, can materials originating from non-Guam areas be allowed to be disposed at the site? Site Users’ Need  for Permits: Regulatory agencies of the US and the Government of Guam will apply their permitting and regulatory responsibilities, as required by US National laws and Guam laws, to the activities undertaken by the users of the ocean disposal site.  To allow expeditious use of the disposal site, the permitting requirements should be obtained from Federal and Guam agencies, including the Guam Bureau of Statistics and Plans, the Guam Environmental Protection Agency and the Guam Department of Agriculture.  The permits, approvals and consultations needed from Government of Guam Agencies as well as from other Federal Agencies should be noted as part of the draft EIS.  The parameters required by US EPA for quality of disposable materials and methods of verifying this quality should be included.  What bioassays will be applied to determine impact of dredged materials to living resources at the site?  What justifications and analysis will be needed to qualify each dredging project for ocean disposal versus beneficial use? Plans for Beneficial Use: The Government of Guam in all cases prefers beneficial use of dredged materials rather than ocean disposal and requests that the US EPA recognizes and describes these uses and their estimated capacities and locations on Guam as part of this EIS.  The EIS must propose and evaluate alternatives that may best serve both the civilian and the military communities on Guam through a comprehensive island-wide approach.  The Guam Departments of Land Management, Public Works and Agriculture, the Chamorro Land Trust, Guam Environmental Protection Agency,  Port Authority of Guam (PAG), Bureau of Statistics and Plans, Council of Mayors and others, as well as the Air force and Navy, must all be approached by the EIS preparers to obtain information on sites and needs for beneficial uses.  These should include filling for fast land (as at the PAG), cover for landfills, capping of clean-up sites, restoration of old quarry sites, beach enrichment, road base fill and use for construction material.   Large quantities of fill are planned to be used for expansion of Guam’s commercial port and arrangements have been made to utilize dredged material from Navy dredging. Cover for the Ordot and the military landfills is constantly needed and possibility of using dredged material should be discussed in the EIS. Dozens of Installation Restoration (clean-up) sites of hazardous wastes on DOD properties as well as off-Base, Formerly Used Defense Sites (FUDS), are recognized.  Many more on Guam may be found in the future as resources become available to identify them.  These are being assessed and slowly restored to allow safe, but often restricted, uses of at least adjoining properties.  Increased DOD developments will lead to pressure to increase and speed up the investigation and restoration of these hazardous waste sites.  Suitability of transporting, storing and finally using dredged materials for capping clean-up sites should be assessed in the EIS. Old quarry sites should be assessed and calculations of potential volumes of dredged material needed to restore them for uses such as recreation should be assessed. Although Guam has regulated shoreline developments to avoid a need for beach enrichment, future demands for this process are expected and the use of dredged material for beach replenishment or creation should be investigated as another alternative to ocean disposal.  Perhaps, as part of the military expansion and training plans, new beaches may be needed for amphibious landing exercises, to avoid damage to and competition for use of natural beaches. New road construction is required on Guam, and this should greatly expand with urgent requirements for roads needed by the military.  The potential needs for road materials and the suitability and requirements of using dredged materials as sub-base fill should be addressed. The EIS should provide the projected costs per unit of purchasing construction and fill materials for which dredged materials can be replaced.  Expanded demand for quarry materials for military construction and off-base construction triggered by the military developments must be generally assessed.  The costs and actions necessary to substitute dredged materials for quarry products should be listed.  The possibility of exporting usable dredged materials to other ports, using ships that unload in Guam and return empty, should be considered. Recent technology for producing “mudcrete´ from silty and salty dredged materials has been applied successfully and economically for construction.  This beneficial option should also be addressed. Assessment of Benthic Resources and Habitats: Descriptions of the benthic ecosystem, including substrate composition, bathymetry and animal species and their abundance and values must be provided.  Deep sampling and photography must be used to accomplish this.  The EIS must note potential impacts to listed endangered species and marine mammals and address protection of their habitats, including providing studies and evaluation of their habitats at the disposal site and links of the benthic ecosystem with the pelagic one at the site.        Impacts to Pelagic Living Marine Resources:  Some of the few remaining large scale fisheries resources in the world that are not over-fished, the Western Pacific tuna stocks, are in waters surrounding Guam.  Guam has had plans for expanded development of a longline fishing fleet within its exclusive economic zone.  Impacts on pelagic fish at the site should be assessed.  Impacts must be addressed on Essential Fish Habitat.  Whales are recorded from this area and photos document birth of a sperm whale in the vicinity.  Impacts to marine mammals and information on their migration and possible exposure to disposal operations must be included. Assessment of Oceanic Conditions: Water quality (nutrients, salinity, turbidity, oxygen, light penetration, chlorophyll, etc) and plankton composition at a range of depths through the water column from surface to bottom at the site as well as thermoclines and ocean currents at the site to be impacted must be described. Monitoring: Proposed methods and protocols for monitoring impacts during disposal operations and periodically over time should be described.  Monitoring activities by US EPA should be described and their frequency. Use of Local Expertise: Local expertise must be utilized as well as off-Island expertise in developing the assessment of impacts to living resources.   There is a wealth of knowledge and expertise based on Guam, in staff at the University of Guam and with  private consultants and local agencies, that should be tapped for EIS preparation.  They cannot work for free and may expect consulting salaries for preparing information, reviewing documents and completing studies.  They are the experts on Guam’s resources, not consultants from outside of Guam. Coordination with other Federal Use Plans: Coordinate with Mariana Islands Range Complex EIS/OEIS identifying military training areas off Guam. Potential Impacts on Sea Traffic Should Be Addressed. Why not an “Overseas EIS”? The Department of Defense (DOD) is developing an Environmental Impact Statement/Overseas Environmental Impact Statement on the impacts of 1) proposed relocation of 8,000 Marines from Okinawa to Guam, 2) facilities for berthing of nuclear aircraft carriers at Guam and 3) placement of an Army Ballistic Missile Defense Group on Guam.  We have been told by representatives of the DOD that their reason for having an “Overseas Environmental Impact Statement” is because their proposed actions and impacts are to be “beyond 12 miles” from US shores and that this distance is said to trigger the need of an OEIS.   Is this application of an OEIS also needed for Designation of an Ocean Dredged Material Disposal Site which is an action proposed to be more than 12 miles off shore?  What is the difference between an EIS and an OEIS? National Defense Concerns Versus EPA requirements: What circumstances relative to National Defense would override, modify or cancel the US EPA requirements applied to ocean disposal of dredged material by the DOD?

 

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