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Clean Ocean ActionParticipating OrganizationsAlliance for a Living OceanAmerican Littoral SocietyArthur Kill CoalitionAsbury Park Fishing ClubBayberry Garden ClubBayshore Regional Watershed CouncilBayshore Saltwater FlyroddersBelford Seafood Co-opBelmar Fishing ClubBeneath The SeaBergen Save the Watershed Action NetworkBerkeley Shores Homeowners Civic AssociationCape May Environmental CommissionCentral Jersey AnglersCitizens Conservation Council of Ocean CountyClean Air Campaign, NYCoalition Against ToxicsCoalition for Peace & Justice/Unplug SalemCoast AllianceCoastal Jersey Parrot Head ClubCommunication Workers of America, Local 1034Concerned Businesses of COAConcerned Citizens of BensonhurstConcerned Citizens of COAConcerned Citizens of MontaukConcerned Students and Educators of COAEastern Monmouth Chamber of CommerceFisher’s Island ConservancyFishermen’s Conservation Association, NJ ChapterFishermen’s Conservation Association, NY ChapterFishermen’s Dock Cooperative, Pt. PleasantFriends of Island Beach State ParkFriends of Liberty State Park, NJFriends of the Boardwalk, NYGarden Club of EnglewoodGarden Club of Fair HavenGarden Club of Long Beach IslandGarden Club of RFD MiddletownGarden Club of MorristownGarden Club of NavesinkGarden Club of New JerseyGarden Club of New VernonGarden Club of OceanportGarden Club of PrincetonGarden Club of RumsonGarden Club of Short HillsGarden Club of ShrewsburyGarden Club of Spring LakeGarden Club of Washington ValleyGreat Egg Harbor Watershed AssociationGreen Party of Monmouth CountyGreen Party of New JerseyHighlands Business PartnershipHolly Club of Sea GirtHudson River Fishermen’s AssociationJersey Shore Captains AssociationJersey Shore Parrot Head ClubJersey Shore Running ClubJunior League of Monmouth CountyKeyport Environmental CommissionKiwanis Club of ManasquanKiwanis Club of Shadow Lake VillageLeonardo Party & Pleasure Boat AssociationLeonardo Tax Payers AssociationMain Street WildwoodMantoloking Environmental CommissionMarine Trades Association of NJMonmouth Conservation FoundationMonmouth County Association of RealtorsMonmouth County Audubon SocietyMonmouth County Friends of ClearwaterNational Coalition for Marine ConservationNatural Resources Protective Association, NYNJ Beach Buggy AssociationNJ Commercial Fishermen’s AssociationNJ Environmental FederationNJ Environmental LobbyNJ Main Ship Owners GroupNJ Marine Education AssociationNJ PIRG Citizen LobbyNottingham Hunting & Fishing Club, NJNYC Sea GypsiesNY State Marine Education AssociationNY/NJ BaykeeperOcean Wreck Divers, NJPaddleOut.orgPicatinny Saltwater Sportsmen ClubRaritan RiverkeeperReligious on WaterRiverside Drive AssociationRotary Club of Long BranchRotary District #7510—InteractSaltwater Anglers of Bergen CountySandy Hook Bay AnglersSave Barnegat BaySave the Bay, NJSEAS MonmouthSeaweeders Garden ClubShark Research InstituteShark River Cleanup CoalitionShark River Surf AnglersShore Adventure ClubSierra Club, NJ Shore ChapterSisters of Charity, Maris StellaSons of Ireland of Monmouth CountySoroptimist Club of Cape May CountySouth Jersey Dive ClubSouth Monmouth Board of RealtorsStaten Island Tuna ClubStrathmere Fishing & Environmental ClubSurfers’ Environmental AllianceSurfrider Foundation, Jersey Shore ChapterTACK I, MATerra Nova Garden ClubThree Harbors Garden ClubUnitarian Universalist Congregation/Monm. Cnty.United Boatmen of NY/NJVillage Garden ClubVolunteer Friends of Boaters, NJWATERSPIRITWomen’s Club of Brick TownshipWomen’s Club of KeyportWomen’s Club of Long BranchWomen’s Club of MerchantvilleWomen’s Club of Spring LakeWomen Gardeners of RidgewoodZen SocietyMain OfficeOcean AdvocacySince 198418 Hartshorne Drive, Suite 2Highlands, NJ 07732-0505Telephone: 732-872-0111Fax: nOceanAction.orgSouth Jersey OfficeTelephone: .orgMay 27, 2009Public Affairs Office -- EA CommentsIMNE-MON-PA, Bldg. 1207, Room G-07Fort Monmouth, NJ 07703Attn: Timothy RiderRE: Final Environmental Assessment (EA) of the Implementation of Base Realignmentand Closure at Fort Monmouth and the draft Finding Of No Significant Impact (FONSI)VIA: EMAIL and MAILDear Mr. Rider,Clean Ocean Action (COA) is a broad-based coalition of 125 conservation,environmental, fishing, boating, diving, student, surfing, women's, business, service, andcommunity groups and also represents concerned citizens and businesses. Our goal is toimprove the degraded water quality of the marine waters off the New Jersey/New Yorkcoast.The Final Environmental Assessment of the Implementation of Base Realignment andClosure at Fort Monmouth, New Jersey (EA) that reviewed the potential environmentaland socioeconomic effects associated with transferring 1,126 acres of Fort Monmouth isincomplete, minimizes impacts without justification, lacks due diligence, and is arbitraryand capricious. In fact, the EA highlights environmental and public health concerns thatwill likely prove costly to remediate or be harmful, if ignored or if remediation is furtherdelayed. The EA does not include the Phase 2 Environmental Condition of Property(ECP) Assessment.1 The Phase 2 Assessment recommends further evaluation of severalcontamination sites for a Baseline Ecological Evaluations that has not been completed anddoes not appear to have even commenced. Therefore, the Finding of No SignificantImpact (FONSI) based on an unacceptable EA is without merit. In fact, the findings todate clearly warrant and demand a complete Environmental Impact Statement (EIS) beconducted to provide a comprehensive assessment of Fort Monmouth and surroundingareas that have been impacted by activities at this facility and remediation plans.Transfer, or “disposal”, of the Fort Monmouth property would be arbitrary and capriciouswithout an EIS and comprehensive remediation plans. Failure to do so would beenvironmentally harmful and could also result in public or private interests investing inthe property with unanticipated higher pollution levels and remediation costs.1U.S. Army 2008 Final BRAC 2005 Site Investigation Report Fort p/ecp.shtml

The EA includes several public health and environmental concerns and yet lacks any summarydata to support and justify claims of only “minor” short- and long- term impacts.-There is a prohibition of ground water use due to contamination in the Classification ExceptionAreas sites which will stay in effect until remediation activities occur and are certified byappropriate regulatory agencies. No summary monitoring data is provided on the specificcontaminants present, their concentrations, or what remediation actions are necessary in theEA.-The EA describes the water quality of many creeks and waterways on or near Fort Monmouthas poor or impaired. Given that groundwater is contaminated at Fort Monmouth, it is probablethat nearby streams and coastal waters and sediments are affected by this groundwater seepage.More summary information on recent monitoring data is needed in the EA.-In Section 2.3.2, The EA states that “The primary contaminants of concern at Fort Monmouthare trichloroethene; petroleum, oil, and lubricants; lead; tetrachloroethene; polychlorinatedbiphenyls (PCBs); chlorobenzene; pesticides; benzene; arsenic; 1,2-dichloroethene; andcadmium. .such as asbestos-containing materials (ACM), lead-based paint (LBP), radon,PCBs, radionuclides, and munitions and explosives of concern (MEC), which includesunexploded ordnance (UXO).” Contamination has been identified in groundwater, surfacewater, and soils. The EA notes that contamination issues at Fort Monmouth “limit or precludethe transfer of property for unrestricted use.”-To characterize hazardous contamination of and explosives at Fort Monmouth, the EA statesthat only a “preliminary investigation” has been conducted s Phase 2 EnvironmentalCondition of Property (ECP) Assessment. How many of these additional sites are in need ofremediation? How many total samples were above residential standards? It is inexcusable thatinformation from this extensive report has been omitted from the EA.This report included the following findings:3U.S. Army BRAC 2005 Environmental Condition of Property Report Fort MonmouthMonmouth County, New Jersey Final ecp/FortMonmouthECPJan-07Final.pdf4USEPA 2009. Coastal Sensitivity to Sea Level Rise: A Focus on the Mid-Atlantic Region. US Climate Change Program,Synthesis and Assessment Product 4.1 ap4-1.html4

--Geophysical surveys indentified 24 suspected underground storage tanks and two suspectedseptic features.Groundwater contamination was again confirmed above groundwater screening levels forseveral dangerous chemicals and further evaluation was recommended.Twenty-seven soil gas samples exceeded NJDEP Non-Residential Soil Gas Screening Levels.Constituents of Concern (COCs) were above NJDEP Non-Residential Direct Contact SoilClean Criteria and required further evaluation. Some of the soil testing indicated that some ofparcels did meet the Non-Residential Criteria; however it is not clear how many of these sitesmet residential standards and will require future remediation based on intended use.COCs were also identified in sediment data in several parcels above NJDEP criteria and wererecommended for further evaluation.Based on the additional investigations of Phase 2 Assessment, facility-wide Baseline EcologicalEvaluations (BEEs) of contaminated parcels were recommended and have not been completed.Funding for the BEEs was only allocated this spring and apparently the BEEs are still in the planningprocess. According to N.J.A.C. 7:26E-3.11, the Technical Requirements for Site Remediation requirethat baseline ecological evaluations be conducted to ensure that the remediation activities are indeedprotective of the environment. Contaminants of concern and sensitive environmental areas need to beidentified and further evaluated, and pathways of contamination to the environment need to beassessed.As mentioned previously, the Phase 1 remediation efforts for the landfills at least are inadequateand unclear as to what the capping plans will be. The remedial actions and recommendationsare not evident but needed based on the results of the Phase 2 Assessment. Since the BEEs havenot yet occurred, the remediation necessary from these further evaluations remainsundetermined. Given this lack of information, the EA has no basis for determining thatmitigation measures are not necessary.The EA simply does not “provide[s] sufficient evidence and analysis of impacts to determine [a]finding of no significant impact” as required by federal regulations (40 CFR 1508.9). The FONSIdetermination must be rescinded. The concerns raised in the EA and its blatant omissions, includingbald eagle foraging habitat, critical Phase 1 findings, and the entire Phase 2 Assessment results,confirm that an Environmental Impact Statement is necessary. The omissions in the EA indicate eitherincompetency during preparation or deliberate interference in the scientific integrity of the reviewprocess. President Obama’s March 9, 2009 Memorandum on Science Integrity states that“Science and the scientific process must inform and guide decisions of my Administrationon a wide range of issues, including improvement of public health, protection of theenvironment . The public must be able to trust the science and scientific processinforming public policy decisions. Political officials should not suppress or alter scientificor technological findings and conclusions. If scientific and technological information isdeveloped and used by the Federal Government, it should ordinarily be made available tothe public. To the extent permitted by law, there should be transparency in the preparation,identification, and use of scientific and technological information in policymaking.”An EIS would provide the critical data and summary information needed to adequately informprivate and government interests considering purchasing Fort Monmouth property.5

In Section 4.13.2.1, the EA states that “the Army is under a mandate to characterize contamination,define the appropriate remediation in coordination with regulatory agencies ” yet the EA does notinclude this information and comprehensive remediation efforts are not available in the Assessmentreports and cannot even be determined until the BEEs and additional investigations of surroundingwaterways are completed. The EIS must include comprehensive remediation plans based on thePhase 1 and 2 Assessment, the Baseline Ecological Evaluations, and additional investigation ofpotentially impacted waterways and sediments surrounding the Fort Monmouth region.The transfer of property must not occur until the EIS, including comprehensive remediationplans, is completed. The Army has a responsibility to the community to ensure that the environmenthas not been or will not be damaged due to their activities at Fort Monmouth. Contaminated areas,environmental impacts, and required remediation need to be identified and well-communicated to thepublic in an EIS. Prompt remediation by the Army or other entities is also necessary to protect theenvironment and public health. The high costs and liability of the Army’s pollution must be publicallyrecognized and not passed on to private and public entities without full disclosure.Public involvement and transparency in the closure process, remediation plans, and EIS for FortMonmouth are essential.In short, transfer, or “disposal”, of the Fort Monmouth property would be arbitrary and capriciouswithout an EIS and comprehensive remediation plans. Failure to do so would be environmentallyharmful and could also result in public or private interests investing in the property with unanticipatedhigher pollution levels and remediation costs.A written response to these comments is requested.Sincerely,Heather Saffert, Ph.D.Staff ScientistCc:Representative Rush HoltRepresentative Frank PalloneEd DlugoszTom MahedyFort Monmouth Restoration Advisory BoardNew Jersey Department of Environmental Protection6

Unitarian Universalist Congregation/Monm. Cnty. . Women ’s Club of Keyport Women ’s Club of Long Branch Women ’s Club of Merchantville Women’s Club of Spring Lake Women Gardeners of Ridgewood Zen Society 1 South Jersey Office Telephone: 609-729-9262 . - Soil contamination by lead-based paint was identified as occurring above the .

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