Initial Observations fromCitizens for a Fort Monroe National Park on theFort Monroe Draft Environmental Impact Statement (DEIS)Plus Suggestions for Submitting Public Commentsto the Army by Oct. 29, 2009(For a link to the DEIS itself, please see the Army's DEIS notice.)
In our view the DEIS seriously understates the adverse environmental consequences of some contemplated reuse alternatives at Fort Monroe. It does so by both:
* treating certain temporary conditions at Fort Monroe, primarily in the Wherry Quarter (the Endangered Green Heart of Fort Monroe, lying northeast of the moated fortress), as baseline conditions against which likely reuse will be measured, and then
* understating certain environmental consequences of reuse.
To put it more simply, the DEIS both fails to look at the current Fort Monroe accurately and compounds that error by understating harm done by certain reuses. These errors play out most significantly in the resource areas of land use, aesthetic/visual resources and cultural resources.
The DEIS also fails to look squarely at a Fort Monroe containing a significant national park unit in partnership with the Commonwealth. Thus, an alternative with the greatest likelihood of few if any adverse consequences, and the most positive environmental benefits, goes altogether unevaluated.
CFMNP suggests that friends of Fort Monroe consider submitting comments to the Army asking, as follows, for significant reworking of the DEIS to correct these significant errors and oversights:
1. Fully evaluate an additional alternative, a significant national park unit operating in partnership with the Commonwealth at Fort Monroe. This alternative is not all coincident with the "Lower Bracket," is a realistic alternative being currently evaluated and is very likely to have more favorable environmental consequences than any of the alternatives evaluated.2. Properly evaluate impact on the Wherry Quarter -- treat its current condition as that of a largely vacant open space, as current structures were always intended as temporary.
3. Properly evaluate impact of reuse on the Wherry Quarter -- evaluate impact of addition of permanent structures (at least in Middle and Upper Bracket options) on all resource areas, especially land use, aesthetic/visual resources and cultural resources, recognizing that the impact on many of these criteria, in the "green" edge of the magnificent stone fort and the historic edge of the 196 acres of park and recreation land to the north, will be significantly adverse.
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