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Joint Base Cape Cod's Multi-Purpose Machine Gun Range review process is fatally flawed

By Richard F. Delaney, President
Cape Cod Climate Change Collaborative
October 2, 2020

Last month, the Cape Cod Climate Change Collaborative submitted comments to the Massachusetts Army National
Guard regarding the Environmental Assessment and Finding of No Significant Impact for the proposed multi-
purpose machine gun range on the Upper Cape Water Supply Reserve at Camp Edwards.

The Climate Collaborative is a coalition of organizations, businesses and citizens committed to mitigating climate change impacts, protecting natural carbon sequestration, and working to achieve net zero carbon emission goals for the Cape & Islands. It is from this perspective of climate responsibility that the Climate Collaborative determined the project’s EA and FONSI to be fatally deficient.

The Climate Collaborative believes the proposed range will have significant climate change impacts, which were ignored in the initial review. These impacts must be identified, quantified and thoroughly analyzed, with public input, through the more rigorous review of an Environmental Impact Statement, in compliance with the National Environmental Policy Act. The EA lacks the cumulative impacts analysis, robust alternatives analysis and mitigation assessment required under an EIS. And, the EA failed to adequately involve the public in the process, ignoring the environmental history of pollution at Camp Edwards where remediation is ongoing.

Of greatest concern, the EA failed to account for or quantify the impacts from the loss of carbon sequestration in clear-cutting 170 acres of forest. The Climate Collaborative is categorically opposed to forest destruction for any reason and has issued a formal position statement opposing tree cutting, even to accommodate solar arrays. This position is based on studies examining forests’ ability to capture and store the carbon pollutants that drive climate change. Research on carbon sequestration indicates mature forests, such as those on Camp Edwards, can potentially sequester between 1 and 1.6 metric tons per acre per year.

The National Guard purports to go through the motions of considering climate change in its assessment, but the outcome fails to reflect NEPA's purposes. NEPA’s decision-making requirements are clear: An EA must consider direct, indirect and cumulative environmental impacts of a proposed action to determine whether the comprehensive environmental assessment contained in an EIS is required.