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Michigan Environmental Council
Briefing Document

10-10-2006

Coast Guard Live Fire Proposal:

Four key questions for or requests of the United States Coast Guard that should be answered or completed prior to approval of any live-weapons firing zones:

A complete federal environmental assessment of the impact of lead, copper and other toxic materials on the Great Lakes should be completed prior to a decision. The only environmental analysis conducted to date – a generic study commissioned by the Coast Guard - only makes conclusions based on 5 years of firing exercises. The lakes are a global resource that will be with us for hundreds of generations. Five years is not enough.

A full explanation of why current live-fire training sites are inadequate – and why 34 sites in the Great Lakes must be used – must be forthcoming.

Alternatives to lead – a carcinogen and neurotoxin – must be examined prior to approval. Coast Guard assumptions suggest that close to 7,000 pounds of lead compounds would be added to the lakes annually. That’s nearly double lead discharged to surface waters from the entire state of Michigan in a year.

Are their training bullets available, or ones that could be manufactured, that reduce the amount of toxic pollution?

The Coast Guard should agree to a maximum level of pollution that it will adhere to annually. The proposed zones and firing exercises are apparently open-ended. Nothing stops the Guard from increasing the number of gunners trained, the numbers of rounds fired, or increasing the size of the ordnance expended. There needs to be a hard cap on the amount of ordnance permitted. 

Summary of Live Fire Zone Proposal

The following is an informal summary of questions and concerns about the United States Coast Guard’s proposal to establish 34 zones for live-fire weapons training in the five Great Lakes, and a critique of the agency's commissioned environmental study that has led to its conclusion that no Environmental Impact Study is necessary for this proposal.

We encourage interested citizens and organizations to attend one of the public hearings listed below to voice their opinions on the matter, and/or to submit formal comments by the Nov. 13 deadline.

This proposal, and the international agreement with Canada that was quietly modified to allow it, reverses two centuries of tradition that the Great Lakes not be used for regular military weapons training. Citizens and public officials should be cognizant that approval of this proposal opens a door that may be difficult to shut.

We undoubtedly live in a new world where terrorism fears and border security require new methods and philosophies. Whether that includes live-fire training, and whether such training if allowed should be subject to any limitations, should be part of any discussion.

Summary:
The proposal was originally published in the Federal Register on Aug. 1 with a public comment deadline of Aug. 31. Notices were neither published by the Coast Guard in mainstream media outlets, nor was any press release issued. The plan … and the international agreement with Canada that was amended by the governments to allow such weapons training … was not actively brought to the attention of members of Congress, public officials in the Great Lakes region or to our knowledge anyone beyond the military and Homeland Security, which oversees Coast Guard operations. 

Live-fire training on the lakes began even before the Federal Register notice was published. In the wake of public outcry over the secrecy of the proposal, it has ceased.

Public Hearings and Comments

The public comment period has been extended to Nov. 13. Seven public meetings have been scheduled.

All meetings run from 5:30 to 8 p.m., with time from 4 to 5:30 p.m. for informal questions and examination of background materials.

Oct. 16, Duluth MN, Duluth Convention Center, 350 Harbor Dr., 218-722-5573.

Oct. 18, Grand Haven/Spring Lake MI, Waterfront Holiday Inn, 940 W. Savidge, Spring Lake. 616-846-1000.

Oct. 19, Port Huron/Marysville MI, Crystal Gardens, 1200 Gratiot Blvd, Marysville, 810-364-6650.

Oct. 23, Cleveland, OH, Celebrezze Federal Building, 31st floor, 1240 E. Ninth St, Cleveland, 216-902-6020.

Oct. 30, Rochester, NY, Details to come.

Nov. 1, Milwaukee/Chicago, Details to come.

Nov. 3, Charlevoix, MI, Details to come.

Additionally, comments on the plan may be made until the Nov. 13 deadline to the Coast Guard. Reference docket USCG-2006-2567 with all comments, to:Docket Management Facility (USCG-2006-2567), U.S. Department of Transportation, room PL-401, 400 SW, Washington D.C. 20590-0001. By fax to 202-493-2251 or electronically through the web site at http://dms.dot.gov

Much information about the proposals is available at:

http://piersystem.com/go/doctype/443/2934

Included in that information is an environmental study commissioned by the Coast Guard and carried out by CH2MHILL of Boston.

The study concludes there are “no elevated risks” to the ecosystem from the proposed live-fire exercises. It is this study that is being used to justify a proposed military exemption from a full-scale environmental impact statement.

While the Michigan Environmental Council has not enough information to determine whether it opposes live-fire exercises on environmental grounds, it is clear that the CH2MHILL study is wholly inadequate, and we will request a full environmental impact study prior to any final decision on these zones.

The following set of bulleted points outlines the inadequacies of the Coast Guard commissioned study, and raises many other issues and unanswered questions that the agency must adequately address.

The CH2MHILL study, “Preliminary Health Risk Assessment for Proposed U.S. Coast Guard Weapons Training Exercises,” Jan. 2006, does not adequately address potential environmental hazards to the Great Lakes: 

-- The assessment evaluates only five years of live-fire training. “Risks associated with training activities that extend beyond this five year period are not evaluated in this PHA.”(Preliminary Health Assessment).  A decision to allow thousands of pounds of toxic lead and copper to sink the lakes' bottom sediment should be made looking hundreds of years into the future. Not five. This shortcoming alone should be enough to trigger a federal environmental assessment.

-- By its own acknowledgment, the study does not take into consideration “factors such as critical habitat, special-status species or potable water intakes.” It adds: “These factors should be considered prior to the initiation of training exercises.” That hasn’t been done.

-- The study does not account for existing levels of background contamination in the proposed zones. “Training exercises that take place in areas with existing levels of contamination with the potential for cumulative impacts ... are not considered in this PHA.”

-- Metals including lead, a carcinogen and neurotoxin, will likely “dissolve into the sediment port water or adsorb (sic) to the surrounding sediment,” the study acknowledges. “Plants and animals that exist at the bottom of the food chain might ingest and be directly exposed to the metals in the sediment.” Scientific studies have already shown an alarming and unexplained decline in bottom-dwelling microscopic organisms that form the base of the Great Lakes food chain. The shrimp-like diporeia, for example, represent up to 75 percent of whitefish diets, but have disappeared completely from some areas of Lake Michigan and are declining in other lakes. Without understanding why this is occurring, it seems especially unwise to introduce unnecessary toxics that may compound the problem. 

-- The study uses a numerical “screening quotient” score for pollutants that will be released to the lakes. Scores of 1 or more are deemed “risks requiring further evaluation. The screening score for lead is 0.96. Given the global resources at risk, that ought to be close enough.

-- The study makes assumptions about the maximum number of 7.62 mm ammunition that will be fired; suggesting each of the 43 great lakes district Coast Guard stations would qualify as many as 10 gunners, discharging 1,000 rounds annually per gunner.

However, it is unclear how or why those figures were used, and what, if anything, would restrain the Coast Guard from increasing the numbers of gunners, numbers of practice rounds discharged, or even the type of ordnance fired. Any of those factors could significantly change the study's baseline assumptions.

-- Even using Coast Guard assumptions, 430,000 rounds of 7.62 mm ammunition annually would add close 7,000 pounds of lead compounds annually to lakes sediment. (9.7 gram bullet @ 76 percent lead equals 7.37 grams of lead per round. Times 430,000 rounds equals 3.17 million grams. Divided by 453.6 grams in a pound equals 6,986 pounds) That’s more than the entire state of Michigan and all its industries and pollution sources emit to surface waters every year. (4,069 pounds in 2004, per EPA Toxics Release Inventory)

-- The study does not account for migratory bird patterns or seasons. Any training should be done with consideration for the paths and timing of such migrations.

-- The study does not address individual sites on specific bases, but generalizes across the breadth of all 34.

Questions or concerns not yet adequately addressed by the United States Coast Guard:

Is there a study or analysis that suggests the probability that the Coast Guard will encounter the need to use deadly force against a target on the Great Lakes? If not, what is the rationale for this change in policy and training?

Have Great Lakes Coast Guard crewman performed live-fire training prior to this? Where? And why is that arrangement now deemed inadequate?

There are 34 proposed live-fire zones. Why 34? Why not five?

What sort of ordnance will be expended during these exercises? And what assurance can the public have that increasingly larger-caliber weapons will not seep into the mix?

What if anything would prohibit other branches of the military from using the same zones? Or helicopter gunners? Or local law enforcement with near-shore marine patrols. Could that include aircraft dummy bombing runs?

Is the Coast Guard willing to set an upper limit for the amount of ordnance, by weight or volume of toxic metals that would be expended annually? If not, what's to stop the lakes from absorbing increasingly higher concentrations of these pollutants if the USCG decides to train more gunners?

The Great Lakes are an international resource. What treaty or agreement obligations does such a change in policy affect?

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