NEPA Law

It appears the Environmental Assessment (EA) was prepared in violation of NEPA law (40 C.F.R. 1502.5), which states the EA will  “serve practically as an important contribution to the decision-making process and will not be used to rationalize or justify decisions already made” 

Based on data provided by American Ordnance, we believe the Army prepared the EA to justify decisions already made.

The contract was awarded in the fall of 2008.  The EA was released on June 4, 2010.

We also believe the EA should have addressed environmental impacts at both facilities, Milan and Iowa since AO is operating under one contract for both plants.

Such a study would have addressed specific environmental impacts of Milan and/or Iowa?  (e.g., permitted air emissions that will be eliminated at MLAAP will likely occur at ILAAP, Indiana Bat, etc.)

EA Results

The EA states that our region will only feel a minimal impact on the economy after 500 or more jobs are moved from MAALP to Iowa.

An independent consulting firm from Jackson, Tn. prepared an objective study that calls into question the findings of the Malcolm Pirnie Study commissioned by American Ordnance.

The independent study indicates an annual $202 Million impact on the state of Tennessee; Over $81 Million in lost wages annually; $800,000 in lost tax revenue to Gibson Co. annually; $400,000 loss in tax revenue in Carroll Co. annually; $1 Million in lost revenue to MPU annually, and total lost jobs of over 2,400 when the ripple effect was considered. (This is the same problem that we have with the AO Study – we only explain a little over $83M of the $202M.  If the 2400 jobs lost covers the rest we need to state that.)

Since there is such a disparity between the independent study and the AO study, we need to examine the data and its sources for the AO Study.

Historically the Facility Use Contract process, including the use of ARMS funding, has resulted
in less than 120 jobs over the last 14 years.  How can AO justify in their study the statement that they
will re-employ 260 – 580 individuals based on new tenants under the facility
use contract?  Where is the objective, credible and verifiable information that substantiates this
assertion? With continued depletion of the local industrial base, what positive
changes or factors has the AO study identified that counter current regional
and historical trends?

Depleted Uranium

The EA (pages 17 & 18) specifically requests more permits to store Depleted Uranium at MAAP.

We are extremely concerned that potential DU demilitarization efforts could have long term effects on the health and well being of the MAALP workforce and our community.

We are also concerned that storing additional DU at MAALP could have an adverse effect on our future industrial recruitment/job recruitment?  We have lots of unanswered questions about the DU issue.

EA Preparation & Release

We believe the company that prepared the EA, Malcolm Pirnie, has a conflict of interest at stake.  Malcolm Pirnie is owned by Arcadis, who has performed  millions of dollars of contract work in the arsenal over the last 5 years, specifically in the area of environmental monitoring and remediation. Additionally, AO was allowed to select Malcolm Pirnie.  We also have reason to believe that contract funding allocated to American Ordnance was used to fund this study.  Please explain how this sequence of events can be considered appropriate and lawful to the requirement of 40 CFR Chapter V that an independent assessment be performed.

Malcolm Pirnie failed to provide any methodology about the data collection process to include the authoritative sources for the data.  We need the source data as well as the citations for the authoritative sources to be able to fully analyze and evaluate the study.

Public Notices about the release of the EA were never published in local newspapers as set forth in 32 Code of Federal Regulations (CFR) Part 651.   As stated in the EA itself, public notices were supposed to be published in the Milan Mirror, Milan; Carroll County News Leader, Huntington; McKenzie Banner, McKenzie; and Jackson Sun, Jackson.  The News Releases which have been provided do not meet legal sufficiency as Public Notices since they are not required to be published, nor are they considered an official communication.  None of these newspapers were provided these public notices before the EA was released.

 MLAAP Workforce

Since 1941, the workforce at MLAAP has proven time after time they are capable of producing ammunition of the United States Army cheaper, safer, and more efficient.

In a recent quality management report published by www.qualitymag.com, MLAAP ranked #5 in the country for production quality while Iowa Army Ammunition Plant came in at 133.  Is that the kind of quality ammo we want to send our soldiers?

BRAC 2005

In 2005, BRAC announced Milan AAP as a future Munitions Center of Excellence to remain viable as a production facility to provide ammunition to the American warfighter.  AO’s current contract reduces Milan AAP to a commercial logistics facility to be used as a production sight for surge production if needed.  How can AO and JMC change the guidance of the BRAC commission, which has now become law?

In light of the concerns listed above, I respectfully request a public hearing, along with an Economic Impact Statement at the earliest opportunity.