The Naval Facilities Engineering Command (NAVFAC) Marianas announced the start of a 45-day public comment period for the Programmatic Agreement (PA) memo associated with Marine relocation projects on Guam.

The memo in question concerns the military relocation to Guam and the CNMI of thousands of Marines and service personnel from Okinawa, Japan.

The relocation of more than 5,000 is slated to start in 2022 with the first wave of 2,500 Marines. The remainder would be due by 2027.

Specifically, the memo looked at the impacts, cultural, environmental and economic, that the buildup would have on island communities.

PA Memo #2 (Revised): J-755 Urban Combat Training Project Design Studies, formerly known as Anderson South Future Defense Policy Review Initiative (DPRI) Project Design Studies is the second such memo released by NAVFAC and vetted by public commentary. The revised version of the PA Memo #2 replaces the prior memo dated Oct. 10, 2013.

The memo proposes "geotechnical and topographic surveys to support project design efforts for the future J-755 Urban Combat Training area within the bounds of Andersen South."

Formerly known as the Andersen Administrative Annex or the MARBO (Marianas Bonins Command) Annex of Andersen Air Force Base, Andersen South covers approximately 2,000 acres in east central Guam.

Area of potential effects

The current project looks at a new area of potential effects reduced from 1,946 acres in the first PA to 580 acres.

Of particular significance to this memo are the sections dealing with potential development zones where sites of historic import have been found. The memo cites four sites of historic significance within the proposed area and includes an additional site not included in PA #1.

"While the site has not been formally evaluated for eligibility on the National Register of Historic Places (NRHP), the DOD has determined that this site should be treated as eligible for purposes of consultation pending further archaeological investigation," the memo stated.

In response to a past comment which stated that the lack of subsurface testing should be considered as noncompliance with procedures, the Department of Defense replied, "Federal agencies are expected to make a “reasonable and good faith effort” to identify historic properties, including archaeological sites listed or eligible for listing on the National Register in the APE ... the level of effort is reasonable and in good faith, not 100 percent or exhaustive."

The DOD determined that the proposed project will have "no adverse effect on historic properties" because stipulations and safeguards have been put in place to avoid such detrimental outcomes. Those safeguards include:

• A mandatory cultural resources awareness briefing will be given to the design studies service providers, including guidance on avoidance areas.

• Prior to the onset of the work described in this memo, previously established high-visibility fences enclosing a 10-meter buffer around each historic property will be inspected by the DPRI CRM, who will ensure that the fences are properly in place around each of the historic properties.

• As per PA stipulation VI.F., the DPRI CRM will provide site checks to ensure the protective site buffers have not been breached.

Public comment phase

Public comments will be accepted through Oct. 15 and can either be submitted electronically to or in person at the State Historic Preservation Officer (SHPO) at the Guam Historic Resources Division Office, 490 Chalan Palasyo, Agana Heights.

Mandates of the programmatic agreement require the DOD to take into account comments received within 45 days of the date of the delivery of this PA memo to the SHPO and public notification via the CRI website.

Earthjustice lawsuit

The PA does not address concerns raised about the impact to the military buildup on Guam from the lawsuit filed in federal courts in Saipan.

The suit was filed by the environmental advocacy group, Earthjustice, and asked the court to have the 2010 and 2015 records of decision regarding the Marine relocation to the Marianas vacated on the ground that the Navy failed to comply with the National Environmental Policy Act.

The removal of the 2015 record of decision would present an impediment to the planned relocation.


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