Military: Mitigation plans to be determined next year

Loss of acres of coral, native forest ‘unavoidable’ Dentons says mitigation plans ‘vague’

The Marine Corps Forces Pacific says mitigation plans will be defined over the next year for live-fire ranges on Tinian and Pagan, as no plans have been committed to yet in draft impact documents.

The construction and impact of “live-fire” ranges is expected to have “significant” and “unavoidable” impacts to Tinian and Pagan, resulting in the loss or displacement of coral reef and local bird species, and, among others, the removal of thousands of acres of native forest, according to impact documents.

Per the Council on Environmental Quality, the military is tasked under the National Environmental Policy Act to provide “appropriate mitigation measures not already included in” the military’s proposed action. It also tasks federal agencies to provide the “means to mitigate adverse environmental impacts.”

MARFORPAC executive director Craig Whelden told Saipan Tribune that it would be “premature” to decide on mitigation before public comment period is over and input is evaluated.

The executive director was responding to concerns from the CNMI side of the draft impact analysis that the military did not follow through on their obligations to NEPA with the indefinite and unclear plans for mitigation left in the draft impact documents.

For one, impact documents use the word “may” repeatedly in describing military mitigation plans, when this is not the same as “will.” Another concern is the lack of discussion on the benefits and disadvantages of mitigation methods like relocation of bird conservation areas, or the transplanting of coral species.

Whelden said, though, that they could not “commit to ‘mitigation’ before its time.” “That’s why you see nuanced language such as “may” or “will consider” in the DEIS,” he said.

Whelden said they are currently in the public comment period and it would be premature to decide on mitigation before the public is given the opportunity to be fully heard. He said they would then spend the next year—until final impact documents are finalized—evaluating input received from the public and regulatory agencies to “determine the most appropriate mitigation for identified impacts. 

“The final [environmental impact statement] and Record of Decision will spell those out,” he said.


Under all the training alternatives proposed for Tinian, their would be the removal of around 1,800 acres of forest and herbaceous scrub habitats that are used by native land birds like the Tinian Monarch, the Collared Kingfisher, Mariana Fruit Dove, and White-Throated Ground-Dove.

Under the military’s preferred alternative, 7,200 Tinian Monarchs, or about 8 percent of the total population, will suffer loss of nesting and foraging areas. Unavoidable noise impacts to foraging Mariana Common Moorhens from large-caliber munitions near the military’s proposed “High Hazard Impact” area are also described.

The impact documents say the Department of Defense may consider “forest enhancement” practices, and would implement training restrictions within limestone forest. It also says new conservation areas will be implemented for this wildlife.

Dentons US LLC, the firm contracted by the administration to review the military’s impact documents, told reporters during their trip to the CNMI that the impact documents did not contain enough information for adequate review of mitigation.

Their comments suggest what kind of mitigation the military would need to adequately mitigate harm to the environment, and comply with NEPA.

Dentons’ Matthew Adams said the impact documents had “vague promises of creating future planning documents that will somehow address mitigation, but there are no standards, there are no specifics.”

Jim Kean, a wildlife ecologist by training and another consultant with Dentons working under Environmental Science Associates, said this was “not keeping up with the spirit and the letter of the law of NEPA.”

Keany also drew a picture of scale of impacts to the CNMI’s relatively small island ecology, saying that the scale of military impact is “not parallel with what’s on the ground.”

“We are talking about a very unique natural landscape here, an island community,” he said, referring to Tinian. “When you are talking about islands, impacts are particularly important, even small impacts can have a particularly great impact on small species.”

“The Navy looks at the impacts and says [they] are effecting 17 percent of the habitat, [and that] the bird populations might be reduced a little…but then if you look at the larger scale of things—on an island ecology standpoint—the total landmass of the CNMI is only about the 17 percent of the land base of Rhode Island, and so this is a very unique bird species on a very specialized landscape.”

“You can’t really discount that,” he said.

Keany said this kind of dynamic needs to be taken into effect in talking about island ecology, however, they did not see “any context” for this in the impact documents, he said.

Dennis B. Chan | Reporter
Dennis Chan covers education, environment, utilities, and air and seaport issues in the CNMI. He graduated with a degree in English Literature from the University of Guam. Contact him at

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