Nature of Environmental Impact Reports explained

I read with great interest Mr. Jesus D. Camacho’s letter on the Saipan Tribune, published on April 1, 2005. By the way, I only call people doctor if they have a medical degree, so please take no offense Mr. Camacho; it is nothing personal. Again, I feel Mr. Camacho has stepped outside his field of expertise when he starts to discuss EIRs. Environmental Impact Reports are required by the Environmental Protection Agency before federal land or funds can be used in a development project. They are only required by a state or local agency if they use federal land, federal funds, or there is a state or local law that requires them. If I am a developer, I own the land, and do not use federal funds; I don’t have to do an EIR.

Mr. Camacho states, “The rationale for EIRs stems from the fact that development, e.g., residential, commercial, and industrial, must not take place at the expense of the destruction and degradation of the environment.” This is clearly false. If no development was to take place at the expense of the destruction and degradation of the environment, then there would be no development at all! I would like Mr. Camacho to show me one EIR, involving development, that does not cause some environmental degradation. I know he will not find any.

The real purpose of an Environmental Impact Report is to help the people making the decisions become aware of what are some of the possible outcomes of a development project. Also the EIR helps by giving choices and ways that might lessen the impact of a project. An EIR does not give a complete picture of a project. This is usually done by using Cost-Benefit Analysis, and the EIR being part of the data use to do this analysis.

Again Mr. Camacho has made a blanket statement that is not true, “Should an EIR report clearly substantiate that the negative ramifications of development outweigh the positive ones, then the officials (generally city councils, county supervisor, planning commissions and boards) will issue a “thumbs down” in terms of approving it.” In an EIR, the negative ramifications will almost ALWAYS outweigh the positive ones. The EIR does not consider the economic, political or social benefits of a project. Again the EIR is not an end to itself for making decisions about a development project, but only one of the tools that should be used. Many projects have gone forward, even with substantial negative ramifications, because of the economic or other benefits it will bring to an area. Just look at the development of an airport. It has a definite negative impact on the environment.

Again, Mr. Camacho needs to look at when an EIR is usually done. It is done as part of the permitting process. In the CNMI, an EIR is submitted before permits to start development are issued. It is part of the package that is submitted to CRM, DEQ, and other agencies that regulate development. MPLA does not regulate land development as far as I know. So to get the lease from MPLA is not the end of the process but only the first step in it. Once the lease is obtained than the permitting process begins. Yes, Mr. Camacho is correct in stating that the company doing the development must shoulder the cost of the EIR and that they are very expensive, running up to 10 percent of the cost of a project. But, has ever a hotel or golf course on public land had to do an EIR before they got the lease to the land? Leasing the land and developing the land are two separate issues.

Since Mr. Camacho’s degree is not in mining or geology, I would ignore what he has to say about the affects of mining on the island of Pagan. Yes, mining will have a negative affect on Pagan. Mining always has a negative impact and there is no way around that. But proper restoration can minimize these affects. Coal strip mining used to leave behind a scarred land, but today with restoration, it is very difficult to tell unmined land from the area that was mined. The restoration process can be, and should be, built into the permits issued to any mining operation, including the current limestone quarries on Saipan, Tinian, and Rota.

As to should the pozzalon on Pagan be mined or not, again, I really don’t know. Economics and business are outside my field of expertise. I just know that, when I read the newspaper nowadays, our government is in financial difficulties because of the slowdown in the textile factories. Something will need to be done soon to increase the government’s revenues or we will have to live with increased taxes or fewer services. So is mining on Pagan a really bad idea?

Howard Cole
Marpo Valley, Tinian