July 23, 2004
Dr. James G. Roche
Secretary of the Air Force
Department of the Air Force
Pentagon, 1670 Air Force, RM4E871
Washington, D.C. 20330-1670
Comments Regarding Final Environmental Assessment For The Proposed
Relocation Of The California Air National Guard 129th Rescue Wing
Dear Secretary Roche:
The City of Mountain View remains deeply concerned about the proposed
relocation of the California Air National Guard 129th Rescue Wing (129th
RQW) and the adequacy of the environmental review conducted for the
City staff has reviewed the final Environmental Assessment (EA) document
regarding the proposed relocation and has identified what it views as
several significant deficiencies with the document. The City of Mountain
View is very concerned that if these deficiencies are not addressed
and rectified expeditiously, you and other decision makers will not
have the benefit of all relevant and accurate information upon which
to make the very important decision regarding whether or not to relocate
the 129th RQW.
Cost Analysis Deficiencies
Of particular concern to the City of Mountain View is the conspicuous
absence of any cost data or analysis in the final EA to support a recommendation
to relocate the 129th RQW. The City finds this problematic because cost
issues are identified in the EA as one of the two issues driving the
proposed relocation of 129th RQW operations.
Page 1-3 of the final EA includes a paragraph stating that NASA Ames
Research Center (the host at Moffett Federal Airfield) is "attempting
to implement large cost increases for the 129th RQW's lease agreements."
The paragraph goes on further to state that the cost increases will
require the 129th. RQW's costs to "increase substantially in the
future." The paragraph concludes by saying that the "life-cycle
cost analysis conducted by the ANG indicates that the costs of beddown
and moving could be recouped in as little as seven years at a less expensive
location and that over $125 million in savings could be achieved over
a 20-year period."
cost analysis the Air National Guard relied on to make such claims is
not included in the final EA document. Consequently, there is no way
to substantiate these statements or any of the other cost-related conclusions
included in the final EA document supporting the proposed relocation
of the 129th RQW.
In its earlier comments regarding the draft EA, the City of Mountain
View cited several concerns about potentially significant and fatal
cost errors and omissions that were included in the 20-Year Cost Comparison
of Relocation document (Appendix B to the draft EA).
While it appears that the Air National Guard may have revised some of
the cost data included in the 20-Year Cost Comparison of Relocation
document, because neither the document nor any update of the document
was included in the final EA, there is no way of knowing how or if the
City's earlier concerns with the cost analysis were addressed prior
to the completion of the final EA and how reliable the cost data used
in the final EA analysis is.
The City of Mountain View strongly believes that the cost analysis conducted
by the Air National Guard for this environmental analysis, and any revisions
made to it, should be included as part of the final document so that
decision-makers and other interested parties can review the accuracy
of the data used by the Air National Guard to support a recommendation
to relocate the 129th RQW. The absence of this vital information from
the final environmental documentation calls into question the veracity
and integrity of the entire environmental review process.
Omissions from Interagency and Intergovernmental Coordination
for Environmental Planning (IICEP) Comments. and Responses
The IICEP section of the final EA provides no explanation of the methodology
used by the Air National Guard to determine what comments from other
governmental agencies or individuals would be included as part of the
The City of Mountain View is aware of several other letters of comment
regarding the proposed relocation of the 129th RQW that have been submitted
during the past year to you and other Guard and State officials that
were not included in the IICEP section of the final EA.
The City is concerned that the absence of any or all of these letters
from the final environmental document and record may skew decision-makers'
perceptions regarding the extent of the public's interest and concerns
about the proposed relocation.
City of Mountain View is aware of at least 14 letters commenting. on
the proposed relocation of the 129th RQW that were not included in the
final EA. Copies of these letters are enclosed.
The absence of these letters in the final EA should be explained or
the final document should be revised to include these documents.
The City of Mountain View appreciates the willingness you have demonstrated
previously to consider its concerns about the proposed relocation of
the 129th RQW.
The City urges you to take no action on the proposed relocation of the
129th RQW until the significant and potentially fatal deficiencies with
the environmental review process used to evaluate the proposed relocation
of the 129th RQW have been fully addressed and resolved.