Letter to Rober Wittig, Commander of the Army Environmental Command - Supplemental Programmatic Environmental Assessment (SPEA) for Army 2020 Force Structure Realignment

Letter

Colonel Robert C. Wittig
Commander, U.S. Army Environmental Command
2450 Connell Road (Building 2264)
Joint Base San Antonio-Fort Sam Houston, TX 78234-7664

RE: Supplemental Programmatic Environmental Assessment (SPEA) for Army 2020 Force Structure Realignment

Dear Colonel Wittig,

As the Member of the U.S. House of Representatives who has the privilege of representing Joint Base Lewis-McChord (JBLM) in Congress, I am writing to express my grave concerns regarding the Supplemental Environmental Assessment (SPEA) for the Army 2020 Force Structure's proposed action. This proposal could mean the elimination of up to 16,000 military and civilian personnel at the installation, a move that makes the Army's Finding of No Significant Impact (FONSI) a little hard to believe.

My concerns regarding this proposal are grounded in three areas:

The lack of due diligence and flawed modeling.

The impact to our national security strategy.

The inattention to the consequences of previous personnel actions at JBLM.
With regard to the lack of due diligence and flawed modeling, please find, attached, two studies that have been conducted here in Washington State, one by the Pierce County Office of Economic Development, and the other by Washington State's Office of Financial Management. Pierce County, where JBLM is located, has studied the economic impact of the installation for many decades and in fact, its citizens used an economic analysis performed by the county to make the initial decision to give land to the Army for the development of Fort Lewis some 97 years ago. Specifically, the Pierce County Study objected to:

The definition of a "Region of Influence" (ROI): The ROI should be localized so as not to mask or dilute the impact.

The estimate of impacts on income: The multiplier used by the Army to calculate income loss, when direct, indirect and induced effects are accounted for, is unusually low as compared to standards used by industry and the U.S. Bureau of Economic Analysis.

The standard that needs to be met before a consequence is considered "significant": According to the Army, unemployment would need to reach 7.1% to be considered "significant" however, during the recent "Great Recession" the employment losses nationally reached 5.6% according to the Bureau of Labor Statistics, and were considered the greatest economic crisis since the Great Depression of the 1930s.
The estimated impacts to local revenue: The Army uses an average tax rate that combines rural and urban areas, but should use a tax rate reflective of where the most sales activity happens, which is in urban areas where the higher tax rates are.
The lack of recognition in assessing cumulative impacts. JBLM is a joint base with an Air Force partner. Nowhere in the SPEA does it take into account parallel moves by the Air Force. Similarly, no mention is made of parallel moves by the Western Region Medical Command (Madigan) or the Guard and Reserve components. Installation Command (INCOM) recently announced a Reduction in Force (RIF), but no accounting of that action is made in the SPEA.

The study performed by Washington State's Office of Financial Management (OFM) also provides critical new information to the SPEA process. OFM is responsible for providing the Washington State Legislature with revenue forecasts so that it can develop its biennial budget. The Legislature, by law, must develop a budget that leaves a positive ending balance. It therefore needs the most accurate revenue forecast possible. OFM found several flaws in the Army's model and analysis that resulted in inaccurate conclusions. In some cases, OFM found that the impact to the local community was up to three times greater than the Army's findings. Specifically, OFM found:

The Army used the "Economic Impact Forecast System" (EIFS) Model, which is designed for the sole use of the military and employs national coefficients as its basis to calculate impact. OFM uses the REMI model, which contains variables calibrated to reflect the Washington State economy. The OFM analysis used state budget data from the Washington State Office of Revenue Forecast Council that contains actual Washington State retail sales tax collections, as well as other tax revenue data. This data, in combination with the stated personnel reductions reported in the USAEC report, provided the basis for OFM analysis.

As an example of the differences in results, in 2016 alone, the USAEC assessment projects a job loss of 4,300 positions while the OFM assessment predicts 13,470 lost positions.

In each of the five years that this SPEA covers, the numbers in the OFM study paint a darker picture. The Army predicts the cumulative 5 year sales tax loss at $17.4 million, while OFM predicts sale tax losses in 2016 alone to be $20.47 million.
I would like to see an explanation from the Army as to why using national coefficients as a basis for local economic modeling is appropriate in determining accurate impacts.

In January of 2012, the President and the Secretary of Defense released the new U.S. Defense Strategic Guidance which articulated the priorities for a "21st Century Defense" that sustains U.S. global leadership. This guidance correctly concluded that U.S. economic and security interests are linked to the economies and military forces developing in the Western Pacific, East Asia, Indian Ocean region and South Asia. Seven of the ten largest armies in the world reside there. The "Asia Rebalance" is a strategy that will maintain peace, the free flow of commerce and U.S. influence in the region through strengthening relationships and the development of cooperative military partnerships to effectively response to crises.

As the only multi-service Power Projection Platform west of the Mississippi, JBLM is ideally situated to execute this new strategy for our nation. With two deep water ports within 15 miles of the installation, an adjoining airfield home to 47 C-17s, a 327,000 acre training ground less than two hours away, as well as Navy assets such as aircraft carriers, destroyers, and submarines within an hour's drive, JBLM is the premier installation to train and launch joint missions. Reducing the capabilities of such an asset would be unwise and would work against our priorities for a 21st Century Defense.

I would like to see an analysis of reduced capabilities and its impact on our national security strategy should the Army decide to eliminate military and civilian personnel at JBLM.

Lastly, I am concerned that the Army has not looked at the impact of recent personnel actions at JBLM and their consequences to the region. Two seminal events occurred last year at JBLM. First, Cadet Command moved the Leadership and Development Assessment Course, also known as Warrior Forge, to Ft. Knox, Kentucky. In addition to the losses of locally stationed personnel caused by the displacement of the 8th Brigade, 5,000 cadets did not visit JBLM for the first time in decades. We cannot find any savings attributed to this move. There was no analysis done regarding the economic impact to the region either before or after the move.

The second personnel action, which resulted in the loss of 4,500 soldiers and the deactivation of the 4/2 Stryker Brigade, was caused by last year's Programmatic Environmental Assessment (PEA). We have not yet completely felt the economic impact of that action, as personnel transfers, retirements and separations are not complete. Before the Army implements additional cuts, a thorough comparison between what was predicted and what actually happened needs to be explored.

I would like to see an analysis of the impacts of already implemented personnel actions at JBLM before additional decisions are made.

Thank you for taking the time to read my comments regarding the Supplemental Environmental Assessment (SPEA) for the Army 2020 Force Structure's proposed action. As you can imagine, I am deeply concerned about the wellbeing of my constituents and this nation should these actions be implemented. I trust the Army will use these comments, and those of others in the JBLM community, to gain a better understanding of the possible impacts.

Sincerely,

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