Letter to U.S. Congressman Dennis Moore summarizing Sierra Club concern over the issue.

March 25, 2002

Honorable Dennis Moore
United States House of Representatives
Washington, D.C. 20515

Dear Congressman Moore:

The Sierra Club has been very interested in the land use of the Sunflower Army Ammunition Plant (SFAAP) since it became surplus. We believe that the proper disposal of the land presents a unique opportunity for all Kansans to enjoy prairie parkland reasonably close to a major metropolitan area. Specifically, we believe that a prairie restoration project such as the conversion of the Joliet Army Ammunition Plant to the Midewin National Tallgrass Prairie in Illinois is the best use for the 9,000-acre SFAAP land (see enclosed).

As part of our continuing interest and involvement with the SFAAP, we have been closely following the circumstances that lead to the recent introduction of KS Senate Bill 611. Kansas House Representative John Ballou from Gardner presented a letter from Blaine Hastings of GSA as part of his testimony before the Commerce Committee of the Kansas Senate. The letter and SB 611 are attached for your reference.

We are asking you to investigate the statements in this letter. We are especially interested in the statement that implies that the work on the NHPA studies will be completed soon. GSA has asked the U.S. Department of Justice to request an expedited hearing on the lawsuit with "Taxpayers Opposed To Oz"(TOTO) upon completion of the NHPA Section 106 process. Mr. Hastings believes that the studies and hearing will both be completed by the end of October 2002.

The October 2002 date appears unrealistic since the NHPA studies involve only part of the TOTO lawsuit. The other part involving the NEPA regulations has not yet begun and is extremely important to the Sierra Club and other conservation organizations.

Blaine Hastings has made similar statements to the Johnson County Board of County Commissioners, the DeSoto City Council, and DeSoto Mayor. In the past Mr. Hastings has held the threat of piecemeal selling off of uncontaminated land at SFAAP over the heads of those opposing the Oz proposal. The Oz proposal supported by Mr. Hastings greatly decreased the amount of land set aside for Johnson County Parks compared to the original request by Johnson County Parks.

We hope that you can clarify this matter for Sierra Club members and the citizens of Kansas. There is no need to rush to redevelop SFAAP until we are certain that the redevelopment proposal is truly in the best interests of the citizens of Johnson County and all Kansans. The GSA needs to understand that your constituents understand this to be the most important land use decision that will be made in the county in this decade. Thank you for your prompt attention in this matter.

Sincerely,

Craig Wolfe, Chair
Sierra Club - Kanza Group

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12 January 2004

Johnson County Board of County Commissioners
Johnson County Government
111 S. Cherry Street
Olathe, KS 66061-3441

RE: Proposed Redevelopment of the Sunflower Army Ammunition Plant Site

The Kanza Group of the Kansas Chapter of the Sierra Club (Sierra Club), representing more than 1700 members in Johnson and Wyandotte Counties, wishes to communicate its concerns about the recent activities of the Johnson County Board of County Commissioners (BOCC) pertaining to the proposed redevelopment of the Sunflower Army Ammunition Plant site (Sunflower).

• The BOCC should postpone making any formal decision on the redevelopment of Sunflower until meaningful public input and review can be completed. The BOCC has allowed little, if any, public participation in the development of alternatives for Sunflower, especially since the "Oz" plan was abandoned. No public hearings on the substance of the redevelopment plans were held, despite suggestions by some Commissioners in late November, 2003.
• The BOCC should allow more time for interested parties to submit completed redevelopment proposals, which should contain innovative land use designs. The County is missing an opportunity to "encourage environmental stewardship of our land and natural resources through role modeling, environmental advocacy and public education," as described in the Johnson County "Living our Vision" report approved in 1997. The only proposal currently under consideration is a typical suburban expansion consisting largely of single family residences built on quarter acre lots, with associated commercial services and with green space limited to streamway buffers. Furthermore, contrary to the County's vision, Sunflower is not being developed adjacent to the urban fringe and will only promote urban sprawl and "leap frog" development along the K-10 corridor.

The Kanza Group will submit more detailed comments soon.

Respectfully,

C. Elaine Giessel, Conservation Chair
Kanza Group, Kansas Chapter of the Sierra Club
11705 W. 101 st Terrace
Overland Park, KS 66214

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14 January 2004

Johnson County Board of County Commissioners
111 S. Cherry Street
Olathe, KS 66061 -3441

RE: Comments on the Proposed Redevelopment of the Sunflower Army Ammunition Plant Site

The Kanza Group of the Kansas Chapter of the Sierra Club (Sierra Club), representing more than 1700 members in Johnson and Wyandotte Counties, wishes to submit comments to the Johnson County Board of County Commissioners (BOCC) on the proposed redevelopment of the Sunflower Army Ammunition Plant site (Sunflower).

The Sierra Club opposes early transfer of the Sunflower land to the County, given the potential for future liability, and the uncertainties surrounding the extent of contamination at Sunflower and the estimated costs of cleaning up the site. The Department of the Army should be held responsible for cleaning up the contamination at the site to a level protective of public use before the County assumes ownership.

However, in the event that the BOCC chooses to move forward with approval of the Kessinger/Hunter proposal for redevelopment of Sunflower, the Sierra Club strongly urges the Commissioners to revisit the recommendations made by the Johnson County Citizens' Visioning Committee in its final report. This is particularly important since the BOCC has not provided any real opportunity recently for the general public to examine and comment on the plans for redevelopment of Sunflower, which was overshadowed by the OZ project.

In the 1997 report, the Visioning Committee concluded as a Guiding Principle that "the County should encourage environmental stewardship of our land and natural resources through role modeling, environmental advocacy and public education." This position was supported by a citizens' survey which indicated that "open space and parks" are one of the three things that Johnson Countians liked the best about living here. The survey also revealed that, of the major improvements and changes to work on during the next 20 years, citizens ranked highest the preservation of open space.

The Sierra Club concurs with the Visioning Committee that natural greenspace and wildlife habitats are valued by the public and should be protected. Large blocks of green space in the metro area are simply too valuable and too important to preserving the quality of life desired by area residents to waste on what amounts to a typical residential development with associated commercial facilities. Innovative land use design by developers and planners should be encouraged to ensure a balance between development and the preservation of open spaces. Acreage dedicated to parklands and recreation areas should be increased. Pollution of our watersheds and airsheds should avoided, and County residents should have multi-modal regional transportation options.

• The BOCC should appoint a Redevelopment Authority which includes a representative of the environmental community and which actively seeks and acts upon input from the broader community, including surrounding counties and non-governmental organizations.
• The BOCC should work with the GSA to expedite the direct transfer of the ~2000 acres of uncontaminated riparian buffer areas to Johnson County Parks and Recreation District, for public access and wildlife habitat, as signed into law last year.
• The BOCC should direct the Redevelopment Authority to increase the acreage devoted to natural open spaces and parkland at the site.
• The BOCC should require redevelopment of the Sunflower site to address proactively any associated environmental issues, including, but not limited to, the following:
  

  Inclusion of onsite alternative energy generation facilities (wind and solar). Maximization of acreage devoted to prairie restoration, which has low water requirements and provides carbon sequestration and climate mitigation. Protection of local watersheds and drinking water sources by creating stormwater retention systems, wetlands and expanded natural green spaces, by landscaping with xerophytes, by reducing impervious surfaces and by limiting use of chemicals onsite. Protection of groundwater, which has the potential to move toxic materials offsite. Protection of the regional airshed, which has the potential to be negatively impacted by increased road traffic and associated air emissions, especially since the Metro area downwind is likely to go "non-attainment" very soon. Provision of design elements which will allow any future development to be integrated rapidly into an effective regional public transportation system. Provision of onsite waste minimization, recycling and composting opportunities. Protection of public health on and around the site as cleanup and redevelopment progress. Provision of guarantees for long term monitoring and future remediation, as needed, to protect human health and the environment. The BOCC should create, as recommended by the Visioning Committee and without further delay, an Environmental Advisory Panel to bring citizens, elected officials and staff together to work in partnership towards common future goals.

Respectfully submitted by,

C. Elaine Giessel 913-888-8517
Conservation Chair, Kanza Group of the Sierra Club
11705 W. 101 st Terrace
Overland Park, KS 66214

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February 20, 2004

GSA Public Buildings Service (9PRF-10)
400 15th Street S.W.
Auburn, WA 98001

RE: Comments on the Supplemental EA for the Proposed Disposal of the Sunflower Army Ammunition Plant of Johnson County, Kansas

Dear Mr. Hastings:

Please accept the following comments on behalf of the Kanza Group of the Kansas Chapter of the Sierra Club. As Conservation Chair for this group, I believe that the Supplemental EA for the above-referenced property does not adequately address environmental issues that were originally raised by Craig Volland in his comments on the EA, submitted February 22, 1999. In addition, more technical information is now available that should have been addressed in the Supplement.

There was a lack of substantial treatment of the following issues in the original FONSI and EA; these issues are not addressed in the Supplement:

1. The economic and environmental impacts of the alternative for the Federal government to complete the entire clean up process and then transfer the property as one piece to the state and any subsequent owner.
2. The potential environmental and economic impacts of the transfer and reallocation of substantial water senior rights upon disposal of the Sunflower property. (See discussion in Volland letter of 2/22/99.)
3. The impacts of the remediation and property disposal on Johnson County and regional air quality, by failing to address the high probability of leap frog development without public transportation options. Since the original EA was completed, air quality in the Kansas City metro area has declined and new rules have been implemented for air quality standards for ozone. As a result, it is anticipated by MARC that the region will declared non-attainment by EPA in 2005. (See Volland, 1999.)
4. The impacts of remediating the 67 solid waste management units, 22 areas of concern, and 3 areas of groundwater contamination that have now been identified. Many of the SWMUs contain highly contaminated materials which will be covered and remain onsite.
5. The environmental and economic impacts of creating a Corrective Action Management Unit (CAMU) with soil treatment and permanent repository facilities onsite, versus the transportation and disposal of treated wastes offsite.

The Kanza Group of the Sierra Club believes that a FONSI is not warranted and that the proposed disposal of Sunflower will significantly affect the quality of the human environment in Johnson County and in the KC Metro area. Given the scope of the contamination at this site and the estimated costs to complete the remediation, the disposal of the Sunflower property constitutes a "major federal action" that should require a full Environmental Impact Statement according to the National Environmental Policy Act.

These comments are respectfully submitted by,

C. Elaine Giessel
Conservation Chair Kanza Group, Kansas Chapter, Sierra Club
11705 W. 101st Terrace
Overland Park, KS 66214

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