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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 proposed relocation.

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."

Inexplicably, the 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 final EA.

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.

Specifically, the 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.

Sincerely,

Matt Pear
Mayor