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Statement of Earth Day Coalition (click here to download a pdf of this statement)

Earth Day Coalition is opposed to the U.S. Coast Guard proposal to establish 34 live firing ranges throughout the Great Lakes, covering more than 2,300 square miles of Great Lakes waters. Additionally, we are opposed to the Coast Guard testing weapons in the Great Lakes with live ammunition.

The four proposed permanent firing zones in Lake Erie, under the rule in the Federal Register, have no limits on when the zones can be used. That means any day, all day. We are also concerned that the Coast Guard has excluded their proposal from environmental review of the National Environmental Policy Act, the Clean Air Act and other environmental statutes.

There are numerous troubling issues with this proposal. We will address two:
Integrity of Lake Erie
•The proposed zones coincide with the three main N-S migratory routes over Lake Erie. Migrating wildlife such as birds, butterflies and fish will be impacted.

-Refer to map 'Lake Erie Overview' for the Coast Guard's proposed live fire zones.

-Refer to map 'Migration Map' (pdf)for a visual presentation of the proposed live fire zones coinciding with the major north-south migration routes over Lake Erie identified by J.P. Perkins - the West End Flyway from Sandusky to Point Pelee, Ontario; the West Central Flyway from Cleveland to Erieau, Ontario; and, the Central Flyway from Presque Isle to Long Point, Ontario.
-Refer to map 'USCG Live Fire-Migration Map' (pdf) to see the migration routes imposed on the live fire zones.
-Click here to see the Atlantic Flyway with principal routes over Lake Erie.

•Live-fire zones are directly in the paths of shipping lanes, ferries, recreational boaters and anglers. When permanent firing ranges are established in our lake, economic development, tourism, and recreation will be impacted. As we continue to strive to get more folks behind Lake Erie and its important environmental and economic development issues, will this, once again, reflect poorly on our lake.

Earth Day Coalition is requesting the Coast Guard do a 'Lake Erie only' Environmental Impact Statement (EIS) due to the fact it is the shallowest and most southern of the Great Lakes. The existing risk document averaged all the Great Lakes and the Chesapeake Bay, and did not account for existing contamination or migration routes, propose alternatives, or put any limit on when the firing zones can be used.

Impact on our drinking water

Earth Day Coalition is requesting the Coast Guard do an Environmental Justice assessment of their proposal. Cleveland has been named as the poorest city in the US. Our residents and children need consideration both for drinking water and fish consumption.

Military ammunition can contain depleted uranium, lead, and other toxics - increasing the risk of exposure to fish and the more than 40 million people who take drinking water from the Great Lakes. Low income and minority anglers in the Lorain, Elyria and Cleveland areas depend on supplementing their dinner table with fish from the lake.

Cleveland has the highest percentage of children with lead poisoning among cities with the major lead poisoning cases. Most children hurt by lead are never identified; and, new findings on lead's damage at lower levels are being promoted.

Lead is a persistent toxic substance - the Great Lakes Water Quality Agreement calls for zero discharge of persistent toxic substances. Ohio has a long, expensive and ongoing effort to clean up and regulate government waste. No additional lead or other toxics should be allowed to pollute Lake Erie.

Environmental Justice
According to Executive Order 12898 "Federal Actions to Address Environmental Justice in Minority Population and Low-Income Populations" section 1-101, "To the greatest extent practicable and permitted by law...each Federal agency shall make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations."

Staff should determine whether this case is a potential environmental justice case, and determine what actions will be taken once this designation is made. The Environmental Justice Community Involvement Team Leader should do this analysis. If there is a finding of disproportionate effect we request early, ongoing and increased public participation at a minimum. Every resident, especially low income and minority residents, are impacted by the water that flows from their tap. Our region deserves special environmental justice consideration.

According to EPA Region 5 guidelines, a minority area is one in which the "minority population percentage exceeds the State minority population percentage." (Ohio's average is 11.9%) These guidelines also defines a low-income community as one where "its low-income population exceeds the state population percentage..."

According to the U.S. Census Bureau, Cleveland has the highest poverty rate among America's big cities, with nearly a third of our people living in poverty (poverty rate the highest of any U.S. city with a population over 250,000).

City of Cleveland: Current population: 452,208 (2005 US Census estimate)
black residency: 51% (2000 Census)
persons in poverty: 32.4 percent (2005) ($20,000 income for a family of 4); median family income: $28,990
Nearly half of Cleveland's children were among the poor, again the highest rate among American cities with populations of 250,000 or more. The Cleveland area has been called one of the most racially segregated big cities in America.

Cuyahoga County: Current population: 1,351,009 (2004 US Census estimate)
black residency: 27.1% (2000 Census)
persons in poverty at 16.9% (US 13.3%); median family income: $52,719
Twenty-two percent of related children under 18 were below the poverty level, compared with 12 percent of people 65 years old and over.

Northeast Ohio: Current population: 2,839,151
black residency: 27.4% (2005 Community Survey)
persons in poverty: 555,860; median family income: $42,082 (US $43,300)

Click here to download a copy of the city of Cleveland's comments.

Which fish to fry? Mercury from Coalfired power plants is a public health concern especially for minority communities who fish for food. The Ohio Department of Health advises that fish consumption from all water bodies in Ohio be limited to one meal per week. While many efforts are in the planning stage, some happen almost every year---fishing expo in Rockefeller Park is one of them. Take a look.

Cost-effective Energy Efficiency options for NOx reduction available to Texas municipalities were discussed at four training workshops in Texas (2003-04). Take a look