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GLIN==> Live Fire Public Comments



This proposed rule is very misleading in that it
frames the issue as the creation of safety zones
rather than the creation of live fire exercises (which
would naturally require safety zones).  

By defining it this way there is obviously no
environmental impact to consider from the firing of
small arms and larger artillery in the Great Lakes. In
other words, the proposed rule, creating safety zones,
does not impact the Great Lakes ecosystem whereas the
live fire exercise does have such an impact.  

If the rule was framed as what it truly represents,
the filling of the Great Lakes with lead containing
ordinance, and TNT and RDX containing artillery, then
there would be an environmental impact to consider
(and comment on).  

This was a very tricky method for the Coast Guard to
take on this issue.  It does not put the impacted
stakeholders on notice that the rule will affect them.

Our organization will be commenting on this
misdirection and also the environmental requirements
being ignored under NEPA, RCRA, CERCLA (future cleanup
of current contamination), CWA, and the inconsistency
with prior Great Lakes cleanup decisions such as the
preliminary assessment of artillery at Fort Sheridan
under CERCLA, and the Chicago Gun Club Area of Concern
near Chicago.

Best regards,

Steven Pollack, J.D.
Founder, Blue Eco Legal Council
www.BlueEco.Org

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