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Kentucky

August 26, 2014

Clarksville-Montgomery County responds to proposed military cutbacks

fort campbell gate

The Clarksville-Montgomery County response to proposed cutbacks at Fort Campbell has been sent to the Department of the Army’s Supplemental Programmatic Environmental Assessment (SPEA) for Army Force Structure Realignment for Ft. Campbell Kentucky.

Mayor Kim McMillan, joined by Montgomery County Mayor Carolyn Bowers and Clarksville Area Chamber of Commerce Executive Director Melinda Shepard, sent public comments on behalf of Clarksville-Montgomery County describing the significant impact a troop reduction could have on the community.

“For the last two months, we have been working on this project virtually nonstop,” said Mayor McMillan. “Our community’s response has been a true team effort. We have received support and information from the Chamber of Commerce, the Economic Development team, the Clarksville-Montgomery County School System, Austin Peay State University, the Regional Planning Commission and the Nashville Chamber of Commerce. We have talked with Representative Joe Pitts, Representative Curtis Johnson, Congressman Marsha Blackburn and representatives from Senator Bob Corker’s office and the U.S. Senate’s Committee on Foreign Relations. While we could not put into words the value each and every soldier brings to our community, we have attempted to address the economic impact a troop reduction would have on Clarksville, Montgomery County and all of Middle Tennessee.”

“I also want to thank everyone who wrote letters in support of Fort Campbell. We have heard from the recipients and know that these letters are emphasizing the importance of the installation to our citizens. We believe the letters are making a difference,” said the Mayor.

Fort Campbell straddles the Tennessee-Kentucky state line and has a critical impact on both Clarksville and its northern neighbor, Oak Grove/Hopkinsville, Kentucky.

The next step in the process will be a listening tour where additional comments may be invited. The City has not yet received the date or location for the listening tour but it will be announced.

The response targets the key areas of impact, including housing, jobs, education (schools), business and more. The following is the complete text of the document.

PUBLIC COMMENT REGARDING
THE SUPPLEMENTAL PROGRAMATIC ENVIRONMENT ASSESSMENT
(DATED JUNE 2014)
SUBMITTED BY CLARKSVILLE-MONTGOMERY COUNTY, TN

For the most part, these comments are offered in the same format as was used in the original SPEA. However, a few data points are sufficiently significant that they overlap all specific socioeconomic factors. Those points are:

Due to its geographic location, Clarksville-Montgomery County is in a prime position to reach most of the U.S. within a short travel time. Twenty-three states are located within a 500-mile radius of Nashville (40 miles southeast of Clarksville) and half of the U.S. population lives within a 650-mile radius of Nashville. The Nashville Metropolitan Statistical Area (MSA) is the largest metropolitan area in a five-state region. The combined Nashville and Clarksville MSAs are one of a small number of U.S. metros where three major interstate highways converge, with immediate access to large parts of the country.

The largest single occupational group in the combined Nashville MSA and Clarksville MSA is Military, based on SOC (Standard Occupational Classification). This equates to more than twice the number of all accountants in the two MSAs combined, more than twice the number of all registered nurses and more than all Technology, Architecture and Engineering occupations combined.

There is a high level of synergy in migration within the region. Montgomery County is a net supplier of in-migration to the Nashville MSA (about 1,500 persons annually). The largest recipient counties are Davidson (662 in the most recent year), Rutherford (385), followed by Robertson, Cheatham and Dickson. This is one indication that population from Montgomery (28% of Clarksville MSA employment is military) finds job opportunity throughout Middle Tennessee and provides an important source of skilled workforce for the larger region.

Federal military contribution to GDP in the two MSAs is equal to 70% of the state and local government share of the combined area’s GDP, up from 53% in 2001

Military share of personal income in the combined Nashville MSA and Clarksville MSA is $3.2 billion or almost 4% of total personal income, a larger share than any of the following sectors: tourism/hospitality, education, arts, real estate, Information, transportation, wholesale trade, nondurable manufacturing, and management of companies.

The following comments pertain to specific content from the SPEA:

economics1) Economic Impact Forecast System (EIFS) Lacks Documentation: Page 4-1, line 33, a determination could not be made from the documentation in the SPEA and from documentation in the PEA January 2013 as to whether the Economic Impact Forecast System (EIFS) uses “employment by place of residence” or “employment by place of work”. Page 4-175, lines 6-8 imply “employment by place of residence” from US Bureau of Census information was used rather than US Bureau of Labor Statistics data. While employment by place of residence (labor force) and employment by place of work may approximate one another for the Region of Influence (ROI), the reality of commuting in and out of the region for jobs may create an actual imbalance between these two factors. Further, employment impacts by place of residence versus place of work does make a significant difference on the impact of local revenues when local option income taxes are based on where one works and local option sales taxes tend to be based on where one lives. (Note: The impacts on temporary assignments to military bases are not evaluated, and the base population is not included in the Decennial Census for the jurisdiction containing the base.)

2) No Documentation of Significant Impact Definition: Page 4-2, lines 13-15, no documentation could be found to support the establishment of the negative significant threshold from 1969 to 2011 for sales at 75% of the maximum decrease, for income and employment at 66% of the maximum decrease, and for population at 50% of the maximum decrease.

3) Ignores Differences in Local Revenue Sources and Ignores Many Sources: Page 4-3, lines 18-29, the use of state average and local sales tax rates to measure the impact of force reduction on government revenues severely masks the differences in how state and local jurisdictions generate revenues. For example, in the case of the Clarksville (TN) metropolitan area, local jurisdictions in Tennessee may raise revenue through local sales taxes up to 2.75% imposed on the State sales tax of 7% on purchases except food for which the State rate is 5% (combined rate of 9.5% on most purchases and 7.5% on food for Clarksville and Montgomery County, 9.25% for Stewart County); whereas, local jurisdictions in Kentucky do not have a local sales tax option, but do have a local income tax option added to the State income tax and State sales tax of 6% (Hopkinsville at 1% and Oak Grove at 1.5% local income tax on wages). Further, Tennessee is among the few states that do not have income taxes on earned income; whereas, Kentucky does have a State income tax on all income (6% of annual income of $75,000 and greater). The differences in how revenue is generated at the State level results in different impacts on State-aid provided to local jurisdictions. Historically, the greater local jurisdiction revenue generated from local income taxes or local sales taxes compared to property taxes, the greater the sensitivity of the local jurisdictions revenue sources to economic swings such as a federal military force reduction. Finally, the use of only sales taxes to reflect the impact on local and State revenues ignores the differences in local real and personal property taxes. Because property tax rates are updated less frequently, they are less sensitive than income and sales taxes to economic swings; yet, a significant impact on employment will adversely affect commercial and residential property values and property tax revenues. Moreover, property taxes represent about 60% of the local revenue compared to 40% for sales taxes and other local sources in Montgomery County. The projected decrease in sales tax and property tax revenues resulting from a permanent reduction in personnel on the Fort Campbell installation will have a significant negative impact on Clarksville-Montgomery County.

4.6.12 Socioeconomics Page 4-176 Housing

housingComment: The Impact on the Housing Industry will be catastrophic.

Page 4-176, lines 21-22 (Page 4.4-9, lines 9-10 of PEA January 2013) states “…construction of multi-family dwellings is limited.” From year 2000 to 2010, Montgomery County (TN) increased from 52,167 units to 70,406 units per the Decennial Census. Of the change of 18,829 dwelling units, there was an increase of 5,088 multi-family dwelling units. Further, the percent of multi-family dwelling units of all housing units increased from 21.9% in year 2000 to 23.4% in year 2010. Over the 10-year period from years 2000 through 2009, 13,961 single-family buildings permits yielded a net increase of 13,508 single-family detached homes; and 5,203 multi-family unit permits yielded 5,088 new multi-family units, in the decade in Montgomery County. The pace of new dwelling unit construction has been slowly declining from a high of 2,500 units (2,088 single-family and 412 multiple-family unit permits) in the year 2004 to 1,745 units (1,165 single-family and 580 multi-family dwellings) in year 2013. The home construction industry (Edsel Charles, Market Graphics Research Group, Inc., Franklin, TN) estimates the annual new single-family home construction will be about 1,320 dwellings per from June 2014 through December 2019.

According to the Clarksville Home Builders Association, a monthly comparison of home sales between January 2011, January 2013 and January 2013 shows the number of home sales as 153, 190, and 158 respectively and have average sales price of $154,734, $164,923 and $159,137.

Over the past 12 months, there have been more than 1,100 new home starts in Montgomery County alone. In the five county area (Montgomery, Cheatham, Christian (KY), Dickson and Robertson) there have been 1,518 new building starts.

While these numbers establish a stable and growing housing market, it is vital to acknowledge that 70% of the individuals (military and civilian) working on the Fort Campbell installation live somewhere other than on post. It is also important to acknowledge that for every 1 house built, it is estimated 10 jobs are created, meaning that the negative impact of Alternative 1 will be significant beyond any increase in unoccupied housing. The housing market remains in recovery in the Clarksville market. Permits for new housing units in the average of the most recent three years (2011-2013) still remain 10% below the average annual levels for the decade 2001-2010 and 40% below the peak year of 2006. This indicates that future losses of demand – in which military households are critical- could produce highly adverse and destabilizing conditions in the area’s housing market, both single- and multi-family, and in the construction sector that experienced record losses of employment through the Great Recession and afterwards.

With an average of over 500 new multi-family dwellings, the characterization of multiple-family as “limited” is inappropriate and with the number of housing units occupied by employees directly related to activities at Fort Campbell, the effect of Alternative I would be catastrophic to the community.

Page 4-176 Schools

Comment: The Impact on schools will be catastrophic.

The Clarksville-Montgomery County School System (CMCSS) provides students with an unparalleled learning environment. There are currently 32,586 students enrolled in CMCSS schools and 8,156 of those are identified as being connected to the military (approximately 25%). The system averages between 25 – 28% military related students. In addition to the various programs offered to all students, CMCSS also provides counseling programs for students of deployed parents and for students dealing with multiple moves. CMCSS works with a Military School Liaison Officer to assist with smooth transitions for families moving into the community and with the Military Interstate Compact in trying to minimize the impact of moves on each student’s ability to graduate on time with a regular education diploma.

Here are a few highlights about CMCSS and the education Clarksville-Montgomery County students receive:

• Over half of the students in grades 3-8 in Montgomery County schools received proficient or advanced scores in all 4 Tennessee Comprehensive Assessment Program (TCAP) subject areas.
• Over half of the 9-12 grade students received proficient or advanced scores in 6 of the 7 TCAP subject areas.
• Montgomery County high schools have a 94.0% graduation rate and all individual schools in the district have graduation rates higher than the Tennessee average of 86.3 and far above the National average of 80%.
• Montgomery County schools also outperform the state in K-8 promotion with a rate of 98.6. (The Tennessee average is 98.2.)
• Students in Montgomery County schools score higher on average on the ACT than other Tennessee public school students.
• Montgomery County schools received a Tennessee Value-Added Assessment System (TVAAS) composite score of 5. Over half of the schools in the district that were rated received a TVAAS score of 5 in at least 2 of the 3 evaluation areas
• Montgomery County students outperform the State in K-8 and High school average daily attendance rates.
• Montgomery County high schools have an extremely low dropout rate of 1.8% in comparison to the State rate of 7.3%.
• Montgomery County schools have fewer suspensions (5.7%) and expulsions (0.4%) than the state average at 7.5% and 0.6% respectively.

In addition to the outstanding performance of Clarksville-Montgomery County public schools, the SPEA also fails to mention the impact on Austin Peay State University, Tennessee’s fastest growing University, and the programs it makes available specifically to the Fort Campbell installation. At least one in five APSU students are military connected (active duty military, veteran, or family member).

Currently, there are over 1,000 students who are active duty, veterans and/or military family members enrolled for the 2014 fall semester on the APSU main campus. (226 military, 422 family members and 465 veterans/retires = 1,113 military-related enrollment.) Since 2008, enrollment for military-related students has averaged 1,500 students per term.

cmcssDuring the past three years ending June 30, 2014, Austin Peay educated:

• 2,283 different military, veterans, or family members using federal educational benefits in the 2011-2012 academic year
• 2,462 different military, veterans, or family members using federal educational benefits in the 2012-2013 academic year
• 2,438 different military, veterans, or family members using federal educational benefits in the 2013-2014 academic year
Over this three year period, a total of $29,169,722 in tuition and fee revenues were received from programs that serve military and military connected students (Tuition Assistance for active-duty military, Army nursing education, ROTC, MyCAA for military spouses, and Veterans Administration programs. Of that amount:
• $5,547,432 in Tuition Assistance received for active-duty soldiers
• $236,281 in Tuition Assistance received for active-duty military from other branches of service
• $563,638 in tuition and fees received for students participating in the Army ROTC program
APSU logoAPSU has also extended its commitment to the Fort Campbell community by investing in a dedicated education facility on the installation. With twenty-five full-time faculty and sixteen support staff assigned to the Fort Campbell Center, students are offered six Associate degree programs, six Bachelor’s degree programs and five Master’s degree programs. All of the requirements for these degrees can be completely entirely at the Fort Campbell Center or online and are arranged in five, eight week terms to better accommodate military schedules. The Center also incorporates one-stop student services where students can access the admissions office, registrar, academic advising, financial aid/veterans affairs and a bookstore and, importantly, students at the Center are not required to pay fees that apply to main campus services or programs. Not only is APSU committed to preparing soldiers with an exceptional education, it is also committed to preparing students for an exceptional military career. The ROTC program is one of the best in the Nation as is confirmed by the following accomplishments:
• APSU is the only ROTC program in the nation to have met its commissioning mission every year since 1997.
• APSU’s ROTC program earned the MacArthur Award in 1997 & 2001 recognizing it as the best program in the Nation and again in 2008 recognizing it as the best program in the region (TN, KY, OH, IN & MI).
• APSU’s ROTC program was recognized as being in the top 15% of programs nationwide during 2004 & 2005.
• APSU cadets were ranked number 1 in the nation (2012 & 2013) for peer evaluations received during Cadet Summer Training.
• 77% of APSU cadets earned “Excellence” ratings during Cadet Summer Training this year (The national average is 27%).
• During Cadet Summer Training this year, two APSU cadets were ranked number 1 in their respective regiments (approximately 460 cadets per regiment). To add more perspective, nearly 6,000 cadets from 275 ROTC programs were divided into 13 regiments, so the two APSU cadets were in the top 13 cadets nation-wide.

In addition to APSU, within a 50 mile radius of Clarksville, there are other Tennessee colleges and universities, many of which offer specific programs for active duty military and their families and veterans. These include: Belmont University, Bethel University, Columbia State Community College, Daymar Institute, Fisk University, Lipscomb University, Middle Tennessee State University, Miller-Motte Technical College, Nashville State Community College, North Central Institute, Tennessee State University, Trevecca Nazarene University, Troy University and Vanderbilt University.

Page 4-176 Public Health and Safety

Comment: The Impact on Public Health and Safety will be significant.

A reduction in forces on the Fort Campbell installation will result in significant changes to the Clarksville-Montgomery County public services and, potentially, safety. According to an FBI report Clarksville is the safest of Tennessee’s medium and large cities in terms of its crime rate and the rate of crimes “cleared.” While there are several factors that must be counted in achieving this standard, two of the most important are a well-trained force and the number of officers per resident ratio. A significant reduction in force at Fort Campbell would impede these goals. The reduction in population of Clarksville-Montgomery County could be sufficient to require a decreased population to bear a greater burden in providing for basic services including water and sewer services, infrastructure improvements and in continuing to provide the personnel and resources needed for public safety officers.

The relationship between Fort Campbell and Clarksville-Montgomery County public safety departments goes much deeper than the number of residents and the resulting tax base. A significant number of officers, deputies, firefighters and EMS personnel are veterans and/or guardsmen.

For example, according to a survey of the Clarksville Police Department last year, of 268 sworn personnel who responded 46% had served in the military. Of the 64 civilian personnel who responded, 15% served in the military. It is estimated that those numbers have now increased.

In Clarksville-Montgomery County, there are 3 police stations, 328 police officers, 10 fire stations, 197 firefighters, 288 Sheriff’s deputies, 31 reserve deputies, 5 district fire stations, 1 fire sub-station, 1 rescue squad and 230 volunteer firefighters. Many of these public safety officers have military ties. All of them, and the listed resources, are available to assist members of the Fort Campbell community as needed.

Page 4-177 Family Support Services

Comment: The Impact on Family Support Services will be catastrophic.

In addition to the services outlined in the SPEA, page 4-177, lines 2-5, programs exist in the Clarksville-Montgomery County area that benefit the military families in the community. Those services and programs will likely continue, although the numbers of military families who seek to access them may increase as the availability of the services and programs decrease.

The Montgomery County Veterans Service Organization currently assists an average of 650 Veterans or their dependents every month. Currently, the average wait time for an appointment at the VSO is three weeks. If, under Alternative 1, 6,000 additional Veterans are added to the current caseload in addition to the 27,000 Veterans already in the Montgomery County area, the wait time for an initial appointment would be extended to seven weeks under the worst case scenario, five to six weeks at best. At first blush, this might not seem significant. However, the VSO’s mission is to help veterans navigate the U.S. Department of Veterans Affairs system in applying for a variety of benefits and entitlements such as Disability Compensation, Veterans Pension and Surviving Spouse Pension, Survivor Benefits, Burial Benefits, Healthcare, GI Bill and Education, Vocational Rehabilitation, Appeals, and Military Service and Discharge Records. According to the Tennessee Department of Veterans Affairs 2011-2012 Annual Report, the Montgomery County Veterans Service Organization had the fifth largest county veteran population in the State of Tennessee, serving approximately 22,000 veterans, as well as their family members. For fiscal year 2011-2012, $200, 814,882 in benefits were awarded to these veterans, placing Montgomery County well ahead of Davidson County (Nashville) at $103,422,236; Hamilton County (Chattanooga) at $70,345,855; Knox County (Knoxville) at $88,668,590 and Shelby County (Memphis) at $185,369,720. Since that time, the veteran population in Montgomery County has increased to approximately 27,000 men and women.

The chart below provides some perspective on the impact the VSO has on Tennessee Veterans:

jobsThe Montgomery County America Job Center hosts several programs dedicated to assisting Veterans and their spouses in finding employment after their separation from the military. Operation Stand Down Nashville, Inc. operates an office in the Clarksville Career Center and provides over 100 services to Veterans at no cost. These services include employment readiness training, employment placement assistance and coordination with other agencies that provide additional social services. Through Operation Stand Down, the Supportive Service for Veteran Families (SSVF) is the primary resource for veterans providing a wide array of life-changing social services. A Transitional Housing Program is also offered through Operation Stand Down. In 2013, 299 veterans found employment, 320 veterans and their families were assisted with filing disability claims and 74 men and women successfully completed the Transitional Housing Program through this volunteer based program alone. A force reduction would increase the demand on this, and other similar programs, to the extent that Veterans and their families will be left waiting for access to services and an eventual depletion of volunteer hours.

In addition to the volunteer programs, the Tennessee Department of Labor’s Career Center is dedicated to assisting Veterans in finding post-active duty employment. Veterans are given priority of service for all programs offered at the Career Centers across the State. In Clarksville-Montgomery County, the Career Center’s staff includes two Local Veterans Outreach Representatives and four Disabled Veterans Outreach Representatives for the Fort Campbell ROI. These specialists serve as liaisons between employers and employees in preparing troops for employment. Again, a reduction in troops will likely result in an increase in the services needed through this program especially with the simultaneous decrease in available jobs.

The residents of Clarksville-Montgomery County are unquestionably committed to providing our military family with the resources they need to succeed. This includes the volunteer and career services outlined above. It also includes the Veterans Treatment Court.

Oversight for the Veterans Treatment Court is provided by General Sessions Judge Ken Goble and provides needed treatment and services to Veterans and some active-duty soldiers who find themselves in the judicial system, usually because of drug addition, homelessness or other issues resulting from wartime service. Progress throughout the program, which may be a 60, 90 or 120 day program, is closely monitored by the Judge and a ten member team. The treatment programs are individualized but include regular drug tests, attendance at recovery support/self-help meetings, personal goal setting and, in some cases, maintaining full-time employment and/or meeting educational goals.

Page 4-17 Recreation Facilities

Comment: The Impact on Recreation Facilities will be significant.

The Clarksville-Montgomery County community offers a wealth of recreational facilities to all its residents. There are also programs specifically designed with Fort Campbell in mind.

The “Go Commando” running events and a paddle/canoe/kayak event are annual events that have been included in the Fort Campbell Eagle Fitness Challenge. The City of Clarksville also hosts several events during “Warrior Week” to encourage community between the soldiers and the citizens of Clarksville. These events include the “Tobacco Stick” softball game and a picnic.

In addition to the recreational facilities located on the installation, Clarksville-Montgomery County also hosts 2 libraries, 34 parks, 644 park acres, greenways and a blueway, 9 tennis courts, 7 golf courses, 5 swimming pools, 4 road races, 3 community centers, 2 movie theatres, 2 major festivals, 2 century rides, a marina with boat slips, a mall, a winery, nationally recognized Farmers’ Market, one of the best museums in the State of Tennessee and many other events and outdoor activities.

The City of Clarksville’s Parks & Recreation department and U.S. Paralympics, a division of the U.S. Olympic Committee, have partnered to create Paralympic Sport Clarksville. Paralympic Sport Clarksville is a community-based sports club developed to involve youth and adults, including active duty service members and veterans, with physical and visual disabilities in ongoing sports and physical activity, regardless of skill level. All programs and activities are based in Clarksville and run by Clarksville’s Parks & Recreation department. The athletics offered through this program include wheelchair basketball, archery, adaptive swim and, most recently, adaptive yoga. The Parks and Recreation Department staff continues to work with the Warrior Transition Unit at Fort Campbell to create additional programs that will assist soldiers who may need assistance in maintaining an active lifestyle.

Another organization, also provides opportunities for individuals age three and above with a mental and/or physical disability the opportunity to play sports, regardless of their abilities. Through this program, participants play basketball, baseball, bowling and cheerleading. This is just another example of the support the Clarksville-Montgomery County community offers to soldiers, veterans and their families.

In addition to these activities, within 50 miles of Clarksville, there are countless other “quality of life” opportunities including a zoo, a symphony hall, performing arts centers, a professional football team and a professional hockey team, historic music venues, shopping, music festivals and historic destination sites.

The adjacent Nashville MSA is home to some of the most dynamic offerings for residents of any comparable area in the nation. Widely recognized as an international center for creative activity through music and arts, the cultural and recreational offerings are nearly unrivalled. Over 11 million visitors come to Nashville –only 50 miles from Ft. Campbell- each year to participate in music experiences, festivals and venues. The proximity of amenities is abundant, affordable and accessible in the region as in few others.

The Smokey Mountains National Park is the most visited national park in the nation- only two and half hours from Ft. Campbell by car. The system of manmade lakes in the TVA system covers the entire area of Middle Tennessee and southern Kentucky with Ft. Campbell at the center. Young families and singles particularly seek out the kinds of outdoor experiences with year-round offerings that the Nashville and Clarksville regions provide. The moderate climate of the area year round further enhances the quality of life of the area.

4.6.12.2 Environmental Effects
Population and Economic Impacts

Comment: Alternative I will result in a significant adverse impact on employment and population in the Clarksville-Montgomery County area.

Additional Notes:

The SPEA assessment ignores Induced Population Losses.

Page 4-177 line 24 and Page 4-178 Table 4.6-6; a direct population loss of 40,288 persons [15,221 soldiers, 799 Army civilians, 8,928 spouses (16,000 X 0.558 spouse per employee) and 15,360 children (16,000 X 0.960 children/employee)] is projected for the Army Force reduction. However, this does not include the population loss due to the loss of direct contract services jobs and due to the induced job losses. Based on the 1,807 jobs loss from direct contract service loss and 1,798 induced jobs loss, the induced population loss would be an additional 8,651 persons [1,807 contract jobs, 1,798 induced jobs, 1,766 spouses (3,605 X 0.49 spouses per job) and 3,281 children (3,605 X 0.91 children per adult)]. The possible Fort Campbell Army force reduction in the four-county ROI is projected to raise the unemployment rate so that most “direct contract services” and “induced job loss” employees will likely leave the region to find employment. Thus, the direct and induced population loss is nearly 48,939 persons. Further, induced jobs losses in the construction industry, real estate industry and education services would add another 9,651 persons lost (for Montgomery County only) for a total of 58,590 persons leaving the ROI from direct and indirect employment impacts of the Army force reduction.

Migration patterns into the Clarksville MSA and adjacent Nashville MSA demonstrate the area’s longstanding reliance on net in-migration to sustain the appropriate levels of economic growth and stability that support the tax base of the region. A substantial portion of in-migration historically and currently relates directly to: 1) timely, successful integration of military into civilian occupations upon exit, 2) extended family migration to the area related to military population’s proven successful pattern of transition to civilian jobs, and 3) affordability and stability of regional housing costs tied to steady flow of in-migration with strong military-related component. Measurable changes in migration patterns that have remained strong and stable for many years likely could prompt devastating impacts on the combined Clarksville and Nashville MSA economies and job markets. Additionally, a very large share of total economic growth and stability for the state of Tennessee is predicated on the vitality of these two metropolitan areas. From 2000 to 2012 The Nashville MSA plus Montgomery County comprised 60.6% of the entire Tennessee net population growth and the equivalent of the entire state’s net employment gains when adjusted for rural job losses. The Tennessee economy has become increasingly reliant on the Nashville and Clarksville area for economic stability and success, both areas with strong dependence on military employment and engagement with the economy.

The SPEA assessment also underestimates Induced Job Losses:

Page 4-178, lines 18-22 and Tables 4.6-5 and 4.6-6, the EFIS model estimates a loss of 19,605 jobs including 16,000 Soldiers and Army civilians, 1,807 direct contract service jobs and 1,798 induced jobs (from the EFIS multiplier). While the methodology for determining significant income impacts is consistent among the 30 bases being evaluated, the methodology significantly underestimates the income impacts of the possible Army Force reduction because the EFIS model significantly underestimates induced job losses. Induced jobs losses in the Construction Industry, Real Estate Services and Educations Services are described below. The underestimate of the induced jobs losses of 4,021 jobs from construction, real estate and education yields a total job loss of 23,626 jobs. Thus, the significant adverse impact on employment and population also applies to income in Tables 4.6-5 and 4.6-6 increasing the forecasted income decline from -7.7% to -9.3%.

The SPEA assessment underestimates Local Government Revenues Losses:

Page 4-179, lines 1-9, the adverse impacts on local government revenues to support basic services is seriously underestimated because local and State income taxes and property taxes are ignored. In as much as Montgomery County represents 93% of the population in the Tennessee portion of the ROI and a major number of the base residents of Fort Campbell, the sales tax rate of 9.50% for Clarksville and Montgomery County is more appropriate than the average sales tax rate of 9.45% for all of Tennessee. The bottom line assertion is that “Sales” tax impacts are a poor measure of the overall impact of Army force reduction on local government revenues.
Housing

Comment: Alternative I will have a catastrophic impact on housing the Clarksville-Montgomery County area.

Additional Notes: The SPEA assessment underestimates Housing Impacts:

Page 4-179, lines 23-29, the possible Army force reduction is such that there is sufficient housing on base to accommodate all remaining Army soldiers and their family members. Thus, the direct population loss of 40,288 persons would result in 15,203 vacant dwelling units, using the 2010 average household size of 2.64 persons per unit. The 2010 Census reports a vacancy rate of 11.7% for Montgomery County up from 7.4% in the year 2000. While the housing unit vacant rate has declined since 2010, it has not yet achieved the historical healthy vacant rate of about 7.0%. Based on the ratio of Montgomery County to the ROI, at least 63% of the vacant units (9,578 units) will be in Montgomery County representing 51% of all types of housing units built over the past decade in Montgomery County. This increase in vacant housing units will cripple the housing industry resulting in a catastrophic reduction in the housing construction jobs and real estate jobs. Assuming only half of the Construction jobs (NIACS_23 of 4,333 jobs per 2012 InfoUSA) and half of the Real Estate jobs (NIACS_53 of 1,415 jobs per 2012 InfoUSA) are lost, there would be an addition induced job loss of 2,874 jobs and induced population loss of 6,897 persons (2,874 employees plus 2,874 X 0.49 spouses per job = 1,408 persons plus 2,874 X 0.91 children per job = 2,615). Recovery in the housing market would not even begin for a minimum of five years and would be more than a decade off.

Even more serious is the adverse impact on the assessed value of housing increasing the vacancy rate from 11.7% in 2010 to 22.6% with the Army force reduction. This an even greater impact on the value of the housing than the Great Recession which resulted in a typical reduction of 20% or more in housing value. This translates into an eventual more significant decline in property tax revenues for local and State governments. If the housing demand for the loss of direct contract employees (1,807 jobs), EIFS reported induced job losses (1,798), construction and real estate induced job losses (2,874 jobs) and education induced job losses (1,147 jobs) is included, there would another 6,933 vacant dwellings [(8,651+6,897+2,754 persons)/2.64 persons per dwelling) shooting the direct and induced vacant housing units to 16,511 dwellings, equaling 88% of the housing over the past decade. The implication of adding the housing vacancies associated with additional induced employment losses is that the housing market would not begin to recover for a decade.

Schools Impact

Comment: Alternative I will result in a significant adverse impact on the Clarksville-Montgomery County School System.

Additional Notes: The SPEA assessment underestimates Local School System Impacts:

Page 4-179, lines 30-37 and Page 4-180, lines 1-20, the Army force reduction would result in sufficient school capacity on base for all children of remaining soldiers and elimination of all military-connected students off base – 10,000 student. The PEA of January 2013 page 4.4-13 reports 8,310 military connected students or 27.2% of the Clarksville-Montgomery County School System (CMCSS) The CMCSS Annual reports for the 2012-2013 and 2013-14 school-years report 30,644 and 31,267 students, respectively with military-connected student enrollment at 27.3%. Thus, 8,366 to 8,536 students would be lost leading to a reduction of 1,147 jobs of the total 4,200 CMCSS employees (162 administrators, 2011 teachers and 2027 support staff). The decline in enrollment may lead to the possible closing of 2 of the 7 high schools, 2 of the 7 middle schools and 6 of the 23 elementary schools. Because of the annual addition of new schools to the system each year in recent years, Montgomery County has used revenue bonds to finance the upfront school construction. Thus, the community will be paying for schools that it no longer needs through revenue bonds for 15 years or more. Finally, as described below an underestimate of the induced job losses and population losses results in a 22% decline in the 2012 population in Montgomery County; thus, the income and sales losses are closer to 22% and the impacts on incomes and sales are both significant.

Public Services Impacts

Comment: Alternative I will result in a significant adverse impact on public services in the Clarksville-Montgomery County area.
Additional Notes:

The SPEA assessment underestimates Public Services Impacts:

Page 4-180, lines 22-29, the methodology ignores off-base impact on public services and facilities. Based on the Montgomery County portion of the ROI in year 2012 (i.e., 64.2%), the direct and induced population loss in Montgomery County is 41,070 persons (40,288 X 0.642 plus 8,651 X 0.642 plus 9,651) out of 185,201 persons in 2012. This reduction of 22.2% of the total population means user fees for already constructed sanitary sewers (Clarksville Water & Gas), waterlines (Clarksville Water & Gas) and electric lines (owned by the Clarksville Department of Electricity) will be spread among fewer customers raising users fees. The loss in population would likely result in reduction in the police force (Clarksville Police Department and Montgomery County Sheriff’s Department), the Clarksville Fire Department, permanent staff and volunteers of the Montgomery Voluntary Fire Department, and the Montgomery County Emergency Medical Services (EMS) including the associated capital cost of police office space, new fire stations in the City and County and new EMS stations. For the Clarksville Police Department, nearly 60 police officers may no longer be needed.

Family Support Services and Recreational Facilities Impacts

Comment: Alternative I will result in a significant adverse impact on Additional Notes:

The SPEA assessment underestimates Family-Support Services and Recreation Facilities Impacts:

Page 4-180, lines 31-35, again the methodology ignore off-base impact to family-support services and programs provided at public recreation facilities.

Environmental Justice and Protection of Children Impacts

Comment: Alternative I will result in a significant adverse impact Additional Notes:

The SPEA assessment provides misleading Environment Justice Conclusions:

Page 4-181, lines 2-15 and Tables 4.6-3 and 4.6-4, if any other federal environmental assessment were examining the impacts of an investment on employment, the impacts would not be limited to alternatives within one employment category but the entire economy. In Lines 9 and 10, a disproportionate adverse impact on minority populations in Christian and Montgomery County is recognized “if displaced Army soldiers and civilian employees move outside the ROI.” The SPEA has already established on Page 4-179, Lines 16-17 that the magnitude of the direct and indirect job reduction compared to the size of the ROI economy will result in relocation of the displaced employees out of the ROI. In Lines 12-15, how can you state that Christian and Stewart counties have a slightly higher population living below the poverty level, yet say the “impacts are not expected to be disproportional”? In conclusion, the Army force reduction has a disproportionate impact on minority and low-income populations in the ROI and no mitigation actions are proposed. At the very least, mitigation actions should be identified like any other environmental assessment that reports a disproportionate impact on minority and low-come populations.
4.6.16 Traffic and Transportation

The SPEA contains vague reporting of Traffic Impacts:

Page 4-183, Lines 29-32 and Page 4-184, Lines 3-5, the SPEA states: “The Regional Planning Commission had concluded that a likely increase in traffic levels would exceed the current threshold and warrant further analysis and growth master planning.” In fact, the “2040 Metropolitan Transportation Plan” (adopted February 20, 2014) reports an acceptable level-of-service (LOS D or better in Figure 4-9) on all access routes to Fort Campbell in the year 2040 with a 37% increase in population in Montgomery and Christian Counties from 246,286 persons in in the year 2010 to 337,231 persons in the year 2040 (per forecasts of the Kentucky and Tennessee State Data Centers).

ADDITIONAL SIGNIFICANT IMPACTS

14) Additional Significant Impacts: Page 4-185, Lines 23-24, add sales, population, local public services and environmental justice to the list of significant impacts. Thus, Page FNSI-13, Table FNSI-4 should be changed to “significant” in all categories for Fort Campbell.

15) Require Finding of Significant Impact: Page FNSI-14, Lines 22-25, while significant adverse socio-economic impact impacts do not in themselves warrant the preparation of an EIS per federal regulations, we would argue that significant adverse Environmental Justice impacts on the Fort Campbell Regional Of Influence argues for the identification of mitigation actions if not the preparation of an EIS.



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