TOKYO — The U.S. Environmental Protection Agency says the Pentagon’s massive buildup plans for Guam “should not proceed as proposed” and has offered its harshest internal rating, a move that could force the military to rewrite its plans for the island.

The sharp criticism came in a six-page letter and 95-page analysis from the EPA on the military’s environmental impact statement, which outlines expansion plans and includes the controversial move of 8,600 Marines from Okinawa to Guam.

The EPA documents, dated Feb. 17, say the permanent military expansion and temporary addition of nearly 80,000 people during construction would “exacerbate existing substandard environmental conditions on Guam,” including public health, the island’s sole aquifer, sewage systems, air quality, trash collection, coral reefs and other marine life.

“The impacts are of sufficient magnitude that EPA believes the action should not proceed as proposed and improved analyses are necessary to ensure the information in the EIS is adequate to fully inform decision-makers,” Jared Blumenfeld, the EPA’s administrator for Region 9 in San Francisco, wrote in a letter to Robert Natsuhara, the Navy’s acting assistant secretary for installations and environment.

By officially calling the military’s plans “inadequate,” the EPA could force the military to revise its entire environmental assessment of Guam, according to documents, which are available at

A ruling of inadequate, according to EPA policy, means the military must rewrite its impact statement, submit a new draft and hold an additional public comment period on expansion. The plans include the proposed Marines’ move, hosting an aircraft carrier berth for two months of every year, and adding an Army air defense unit with anti-ballistic missiles.

It was an unusually harsh ruling from the EPA, according to Mike Gawel, who retired from the Guam Environmental Protection Agency four months ago. As an environmental engineer planner, he was involved with impact statements for more than 30 years.

The EPA comments on all impact statements, which are required of federal projects that might pose harm to the environment. But the military’s statement, with its combination of a rapid construction schedule on a 212-square-mile island with aging infrastructure, tackled too much at once, Gawel said in a phone interview Thursday afternoon.

“This is just unheard of,” he said of the thousands of pages submitted last November by the military. “I am very concerned about this.”

The military, too, acknowledges that the scope of the project is extraordinary, calling it one of the most complex impact statements the Department of Defense has ever prepared, according to Marine Corps Maj. Neil Ruggiero, a spokesman for the Joint Guam Program Office.

“Although we have worked closely with EPA and other federal and local agencies during the development of the draft EIS, we fully anticipated that formal agency comments would point out deficiencies and areas requiring revision,” Ruggiero said in a prepared statement.

“The Department of Defense is seriously evaluating all comments received on the draft EIS and is determining how best to address these issues in the final EIS,” he wrote.

That final document is expected this summer.

In its analysis, the EPA did not condemn the idea of a larger military presence on Guam, nor did it issue an opinion on whether Guam could support the influx of troops, equipment, traffic and flushing toilets. Rather, the analysis questioned whether the military had thoroughly studied the potential effects of its plans and offered adequate and long-lasting solutions for the island.

The EPA did sweep aside some of the military’s mitigation proposals, including the offer to build an artificial reef to replace coral in Apra Harbor and the plan to rely on construction companies to supply imported workers with medical, housing, electrical, water and sewage needs.

The EPA’s comments join an escalating chorus of concerns from local, congressional and Japanese officials about the buildup.

In recent months, U.S. and Japan leaders have hit a stalemate over relocating the 8,600 Marines from Okinawa to Guam. In recent weeks, the island’s legislators and governor — many of whom initially embraced the military’s plans — have offered stronger words for military and other federal leaders about the feasibility of housing those Marines and their families by 2014.

Earlier this month, the island’s lone delegate to Congress, Madeleine Bordallo, said she would not support funding for that construction schedule.

On Thursday, some of those same leaders praised the EPA’s comments.

“The Department of Defense must address the overall infrastructure requirements on Guam and how to fund those requirements including waste water and clean water concerns associated with the induced population growth,” Bordallo said in a written statement. “The EPA raised serious concerns with the DoD’s assessment method of coral reef impact and stated that the DoD underestimates coral reef impact on Guam.”

“This document further solidifies our position that these concerns must be addressed to ensure the buildup is beneficial for Guahan,” said acting Gov. Michael Cruz in a statement, using the native Chamorro word for Guam.

More vocal critics found relief — and vindication — in the EPA’s comments.

“I thought it was great,” said Guam Sen. B.J. Cruz, the legislature’s vice speaker, who has been a vocal opponent of the buildup. “It contains everything I was complaining about. I’m hoping the EPA holds their feet to the fire and insists on a redraft.”

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