[CPEO-IRF] Cleanup to current use

[Lenny Siegel <lsiegel@cpeo.org>]

Buried in the Pentagon's BRAC 2005 report, in a brief section describing
the Defense Department's environmental responsibilities, the authors
made a word choice that I hope is a mistake, but I fear is a hint of
future policy. The text discusses the objective, "the remediation to
current use standards may be completed after transfer." This seems to
imply that the military will take responsibility for cleaning up
contamination only to support continuation of currents uses on a parcel
of property. For example, if the military has used an area for
industrial activity, it seems to be saying that it will only clean it up
to standards based upon industrial land use scenarios. Current
government policy is to clean property to its "reasonably anticipated
future land use," so if the local community were to designate the
property for residential use, then the military would be responsible for
ensuring that there is sufficient remediation to support such a use.

The following text, from which the above quote was taken, may be found
by going to http://www.defenselink.mil/brac/vol_I_parts_1_and_2.html and
downloading Chapter 4 as a PDF file.. It's on page 30 of the overall document.

***

Realigning and Closing Bases: Environmental Responsibilities 

The Department intends to transfer BRAC property expeditiously for
reuse. However, the Department will comply with the National
Environmental Policy Act (NEPA), which requires all Federal agencies to
identify and consider possible environmental impacts of proposed reuse
activities before transferring any real property. This analysis will
also include the potential impacts on historical and cultural resources.
While NEPA does not apply to the BRAC decisions themselves, the Act does
require an environmental analysis for each installation receiving
additional functions. Any mitigation that may be required will be
identified and considered for implementation. 

The Military Departments are responsible for environmental remediation
of closing installations. Early in the implementation process, the
Military Departments will assess and document the environmental
condition of all transferable property in terms of the extent of
contamination and the current phase of any remedial or corrective
action. 

If no remedial action on the installation is required, surplus real
estate may be transferred. If remediation is required, the Military
Department may complete the work before the transfer, or alternatively,
with agreement from the affected community, the remediation to current
use standards may be completed after transfer. Some property transfer
negotiations have the new owner managing cleanup as a part of the
redevelopment process. With regulatory concurrence, remediation and
redevelopment activities may be integrated, potentially saving time and
money. An ideal candidate for this type of transfer is property that has
manageable environmental contamination, is readily marketable, and has
community and regulator support.

-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org
_______________________________________________
Installation_Reuse_Forum mailing list
Installation_Reuse_Forum@list.cpeo.org
http://www.cpeo.org/mailman/listinfo/installation_reuse_forum