Controls

[Lenny Siegel <lsiegel@cpeo.org>]

Here is Steven Pollack's reply to the comment from inside DOD:

Subject:
 More on Institutional Controls
 Date:
 Mon, 13 Jul 1998 20:59:28 -0500
 From:
 Steven Pollack <themissinglink@eznetinc.com>
 Reply-To:
 steve@familyjeweler.com
Organization:
 The Missing Link

A reply from someone inside the Department of Defense:

"Have been reading with interest the flurry of e-mails on institutional
controls. Certainly feel the emotion transmitted. In a perfect world
(with unlimited money), there would be no need for controls of any type
---but we are not there."

Agreed. There will be instances where institutional controls are
warranted
but not in areas where clearance would free up land for productive use.

"A cost-benefit analysis is not the perfect approach but there must be
consideration of a number of factors before we opt for either
unrestrained
cleanup or institutional controls. If the land is government, then the
cost of cleanup is ultimately born by the taxpayer whereas commercially
owned property/facilities will ultimately be cleaned up using the
consumer
price increases not by reducing profit margins."

The difference between a Federal Facility cleanup and a private industry
cleanup is that the corporation has no say in the amount of cleanup
costs.
The EPA tells them what cleanup standards are to be obtained and the
costs
follow. The government, by contrast, budgets in advance for cleanup
costs
on a national level and then alters the remediations to fit the budget.
If
the citizenry is calling for higher cleanup standards of Federal
Facilities, who is the government to argue budget? It is as if the
government was a separate entity from the tax paying citizen. It is a
thin
line between higher consumer prices due to environmental regulations and
higher direct taxes because of Federal Facility cleanups. Cleanup
standards are public policy issues, not the sole domain of the
regulatory
and scientific communities.

"Current/future land use, risk (now and in future), cost to cleanup vice
cost of land, etc. need to enter the equation. Why would you pay
$20,000
to clear an acre of land worth only $500 if the risk is or can be
contained? This is a great area for public dialogue."

$500/acre implies farmland but the principle is noted. Acres of land in
a
residential use scenario can range from $15,000 to $500,000. Because of
inflation, a $40,000 home bought by my father-in-law thirty years ago is
now worth $240,000 so this future value must be accounted for. If the
restricted land is within a residential community, loss of value to
adjacent properties should be accounted for due to proximity to a
contaminated property. Loss of productive industrial use and property
tax
losses should also be quantified. Absolute containment of toxins is
also
questionable. RDX, TNT, HMX, Tetryl, and all the breakdown compounds
can
and do migrate offsite. What amazed me as regards the cost/benefit
analysis in the Feasibility Study for Fort Sheridan is the lack of
economic
imputation for the increased human and environmental hazards of the
capping
option. Great effort was taken to assess the cash costs of various
remediations but no specific dollar figure was assigned the loss of life
implied by Hazard Index and Cancer Risk values. It really turns into a
subjective analysis without it.

Finally, why is the Army's judgement between remediation options given
more
weight than the stakeholders? Why is the polluter and financially
responsible party the lead agency in analysis of options while those who
will live with the contamination are only given an advisory role? Is
this
an area of dialogue which the Department of Defense will engage in?

Steven Pollack
concerned citizen
Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org