Sustainable Range Management Directive

[Pauline Simon <cpeo@cpeo.org>]

On August 17, 1999, the Department of Defense issued two significant new
internal Directives, 4715.11 and 4715.12. The first deals with the
management of Active and Inactive Ranges within the United States. The
second, built from the first, covers U.S. military ranges abroad. This
message describes 4715.11. I will summarize the differences in the
foreign-range Directive in a subsequent message.

While I am familiar with many of the issues addressed in these two
Directives, they are part of a much larger management framework within
the Department of Defense. I don't know precisely which of the policies
in the Directive are new, and which simply restate previous policies. In
general, the Directive seems to build on "best practices," sound Range
Management actions that are taken at some ranges but not all.

Right now I only have a hard copy of the Directives. Once we obtain a
Web address (URL) for these documents, CPEO will circulate it through
our listserver - the Military Environmental Forum.

Lenny Siegel


DoD Issues Directive 4715.11

The subject of Department of Defense Directive 4715.11 (August 17, 1999)
is "Environmental and Explosives Safety Management on Department of
Defense Active and Inactive Ranges Within the United States." An
"Inactive Range" is "a range that is not currently being used, but that
is still under military control and is considered by the military to be
a potential range area, and that has not been put to a new use
incompatible with range activities." 

The Directive does not apply to ranges on former military installations
or those undergoing closure. It also does not apply to "closed ranges,"
which are former ranges, on active military installations, NOT
considered by the military to be potential range areas, or which have
been put to new uses incompatible with range activities.

This distinction is significant, because under U.S. EPA's Military
Munitions Rule, hazardous waste laws do not normally apply to Active and
Inactive Ranges. Occasionally, such as at the Massachusetts Military
Reservation, regulators are able to control range activities under other
environmental laws, but the Directive basically governs environmental
management on ranges in the absence of external authority.

Directive 4715.11 was signed by Deputy Defense Secretary John Hamre, and
it assigns responsibilities to several organizations within the
Department of Defense (DoD), including the armed services. For example,
it directs the Under Secretary of Defense for Acquisition and
Technology, whose responsibilities include Environmental Security, to
designate an armed service as Executive Agent responsible for the
"coordination of Joint Service technology requirements for UXO
[unexploded ordnance]." It also directs the Under Secretary  to
"coordinate DoD Component efforts to assess the environmental impacts of
munitions use on DoD ranges." This does not appear to provide the level
of consolidated leadership recommended by the Defense Science Board in
its 1998 report on Unexploded Ordnance, but I don't really know whether
or not it simply confirms the status quo.

The Directive declares a twofold purpose. It "establishes policy and
assigns responsibilities" for

* "Sustainable use and management of DoD's active and inactive ranges
located within the United States"

* "The protection of DoD personnel and the public from explosives
hazards on DoD's active and inactive ranges located within the United
State."

The concept of "sustainability" may seem out of place on a range where
the normal activity is to bomb or shell the hell out of the place. Most
of us tend to use the term "sustainable" to describe more
environmentally friendly activities. Yet I believe the Defense
Department is using it properly. The military has to figure out ways to
train and test with high explosives in ways that they can continue using
the same property for that purpose, indefinitely, and so they can
prepare it for other uses should it no longer be needed as a range. This
Directive moves in that direction.

Among the specific requirements of the Directive:

* The armed services will establish and maintain inventories of active
and inactive ranges. I don't believe such complete inventories exist
now.

* They will "ensure that management plans ... include planning for
sustainable range use by December 31, 2001, and are reviewed or updated
at least every 5 years. This planning, at a minimum, will address:
long-term sustainable use; management procedures; record keeping;
standards, monitoring; public outreach and public participation
programs, if required; technology requirements to ensure sustainable
range management; integration with other installation planning
processes; and resources." 

* They will "establish procedures for range clearance operations."

* They will restrict access to ranges and provide safety training to
those authorized to enter ranges.

* They will maintain permanent records on 1) the  use of munitions,
including "an estimated dud rate, by type, quantity, location, and using
organization," 2) "all UXO clearance operations or explosives ordnance
disposal (EOD) incidents conducted on the range," and 3) "the
coordinates of all areas known or suspected of containing UXO."

* They will segregate the use of munitions containing submunitions
(cluster weapons) and depleted uranium (DU). DU target areas should be
licensed by the Nuclear Regulatory Commission, and when possible, should
be in containment fixtures.

* "To the extent practical," targets will not contain hazardous
substances.

* The armed services will conduct hazard assessments before any range
clearance operation.

* They will ensure that range residue and other materials to be
recycled, or otherwise removed from DoD control, not contain explosives.

* Range fires are prohibited as a method of UXO clearance, but
controlled burns may be used to control vegetation to permit clearance.

* Installations will notify the public, as well as their own personnel,
of "range operations that may present an explosive safety hazard off
range."

* The military will continue to participate in national public
involvement programs.

* The armed services must "ensure [that] range issues that affect or
have the potential to affect the surrounding communities ...are
addressed in appropriate local public participation forums." I know of
no such requirement for active ranges now. DoD's public participation
activities are focused either on cleanup or the completion of
environmental impact studies.

* They will establish educational programs on UXO hazards.

* "Before changing the use of a range area, [they must] conduct
appropriate range clearance operations...."

* Finally, they will respond when the release (or threat thereof) of
munitions constituents poses "an imminent and substantial threat to
human health or the environment." This is one area where I believe
regulatory agencies have the clear authority to require a response.


This document, in both its general theme of sustainability and many of
its specific requirements, appears to grow in substantial part from the
work of the National Dialogue on Military Munitions. This dialogue,
facilitated by the Keystone Center, first met for a scoping session the
week of President Clinton's second inauguration in 1997. The group
brings together military representatives, regulators, other agencies,
and public representatives, including CPEO. One of its work groups has
developed a consensus set of "Principles for Sustainable Range
Use/Management." When planned revisions are completed, CPEO plans to
circulate the current draft - as part of the group's minutes - for
feedback from public stakeholders.

Directive 4715.11 covers many - perhaps most - of the concerns raised by
the principles. Some which are not covered, such as the reporting of
toxic releases on ranges and access controls at former defense sites,
are being addressed through other vehicles. 

This issuance is this directive is a remarkable step forward by the
Department of Defense. I don't want to imply that no one within DoD has
been pursuing the same reforms. Again, many of the requirements listed
in the Directive are simply best practices. Still, it is to DoD's credit
that it has adopted with a number of policies - requested, not required
by outsiders - even before the report documenting those external
requests has been finalized.

-- 


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
http://www.cpeo.org


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