[CPEO-MEF] Sign-on letter to OMB on DoD's impending range rule

[mtptara@ime.net]

Please Post- Anyone wishing to sign-on to this letter should send their
name, organization (please state if only for identification purposes), base
(if active or RAB member), city and state to Tara Thornton at mtptara@ime.net
Thank you,
Tara Thornton
Military Toxics Project


May 15, 2000

Mr. Art Fraas
Office of Management and Budget
New Executive Office Building
Suite 10202
725 17th Street, NW
Washington, DC 20503

Dear Mr.Fraas,

We, the undersigned are writing to you today to express our concern over
the Department of Defense's draft final range rule currently under review
by the Office of Management and Budget.

We understand the extent of the problem of range cleanup and UXO 
remediation is daunting.  The military estimates there might be as many as
25 million acres of land on closed, transferred, and transferring ranges
contaminated with unexploded ordnance and chemical munitions. The estimated
cost to clean up these ranges is expected to exceed 15 billion dollars.

As costly as remediation may be, the human, cultural, and environmental
costs of letting munitions lie where they fell may be even more costly.
Impact ranges for artillery; bombs and conventional armed rockets are
located in every section of the country, as well as abroad. Not only are
they littered with potentially explosive devices, but also chemical
contamination from exploded and unexploded munitions is leaching into the
environment.

Studies conducted at training ranges suggest that explosive and propellant
contaminants migrate to groundwater.  In 1994, a study conducted at a
firing range at Fort Ord in California found that the impact areas were
contaminated with residues of high explosives, including HMX, RDX, and TNT. 

In 1997, the US EPA Region I ordered the military to cease training 
activities at the Massachusetts Military Range on Cape Cod, MA due to 
concern for drinking water contamination.  Recently, they invoked the Safe
Drinking Water Act to protect the health of persons and the environment;
and ordered the training ranges and impact areas to be cleaned up.

At the Lowry Range (Buckley Field) in Colorado, a formerly used defense
site, the Army Corps underestimated the extent of the hazard and only
undertook a comprehensive cleanup, using its most recent technology, when
pressured by state agencies.

In addition to environmental issues, we are also concerned about
biological, health and cultural impacts:

At the Army's Eagle River Flats artillery range in Alaska, there was an
unusually high mortality rate among waterfowl that feed and nest in this
area during spring and fall migrations.  After a year long study,
researchers at the Cold Regions Research and Engineering Laboratory (CRREL)
and Dartmouth Medical School determined the deaths were caused from the
ingestion of white phosphorus particles left from smoke-producing shells
fired into the range.

Many of the training ranges in Alaska and elsewhere have adversely
impacted the Native population.  The lands where many of the ranges are
located were traditionally used for hunting and fishing grounds. Now the
birds, fish and other wildlife that roam the ranges have high levels of
heavy metals and other contaminants.

There are high rates of cancer around munitions ranges like Camp Edwards
on Cape Cod, MA, Toole Army Depot in Utah, Sierra Army Depot in California,
and Vieques, Puerto Rico.  A 1992 epidemiological study of the community
surrounding Camp Edwards suggests a correlation with exposure to air-born
toxins from open burning of munitions and propellant bags to increased
cancer rates.

It's easy to see why we are so concerned with DoD's impending range rule.
Communities around the country and overseas will be greatly affected by the
final outcome of the range rule. OMB must require that any rule provide
stringent protection of public health and safety.

The Defense Department should not hold unilateral dispute resolution or
decision-making authority over any decisions on whether and how to clean up
UXO and related wastes. At Camp Bonneville in Washington and Fort Ord in
California, reuse is being delayed because the military has thus far been
unable or unwilling to clear the property to safe levels.

The range rule should be fully consistent with CERCLA and the National 
Contingency Plan and should include provisions for public participation.
In 1999, the US Army disbanded the Fort Ord Restoration Advisory Board and
has essentially squelched public participation.  As recent as May 12, 2000,
McClellan Air Force Base officials ousted every member of a community
advisory board that scrutinized the cleanup of the heavily contaminated
military installation.  Many see this as the military limiting access to
public participation, to only those views, which are friendly to the 
military.

The risk methodology, being developed in support of the range rule, should
be simple enough for public stakeholders to understand and use.

Finally, any portions of the range rule that has undergone significant 
changes since the closing of the initial public comment period in December
1997 should be made publicly available for comment prior to promulgation.

We look forward to hearing OMB's position on the above concerns.


Sincerely,

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