[CPEO-MEF] ACSIM's proposed study and the Army Audit Report on MMR

[joelf@cape.com]

This is a comment on Peter Schlesinger's notice (CPEO 11/11/02) 
concerning the Regional Range Study to be conducted under the Army's 
Assistant Chief of Staff for Installation Management (ACSIM) Major 
General R. L. Van Antwerp.
(See http://www.hqda.army.mil/acsimweb/hottopic133.shtml ).

The Regional Range Study description begins:

"Training operations at the Massachusetts Military Reservation (MMR) have
been severely restricted by environmental regulatory actions. Other ranges
have also been impacted. The Army currently has insufficient scientifically
defendable information on the actual impacts of artillery and other live
fire on the environment."

Oddly, this statement mentions "regulatory actions" but fails to note 
that under these actions a five year study has been conducted by the 
Massachusetts Army National Guard of the Impact Area and surrounding 
land at the MMR. This study, performed by the AMEC Corporation, has 
cost approximately $100 million, and has been continuously peer 
reviewed by staff and consultants of EPA Region 1 and the 
Massachusetts Department of Environmental Protection.  Additionally, 
groundwater flow data has been supplied by the U.S. Geological Study.

Therefore, the Army does have access to the highest quality 
"scientifically defendable information on the actual impacts of 
artillery and other live fire on the environment." General Van 
Antwerp may contact the Army Guard's Project Manager, Ben Gregson 
<ben.gregson@ma.ngb.army.mil> for details. The short version is this: 
RDX and other explosive compounds have migrated from the soil in the 
impact area into the aquifer, contaminating billions of gallons of 
potential drinking water. Perchlorate from "other live fire" has 
produced pollution over a much wider area and has recently caused 
valuable production wells in the Town of Bourne to be shut down.

Having ignored existing information, the study description concludes:

"The information developed in these studies will provide the
basis for making the arguments to counter regulators/activists and public
claims about the impact of Army ranges on the environment. This, in turn,
will help to ensure the ranges remain available for use ..."

Evidently, the results of the proposed study are known in advance and 
support arguments that "counter regulators/activists and public 
claims." Is this what ACSIM Van Antwerp means by "scientifically 
dependable information"?

Cape Cod citizens have recently received an article in Defense 
Environmental Alert (Oct. 8, 2002) about a Sept. 23, 2002 Army Audit 
Agency Report on National Guard handling of the impact area 
groundwater study at the MMR.  The article states: "The auditors say 
EPA has too much control over the work at the high-profile site, and 
call on the Army to step in to exert greater influence over the 
program at Camp Edwards, the only military site where EPA has halted 
live -fire training."

The Army audit recommends replacing the Army Guard with the 
Department of the Army as lead agent with the "ACSIM assuming 
management responsibility for the program and oversight 
responsibility for cleanup issues at MMR."

The strange language of the proposed Regional Study cited above would 
be sufficent reason for Cape Cod citizens to fear the giving the 
ACSIM such power in the MMR cleanup. However, this is not the first 
time that ASCIM, Major General Van Antwerp has paid special attention 
to MMR issues.

On March 20, 2001, Major General R. L. Van Antwerp told the Senate 
Armed Services Committee hearing on "encroachment":

"MMR has afforded the Army a unique opportunity to analyze our past
practices and to understand what needs to be done differently in the future.
In order to maintain effective sustainable military operations and training, we
must have community acceptance and support for military activities, including
those military activities that affect public health and the environment."

The General testified that the Pentagon's strategy for bringing this 
about rested on two concepts which he defined as  "information 
dominance" and "outrage management."






--
Joel Feigenbaum
24 Pond View Drive
E. Sandwich MA 02537
(508)-833-0144

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