[CPEO-MEF] The Lessons of MMR

[Lenny Siegel <lsiegel@cpeo.org>]

In April, 2001, Lt. Col. William F. Fitzpatrick of the Massachusetts
Army National Guard wrote a report, "The Lessons of Massachusetts
Military Reservation," for the Army Environmental Policy Institute
(AEPI-IFP-1001B). This 50-page study may be downloaded as a 240K PDF
file from
http://www.aepi.army.mil/Publications/The%20Lessons%20of%20Mass%20Mil%20Reservation.pdf
If that doesn't work, go to
http://www.aepi.army.mil/ and click on #17 under Past Publications.
I have pasted Fitzpatricks's summary and conclusions below.

This report is thoughtful and unusually self-critical. Fitzpatrick
criticizes the "public affairs" approach that the Army Guard first took.
And he questions the lack of coordination between the Air Guard - which
runs the Otis Air Reserve Base - and the Army Guard, which manages Camp Edwards.

He doesn't point it out, but despite the Army's weak performance, EPA
would never have ordered an end to training using high explosives if
explosive contaminants hadn't entered the soul source aquifer. That is,
to prompt severe regulatory action there needs to be both problems of
substance and of procedure.

Please remember that a lot has happened at Camp Edwards since
Fitzpatrick wrote the report. I believe the Donovan blast chamber was
brought in - to dispose of unexploded ordnance - later, and no one had
identified perchlorate in the groundwater yet.

Lenny


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"The Lessons of Massachusetts Military Reservation"
8. SUMMARY AND CONCLUSION

Massachusetts Military Reservation is an established military training
facility where past military practices contaminated a sole-source
aquifer. Like most Army installations, MMR has supported military
operations for over ninety years. Inherent in such longevity is the
potential to cause some type of contamination over time. MMR is an
example of just one installation with not only an extensive military
heritage but also a legacy of contamination.

The Army Environmental Strategy developed in 1992 provides a framework
for the Army to become an effective environmental steward. Common themes
throughout the strategy are coordination on and resolution of
environmental issues, a holistic approach to site assessment, and
minimization of risks to the environment. Environmental site assessments
are important tools that enable Army leaders to become effective
environmental stewards in their management of installation resources.
Effective environmental stewardship is not incompatible with maintaining
military training areas and ensuring combat readiness.

Environmental stewardship should be approached as one would approach
combat operations: analyze the present situation, consider historical
activities, and remain flexible for the unexpected. Because this was not
the approach taken at MMR, the Army Guard environmental stewardship
program was incomplete and uncoordinated.

Over the twelve years during which the Massachusetts Army Guard was
preparing its Master Plan, the Massachusetts Air Guard and NGB-Air were
dealing with stakeholders on the issue of groundwater contamination. The
Army Guard did not consider prior activities relevant or current
training as posing environmental problems nor was it flexible enough to
interact with the Air Guard, the regulators, or the environmental
activists. The Army Guard failed to correctly analyze the situation,
consider historical activities, and remain flexible. The 1996 EIR with a
finding of "no significant impact to the environment" never had a chance
of being approved. The ultimate result was a series of EPA Region 1
Administrative Orders that indefinitely suspended high explosive
training at MMR.

A review of the lessons of MMR suggests the following recommendations
for Army installations implementing environmental stewardship programs: 

* Read and apply the 1992 U.S. Army Environmental Strategy into the 21st
Century 

* Ensure that there is one leadership team for each installation 

* Understand that the environment includes public health issues 

* Review past practices, especially with respect to changing
environmental laws 

* Engage the public openly, honestly, and aggressively 

* Identify each stockholder's agenda, for every situation

Incorporation of these recommendations will not reverse the
contamination, eliminate lasting environmental effects, or necessarily
satisfy a concerned public. It will, however, improve trust and
understanding between Army installations and local communities. The
critical decisions required for contamination remediation will have a
more likely chance of acceptance. Had these recommendations been
implemented during the 1996 Master Plan process, Region 1 may still have
issued Administrative Orders, but all sides would have had a clearer
understanding of the others' agendas.

The Army has an excellent environmental awareness and stewardship
strategy and mature programs to integrate that strategy into military
operations. As the Army redefines installation management in terms that
incorporate ecosystem management, both environmental and public health
systems will be protected.

The Army and the community together form one ecosystem. As a partner in
this ecosystem, the Army faces the challenge of acknowledging community
needs while achieving the objectives of the NMS. This is critical,
because the ecosystem partners need to jointly assess the risks
associated with protection. Stewardship of the environment ensures that
we will always have a safe place to live; stewardship of the country
ensures our way of life. The Army has responsibilities in both areas.

An objective of the NMS is to "prepare now for an uncertain future." To
be able to prepare we must have the lands required for training. As the
Army works with the stakeholders, public health and the environment
should not be neglected, nor should the preparedness of the Army be
compromised. This is a risk-based dilemma that can be resolved only when
all stakeholders have an open and honest exchange of information.

Another objective of the NMS is to "respond to the full spectrum of
crises." As soldiers we swore to "protect against all enemies foreign
and domestic." The values that inspire us to be successful and win are
the same values that inspire environmental activists. In fact, these
common values are rooted in the foundation of our country, the
Constitution. The Army does not exist in a vacuum; furthermore, soldiers
often come from the neighboring communities. Wherever and whatever
crises arise, our common values should shape our response. Stakeholders
may have different methods, but when faced with a serious threat, the
core motivation to resolve the problem is the same.

History has taught us how to be leaders. History has also shown us the
errors of our ignorance. The events that have taken place at MMR
exemplify our past ignorance. They also exemplify our willingness to
rectify the effects of that ignorance. The 1992 Environmental Strategy
demonstrates the Army's awareness of environmental stewardship and
commitment to it.

Only the future's recounting of the present will show whether the
environmental lessons of MMR and other installations were learned and
implemented. It is hoped that the history of the years to come will
demonstrate the Army's environmental ethic in responsibly safeguarding
neighboring communities without compromising execution of the National
Military Strategy. 

-- 


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

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