Here we go again!

[Lenny Siegel <lsiegel@cpeo.org>]

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For nearly 15 years, I have been working to strengthen the Defense
Department's environmental programs. I have challenged the people who
run those programs when I think they're wrong. I have praised them when
they do the right thing. And I have fought to see that they have the
resources to accomplish their missions.

Unfortunately, the Defense Department's argument for the 2004 version of
the Readiness and Range Preserve Initiative confuses a difficult
environmental problem, the characterization and remediation of military
ranges, with a remote, theoretical threat to readiness.

In one of its fact sheets, the Defense Department explains its proposals
for restricting the Resource Conservation and Recovery Act (RCRA) and
the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), saying that the legislation would "Preclude the use of
RCRA and CERCLA to shut down munitions testing and training on
operational ranges."

This has never happened, and regulatory agencies have gone to great
lengths to ensure that environmental activities do not interfere with
readiness activities. In the closest example I can think of, the Eagle
River Flats range in Alaska, the Army conducted a successful CERCLA
cleanup with regulator oversight and also chose to time its subsequent
exercises to minimize the death of waterfowl from white phosphorous
ingestion - a problem identified by Army scientists. I saw that as a
success for the current regulatory framework, not as the harbinger of a
breakdown in military readiness.

I am offended by the innuendo contained in the Defense Department
argument, "The readiness of our Armed Forces depends on the continued
availability of realistic testing and training. We owe our men and women
in uniform nothing less." Environmental activists and regulators have
family and friends in today's combat zones, too. Many have served in
previous wars. Americans are dying in the Middle East, but it's not
because some environmental organization might someday file a lawsuit.

I've said it before, and I'll say it again. Munitions and their
constituents on active and inactive (AKA "operational") ranges pose a
threat to public health, public safety, and the environment. Figuring
out ways to address those risks reliably and cost-effectively will take
teamwork, among the military, regulators, and the public. Exempting the
armed services from mandates for the investigation and cleanup of toxic
contamination at its source, and which give regulators the authority to
insist on better site security, would be part of the problem, not the solution.

Lenny Siegel
--


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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