Re: [CPEO-MEF] [Fwd: [CPEO-IRF] Defense Department environmentaltestimony]

[Lenny Siegel <lsiegel@cpeo.org>]

I want to clear up a potential misunderstanding of my message about the
maturity of the Defense cleanup program. I am not challenging the
competence of the program. It's not perfect, but overall the program -
along with its state and federal regulators - is proceeding as well as
similar programs at private sites..

Rather, I'm suggesting that the cost of cleanup will increase
significantly after the BRAC '05 bases close, because new problems will
be discovered. Furthermore, with a steady stream of emerging
contaminants and pathways, many large cleanup sites - private as well as
federal - face significant unanticipated costs.

Opponents of specific closures, and perhaps the BRAC commission itself,
are using this concern to argue that closing major bases would be too
costly. In the long run, that's not true.

Rather, I'm concerned that the Defense Department will lowball its
cleanup estimates to avoid sticker shock. Congress will appropriate
insufficient funds, and cleanup program managers will be forced to seek
acceptance for inadequate remedies because the money in the pipeline
doesn't match requirements.


Lenny

Lenny Siegel wrote:
> 
> {I just sent this out to CPEO's Installation Reuse Forum, but I'm
> sending it to this list too because it deals also with the cleanup of
> active bases. - LS]
> 
> Lenny Siegel wrote:
> >
> > The Defense Department says that its cleanup program is mature, and that
> > costs have been identified. It also says that most remedies are in
> > place. DON'T BELIEVE EITHER CLAIM.
> >
> > 1. Maturity
> >
> > The Defense cleanup program is as mature as my 18-year old son, who
> > actually grew up with the military's cleanup program. (Some readers may
> > remember him from meetings of the Federal Facilities Environmental
> > Restoration Dialogue Committee in the mid-1990s.)
> >
> > That is, the program for cleaning toxic and radioactive wastes is
> > full-grown, but it still maturing in other ways. Most important, it is
> > full of surprises. For example, the former Moffett Naval Air Station
> > (CA), in my community, was closed as part of BRAC '91. The Navy's
> > cleanup program at Moffett is generally well regarded. Yet two of the
> > biggest cleanup challenges (volatile organic compounds in the shallow
> > groundwater beneath a military housing area now owned by the Army, and
> > PCBs and other contaminants built into the huge dirigible Hangar) were
> > only identified within the past few years.
> >
> > The only way that such new discoveries will not boost the cleanup
> > expense will be if the Defense Department refuses to pay for the cleanup
> > - as the Air Force is doing at the former Lowry Air Force Base (CO) and
> > the Navy is trying to do at the Moffett Military Housing Area. As BRAC
> > '05 bases open up and communities develop reuse plans, one can expect
> > major new cleanup challenges on those as well.
> >
> > The Military Munitions Response Program, on the other hand, is in its
> > infancy. It will take the armed services some time to finish identifying
> > closed ranges on active bases. And as bases with operational (active and
> > inactive) ranges close, those ranges will have to be added to cleanup
> > calculations. Remember, the military does not spend munitions response
> > dollars on operational ranges. Of course, if the armed services simply
> > refuse to make those ranges safe - as the Army has done at the Jefferson
> > Proving Ground - then the cost of "cleanup" will be much lower.
> >
> > 2. Remedies in place.
> >
> > When it reports that a large share of sites (portions of bases) have
> > response complete, the Defense Department usually counts those sites
> > which required no further action after initial identification or
> > investigation. It's inaccurate to describe those as having "remedies in
> > place." A relatively small fraction of sites requiring cleanup actually
> > have remedies in place. This is true in general at Defense Department
> > facilities, and spot-checking some of the major bases currently on the
> > BRAC '05 list shows very few remedies in place.
> >
> > Lenny Siegel
> >
> > Lenny Siegel wrote:
> > >
> > > Most BRAC '05 Environmental Restoration Remedies in Place
> > >
> > > By Gerry J. Gilmore
> > > American Forces Press Service
> > > August 11, 2005
> > >
> > > WASHINGTON ? The Defense Department has identified and provided remedies
> > > for environmental restoration issues associated with most of the
> > > installations on the 2005 Base Realignment and Closure list, a senior
> > > DoD official told the BRAC commission today.
> > >
> > > "From a base-reuse perspective the department will enter implementation
> > > of BRAC '05 with a mature restoration program," Philip W. Grone, deputy
> > > undersecretary of defense for installations and environment, told BRAC
> > > committee members at a hearing here.
> > >
> > > Among the installations recommended for closure under this BRAC round
> > > "84 percent of those sites, over 1,000, have remedies in place" that
> > > address environmental restoration issues, Grone said.
> > >
> > > And at installations possessing information on environmental conditions,
> > > "restoration projects are already identified and in various stages of
> > > completion," Grone said, noting that "required funding and goals have
> > > already been established to achieve required environmental actions."
> > >
> > > DoD "has mature relationships" with federal and state regulators and
> > > local communities involved with the 2005 BRAC process, Grone pointed
> > > out.
> > >
> > > "In each of the states where DoD has recommended an installation
> > > closure, the department has signed agreements to engage and financially
> > > support state agencies to assist us in restoration efforts," he said.
> > >
> > > Half of the 180 major and minor installations recommended for closure
> > > under BRAC 2005 contain environmental restoration sites, Grone reported.
> > > Those 90 installations contain more than 1,200 individual restoration
> > > sites, he said, with 6 percent involving military munitions clean-up
> > > sites.
> > >
> > > If implemented, the department's 2005 BRAC recommendations would close
> > > just over 10 percent of today's existing military bases, Grone had said
> > > June 6 at a community redevelopment association meeting in Denver. The
> > > 2005 BRAC recommendations propose closing 33 major stateside bases, as
> > > well as 29 major realignments and 775 minor closures and realignments.
> > >
> > > There are 843 environmental restoration sites among the 33 bases
> > > recommended for closure, Grone reported, noting that 78 percent of those
> > > sites "report either response complete or remedy in place."
> > >
> > > The certified estimate for the cost to clean up all the installations
> > > recommended for closure "was approximately $1 billion," Grone noted.
> > > That figure is based on fiscal 2003 data as reported to the BRAC
> > > commission, he said.
> > >
> > > "This figure includes both the cost for traditional clean up as well as
> > > for the military munitions response program," Grone said.
> > >
> > > In this BRAC round DoD wants to quickly transfer BRAC-affiliated
> > > property "by using the full range" of tools available in the public and
> > > private sectors," Grone said.
> > >
> > > DoD is applying knowledge gained from previous BRAC rounds to conduct
> > > more rigorous processes for transferring property within the federal
> > > government, Grone noted. The department will also employ a wider variety
> > > of property disposal methods, integrate environmental clean up and
> > > redevelopment more closely, and share full information on the condition
> > > of property early in the process with all interested parties, he said.
> > >
> > > Grone noted that DoD's environmental strategy for BRAC 2005 consists of
> > > four main elements:
> > >
> > >                  Streamlining the process consistent with existing laws
> > > and regulations;
> > >                  Making the process more market-oriented by using the
> > > full range of tools available for property transfer;
> > >                  Leveraging existing environmental assessments available
> > > for each installation to provide critical environmental information
> > > early to all parties for planning purposes; and
> > >                  Involving DoD components and all interested parties in
> > > early planning.
> > >
> > > "The department will use early transfer authority to the maximum extent
> > > practicable," Grone pointed out, to return property "to productive use
> > > as quickly as possible."
> > >
> > > Early transfer of formerly DoD-owned properties allows "reuse to occur
> > > in advance of the environmental cleanup being completed," Grone
> > > explained. However, such transfers "do not eliminate the department's
> > > responsibility to ensure that all necessary response action will be
> > > taken," he emphasized.
> > >
> > > "And it is a responsibility we take very seriously," Grone concluded.
> > >
> > > ...
> > >
> > > For the entire article, see
> > > http://www.defenselink.mil/news/Aug2005/20050811_2394.html
> > >
> > > --
> > >
> > > 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
> > > _______________________________________________
> > > Installation_Reuse_Forum mailing list
> > > Installation_Reuse_Forum@list.cpeo.org
> > > http://www.cpeo.org/mailman/listinfo/installation_reuse_forum
> >
> > --
> >
> > 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
> > _______________________________________________
> > Installation_Reuse_Forum mailing list
> > Installation_Reuse_Forum@list.cpeo.org
> > http://www.cpeo.org/mailman/listinfo/installation_reuse_forum
> 
> --
> 
> 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
> _______________________________________________
> Military mailing list
> Military@list.cpeo.org
> http://www.cpeo.org/mailman/listinfo/military

-- 


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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