[CPEO-MEF] [CPEO-IRF] Ft. Ord (CA) letter]

[Lenny Siegel <lsiegel@cpeo.org>]

Submitted by Laura Olah <info@cswab.org>:

More than 50 organizations from across the U.S. have submitted formal
comments to the U.S. EPA in solidarity with communities near the closing
Fort Ord base in California.  The EPA’s proposed Order of Consent, which
transfers cleanup responsibilities from the Army to a local reuse
authority, carries no requirements for continued public participation
and meaningful involvement of community and tribal members.  The
precedent-setting proposal contradicts the Agency’s environmental and
economic justice mandates and could, by example, affect communities
everywhere that are at risk from military toxins in their environment.

The entire letter and co-signators follows:

Judith Winchell (SFD-7)
United States EPA Region IX
75 Hawthorne Street
San Francisco, CA  94105
winchell.judith@epa.gov

RE: Former Fort Ord Superfund Site – Docket No. R9-2007-03

January 26, 2007

Dear Ms. Winchell,

The proposed Administrative Order of Consent does not comply with EPA’s
Environmental Justice mandates and policies as it does not require and
assure a mechanism for continued public participation and meaningful
involvement of community and tribal members in the cleanup and
restoration of environmental contamination in and around the former Fort
Ord and, by example, all communities threatened by military toxins.

This serious omission is of immense concern as, to the best of our
knowledge, this is the first such order issued by the EPA and therefore
sets a national precedent for this and countless other communities
across the U.S. that are at risk from exposure to military toxins in
their environment – risks that are greatest to the developing fetus,
infants, and children as the population groups most vulnerable to
environmental pollutants.

By both EPA law and policy, the transfer of responsibilities from the
federal government to another party (in this case from the U.S. Army to
the Fort Ord Reuse Authority) must carry assurances and specific
mechanisms for compliance with environmental and economic justice.
Moreover, in communities where a RAB or SSAB have/may be established,
these mechanisms would be abruptly terminated as having no provision or
resources to continue.

As the local reuse authority, the Fort Ord Reuse Authority has routinely
blocked meaningful involvement of affected community members, including
specific racial and socio-economic groups, in the economic development
planning process.  In fact, no one from the affected community has a
seat at the table.  Moreover, the inherent economically-driven mission
of the FORA directly conflicts with the community’s right to a cleanup
that affords the greatest possible protection of human health and the
environment.

The EPA has both the authority and a duty to require fair treatment and
meaningful involvement by assuring that community and tribal
stakeholders are from all perspectives and are armed with the capacity
to participate in policy development as full partners that are afforded
necessary support and resources.

For these reasons, we urge the EPA to extend the public comment period,
to hold public meetings to actively solicit and incorporate comments
from affected community and tribal members, and to withdraw the proposed
Administrative Consent Order as it fails to require and assure a
mechanism for continued public participation and meaningful involvement
of community and tribal members.

Sincerely,

Levonne Stone, Executive Director, Fort Ord Environmental Justice Network

Laura Olah, Executive Director, Citizens for Safe Water Around Badger

Kaye Kiker, Organizer, Citizens Task Force, York, Alabama

Wilbur Slockish, Columbia River Economic and Education Development, Oregon

Dr. Herbert J Bernstein, President, Institute for Science and
Interdisciplinary Studies, Massachusetts

Betty Salamun, Artistic Director, DanceCircus, Ltd

J. Gilbert Sanchez, Director, Tribal Environmental Watch Alliance, New
Mexico

Guy Wolf, Co-Chair, La Crosse Coalition for Peace and Justice, Wisconsin

Elaine Cimino, Director, Citizens For Environmental Safeguards, New Mexico

Robert A. LoPinto, PE, Co-Chair, Ft. Totten Restoration Advisory Board,
New York State

Joseph DiGangi, PhD, Scientist, Environmental Health Fund

Melodie Dove, Lead Environmental Organizer, Concerned Citizens of South
Central Los Angeles

Will Fantle, Northern Thunder, Eau Claire

Dr. Warren Porter, Prof. of Zoology, Prof. of Environmental Toxicology,
Dept. of Zoology, University of Wisconsin, Madison

Paul Herr, Owner, Paul Herr Consulting

Lyndie Malan, Executive Director, Great Keppel Island Conservation Group

John E. Peck, Executive Director, Family Farm Defenders

Bonnie Urfer, John LaForge, Co-Directors, Nukewatch

Mike Schade, PVC Campaign Coordinator, Center for Health, Environment
and Justice

Denny Larson, Director, Global Community Monitor, California

Peter Montague, Ph.D., Director, Environmental Research Foundation

Vina Colley, Portsmouth/Piketon Residents for Environmental Safety and
Security (PRESS), Ohio

Bill Ahrens, President, Mining Coalition of Wisconsin

Rick Hind, Legislative Director, Greenpeace Toxics Campaign, Washington DC

Mary David Walgenbach OSB, Prioress, Benedictine Women of Madison, Wisconsin

Julie Enslow, Project Organizer, Peace Action Wisconsin

Rebecca Katers, Executive Director, Clean Water Action Council of NE
Wisconsin

Cynthia Stimmler, Office Manager, Women's Environmental Institute, Minnesota

Sandra Hausman, President, Glenview Prairie Preservation Project

Doris Bradshaw, President, Defense Depot Memphis Tennessee - Concerned
Citizens Committee

Doris Bradshaw, Chair, Tennessee Environmental Justice Network

Isis Bradshaw, President, Youth Terminating Pollution, Tennessee

Doris Bradshaw, President, Military Toxics Project

Chamomile Nusz, Executive Director, Citizens Energy Cooperative of Wisconsin

Greg Wingard, Executive Director, Waste Action Project

Al Gedicks, Executive Secretary, Wisconsin Resources Protection Council

Marcia Halligan, Kickapoo Peace Circle

Steven Adams, Viroqua Biodynamic Group, Wisconsin

Pamela Miller, Executive Director, Alaska Community Action on Toxics

Wanda Colón Cortés Caribbean Project for Justice and Peace / Proyecto
Caribeño de Justicia y Paz, Puerto Rico

Lynelle West Hatton, Director, Toxic and Explosive Substance
Accountability, Washington

Judy Miner, office coordinator, Wisconsin Network for Peace and Justice

David Wilmot, Co-Founder/Lead Analyst, Abington, Weymouth and Rockland
Environmental Studies (AWARES) of Massachusetts

Jill Johnston, Program Coordinator, Southwest Workers Union, Texas

Guadalupe Alvarado, President, Committee for Environmental Justice Action

Sandra Garcia, Organizer, Youth Leadership Organization

Judith Sullivan, SDS, Coordinator, Sisters of the Divine Savior Justice
and Peace Office

Craig Williams, Executive Director, Chemical Weapons Working Group

Sr. Dorothy C. Pagosa, Sisters of St. Joseph of the Third Order of St.
Francis Director for Social Justice (organization for identification
purposes only)

David Ciplet, U.S. Coordinator, Global Alliance for Incinerator
Alternatives (GAIA)

Irene Senn, Justice, Peace & Integrity of Creation Committee of the
Sisters of St. Francis of Assisi

Richard Moore, Executive Director, Southwest Network for Environmental
and Economic Justice

John Steines, member and co-founder, Friends of Starkweather Creek,
Madison, Wisconsin

Marie Zellar, Regional Director, Clean Water Action

Marc Rosenthal, Board of Directors, Madison Arcatao Sister City Project

Mary Pendergast, RSM Sisters of Mercy, Earth Committee Chairperson,
Northeast

 (56 co-signators)

--

LeVonne Stone, TAG Manager
Fort Ord Environmental Justice Nework
P.O. Box 36, 217 Reindollar, Marina, CA. 93933
Phone and fax: 831-582-0803
www.foejn.org

Laura Olah, Executive Director
Citizens for Safe Water Around Badger (CSWAB)
E12629 Weigand's Bay South, Merrimac, WI  53561
Phone: (608)643-3124
www.cswab.org

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