2006 CPEO Installation Reuse Forum Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: 26 Jun 2006 03:40:17 -0000
Reply: cpeo-irf
Subject: [CPEO-IRF] Camp Bonneville letter
 
The following letter to Washington governor Christine Gregoire as submitted by its author, Lynelle West Hatton <lynellehatton@comcast.net>.



TOXIC AND EXPLOSIVE SUBSTANCE ACCOUNTABILITY

June 22, 2006

URGENT: FOR PERSONAL REVIEW BY GOVERNOR GREGOIRE

Governor Chris Gregoire
Office of the Governor
PO Box 40002
Olympia, WA 98504-0002

RE: Camp Bonneville FOSET

Dear Governor Gregoire:

I am writing as Director of Toxic and Explosive Substance Accountability (TESA), a Washington State non-profit organization. I am also a member of the federal Camp Bonneville Restoration Advisory Board.

After reading and listening to massive amounts of technical information on Bonneville, my personal conclusion is the same as that of the Board, which recently issued this advisory to the Army:

No amount of cleanup will ever suffice to make Camp Bonneville safe for reuse as a Free-range Regional Public Park.

As the State's highest authority and as signatory for the FOSET, please give the following critical points your highest consideration.

PURPOSE OF THE PARK. What are the objectives of this Park? What do Clark County and the State of Washington expect to gain? Fatal encounters with UXO are a certainty given the odds at other UXO sites. The first fatalities will cause the Park to be closed indefinitely, and the site will become a huge liability for the both County and State. If the objective is to satisfy a State GMA requirement, then this objective will certainly fail.

VALUE-VS-RISK. County planners originally believed the Park would benefit the County economically, but the Conservation Conveyance prohibits this. All revenue must remain within the Park. There will be no net benefit to the County. Value-vs-Risk is no longer relevant.

ECONOMICS. Hidden Costs and Long-term Obligations in perpetuity will ultimately have a negative financial impact on the State. Items such as outhouses for 46 miles of fenced and cleared trails must be constructed and maintained for hikers who will not be allowed to step off the trail for privacy. These have not been factored into the cleanup plan. Institutional Controls must be implemented and maintained in perpetuity. Public awareness programs must be developed and implemented County-wide in perpetuity. UXO specialists must be hired for every intrusive act of construction or maintenance in perpetuity. Impacts to the local and regional economy resulting from Hidden Costs and Long-term Obligations in perpetuity will also impact the State.

SELF-SUSTAINABILITY. The Park's self-sustainability is in question due to original uses that have pulled out. An independent poll of the Vancouver and Evergreen School Districts resulted in statements from District officials that they will no longer seek re-location of Outdoor School to Bonneville. The FBI has moved its training facility to Washington County. Retreats are in question due to UXO on-site. Hiking will be impossible without outhouses and lack of rescue in the event of fire. Trees that are suspected of containing UXO will have to be harvested in a costly, if not cost-prohibitive, manner. The County's stipulation for the Park is that it must be self-sustaining. Self-sustainability is in question.

CLEANUP PLAN. Although DOE has spent years developing a cleanup plan, the plan has failed to address several basic concerns. For example, UXO will prevent fire suppression teams from reaching hikers stranded on 46 miles of trails. The cleanup plan also offers no solution for lack of potable water on the site. If the cleanup plan cannot address every means of keeping the public safe, then the cleanup plan has failed.

ENVIRONMENTAL REMEDIATION. National estimates for proper cleanup of Bonneville have been far greater than the $25 million currently proposed. Available funds for cleanup have dropped steadily each year the transfer is postponed. DOE could have told the County it could not develop a protective cleanup plan for $25 million. Instead, it is attempting a superficial cleanup that will fail to protect the public. DOE's interests should lie in protecting the greater community, not just those using the Park. Funds for cleanup are not adequate for the safety of people using the Park. These funds would have a much broader impact if used, for example, to remediate perchlorate-tainted groundwater, and investigate and remove UXO on private property within Artillery Range Fans - elements of cleanup that are not even proposed.

UXO HAZARDS. At the time the Reuse Plan was developed, the Reuse Steering Committee was told by the Army that there was no UXO on the site. Site characterization has proven this false. (Even now, the Army continues to promote this false sense of security. The June 2006 pamphlet developed for the public states that "[no UXO] are suspected to be present.") The Steering Committee was further told that if UXO was found, it would be removed. Members of the Steering Committee have stated they would never have selected a Regional Park plan had they known UXO would remain on-site. UXO will remain on 70% of the site after cleanup, without so much as a surface sweep. Only 3-ft fences will prevent curious children from coming in contact with UXO.

OFF-SITE HAZARDS. As recently as last summer (2005), DOE stated in a memo that the concerns of neighboring property owners were valid. Of the $25 million allocated for cleanup, however, there will be no funds available to address these concerns. Neighboring properties within Artillery Range Fans will not be investigated for UXO. Fire risks to these properties are exponentially increased by the presence of UXO on the Bonneville property. Fire suppression teams will not approach areas that have not been cleared of UXO, including private properties within Artillery Range Fans. Off-site Hazards have not been factored into cleanup, and will have a huge impact on County finances when an accident occurs. Funds for cleanup must be available for cleanup of these neighboring properties.

LIABILITY. Liability issues have not been resolved. By signing the first-ever BRAC Early Transfer for a high-intensity UXO Behavior-Modification Park, the State of Washington will be in a precarious position with regard to liability. An LLC will own the site during cleanup. In addition to lawsuits in the tens of millions of dollars that will result from on-site bodily injury and death, off-site incidents will also impact County finances. The County risk pool will not be adequate to protect County finances. As signatory on the FOSET, the State must be prepared to back up the County financially, which will cost taxpayers dearly. Insurance will not cover bodily injury and death resulting from UXO accidents. Liability in perpetuity for UXO claims both on- and off-site will fall to the County and State.

ALTERNATE USES. Alternate uses would fill other needs without attracting the volumes of people who will flock to a Recreational Regional Park. Most recently, for example, the Veterans Administration has expressed interest in creating an "Arlington West". Willamette Cemetery has reached capacity and the Veterans have no other possibilities for their own cemetery. This honorable use would satisfy a need up and down the West coast that would be recognized nationally. It would not preclude a shared use with the County and/or local Native American Tribes, who have a vested interest in the property by virtue of the aboriginal villages that have been discovered since the initial site characterization. This interest has been ignored by the County. The Tribes have been completely disenfranchised by the County's Park plan. By keeping the site in federal hands, liability will also remain with the U.S. Government.

FEDERAL RESPONSIBILITY. Just as land mines cause civilian casualties worldwide, the Dept of Defense is creating the same scenario at home. Explosives will be left on-site that will eventually kill and maim unsuspecting civilians. Indemnity clauses pervade the PPCD. It is time for the Dept of Defense to accept responsibility and liability for contamination its activities have caused. By accepting this property in its contaminated state, the State of Washington is making this unprecedented statement to the world: The U.S. Government need not be held accountable for its actions.

LEGACY. Decisions made today will create a legacy that will impact the State forever and set a global precedent. The legacy must be this: Washington State will not accept responsibility for lethal contamination left behind by the U.S. Government. This legacy far outweighs the legacy of a doomed Park.

SUITABILITY FOR EARLY TRANSFER. Governor Gregoire, this property is not suitable for early transfer. DOE has spent years attempting to draft a cleanup plan that will make this site safe for a Park use. DOE is recommending Early Transfer because it has a vested interest in implementing its cleanup plan, not because the plan is adequate for a Park. DOE representatives have made choices along the way. They have chosen not to enforce their own cleanup orders. DOE has caved to the federal government's resistance to clean up the property. Instead of working with the Dept of Defense to secure the property and remediate its own contamination, DOE has chosen to work with the government to pass the buck.

I and those represented by this letter believe that this site can never be safe enough for the children who will have free reign of the Park. At the very least, there are no guarantees of safety. No one knows for certain what will be found during cleanup. If the State gambles and loses, the Park use will end. If there is no Park, the County and State will have a liability on their hands that can never be reversed.

We are calling on you to make the choice not to accept this property in its contaminated state.

Thank you for your consideration.

Sincerely,

Lynelle West Hatton
Director, Toxic and Explosive Substances Accountability (TESA)
Member, Camp Bonneville Restoration Advisory Board


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