[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


--
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
http://www.cpeo.org

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