2000 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: Fri, 27 Oct 2000 14:09:58 -0700 (PDT)
Reply: cpeo-military
Subject: [CPEO-MEF] Alaska Report

I (CPEO director Lenny Siegel) spent three full days in Alaska, August
14-16, 2000. At the invitation of the Tanana Chiefs Conference (TCC), I
spent two days visiting military contamination sites in the Upper Tanana
Valley. I spent the third day in Anchorage, meeting with officials and
representatives of non-profit organizations. The principal purpose of
the trip was to learn about community concerns about contamination and
response at formerly used defense sites (FUDS), but other issues came up
in my meetings as well.

The Tanana Chiefs Conference is a service agency made up of and serving
42 native villages, most of which are federally recognized tribes, in
the interior of Alaska. Three TCC staffers took me to two major FUDS and
several minor military sites in the Upper Tanana Valley - southeast of
Fairbanks. I met with environmental staff and tribal leaders at the
native villages associated with the two major FUDS, Tanacross and

The Tanana Valley is home to three huge military installations: Ft.
Wainwright, Ft. Greeley (the garrison area of which is closing), and
Eielson Air Force Base. It is also anticipated to be the home of the
proposed national missile defense system. This visit, however, focused
on military facilities constructed during World War II and the early
years of the Cold War.

The Tanana Valley is defined by the Tanana River, a tributary of the
Yukon River. It is a low, wide, flat valley that is a natural corridor
to Canada's Yukon Territory and areas south. During World War II, an
impressive mobilization by the U.S. military constructed the ALCAN
Highway and the CANOL fuel pipeline through wilderness in just a few
years. The military also built a series of airfields through which over
8,000 aircraft were flown to the Soviet Union under the Lend-Lease
program. In the 1950s, a second, larger fuel pipeline connected Haines,
in southeast Alaska, with Fairbanks.

While the creation of this military infrastructure was impressive, the
environmental degradation has been persistent. The pipelines were
plagued with fuel leaks. Other toxic substances, including pesticides,
cleaning solvents, and PCBs were likely released. Troops and contractors
deposited all kinds of debris, from tin cans to 55-gallon drums to
broken-down vehicles, throughout the landscape. When facilities were no
longer needed, many were simply abandoned in place. The contaminants
appear to pose health threats to the native communities who have
inhabited the Valley for thousands of years, since most people rely on
local fish and game for subsistence. The debris restricts their use of
real property, property which was later formally transferred to native
communities with no acknowledgment of any form of contamination.

The principal agency responsible for military environmental remediation
along this corridor is the Army Corps of Engineers, which manages the
FUDS program. However, there are some properties still under management
of the active Army and its environmental restoration program, and
responsibility at the Tanacross and Northway airstrips has been passed,
to some degree, to other federal agencies - the Bureau of Land
Management (Interior Department) and the Federal  Aviation
Administration (Transportation Department) - which now operate the

On August 1, I first met with people from the University of
Alaska/Resource Solutions, Alaska Community Action on Toxics, and the
Native American Fish and Wildlife Society. I then met with ten staffers
of the federal cleanup branch of the Alaskan Department of Environmental
Conservation. Next I met with an Army Corps project manager of a FUDS in
the Tanana Valley, completing the day with the manager of the Air Force
environmental restoration program in Alaska.

In the course of my visit, I identified a number of issues and in
consultation with my hosts, came up with some proposed actions.

1. Debris. Building demolition and debris removal (BDDR) appears to be a
low priority at FUDS. In general, it is conducted only if a toxic or
physical hazard is clearly demonstrated. However, the Corps has made
some money available for this purpose through the NALEMP (Native
American Land Environmental Mitigation Program), through which the
Defense Department provides $8 million each year to deal with Native
American and Native Alaskan military contamination problems.

My visit made it clear that debris and deteriorating facilities are a
much more significant problem in Alaska than in the "lower 48" states.
It is probably associated with toxic contamination at many locations,
but elsewhere the litter itself discourages use of affected property for
housing, fishing, and other purposes. It has invited continuing dumping
by others. It is also a culturally significant environmental justice
issue: military debris is a constant reminder of past military attitudes
toward the Alaskan environment and Native Alaskan health.

At first it appeared that this might require a legislative remedy, but
the Air Force has apparently found a solution within existing statutes.
Air Force active installations within Alaska also contain old
deteriorating structures and debris. Air Force officials determined that
the problem was unique to Alaska - that national policy did not take
Alaska's unique situation into account. So they sought and obtained a
waiver, from the Defense Environmental Security office, allowing the
expenditure of environmental restoration money on BDDR, as originally
authorized by statute. Its Clean Sweep program allows it to attain
economies of scale in field mobilization by simultaneously conducting
toxic cleanup and BDDR.

Reportedly, the Army Corps obtained a similar waiver for the Northway
cleanup, but it never used it because the NALEMP money became available.

2. Capacity building. Native villages are small and few residents have
technical environmental training, though many have experience - and even
business units - in construction. Though many villages now have hired
environmental staff, in general they still lack the capacity to monitor
and oversee cleanup activities. Where communities are developing such
capacity, both they and the military appear to benefit. Existing
technical assistance programs (EPA's Technical Assistance Grants and the
Defense Department's Technical Assistance for Public Participation)
could prove valuable, but most native communities, as well as other
Alaskan communities, don't really know how to define the requirements
for finding and hiring independent consultants. There are a few options
for overcoming this problem:

A. Fund intermediaries such as the TCC to provide help in defining the
need for, obtaining, and managing independent technical consultants.

B. Focus NALEMP money on capacity building by funding debris removal
through the FUDS program. NALEMP appears to have originally been
available in support of cleanup at any DOD site; now it appears to be
limited to FUDS.

C. Convene an Alaska-wide conference/workshop of RAB members,
representatives of affected villages, and other community activists to
help participants better influence DOD cleanup activities.

3. Government-to -government relationship. Under President Clinton's
direction, federal agencies - particularly EPA, DOD, and the Energy
Department - are establishing government-to-government relationships
with recognized Alaskan native tribes, including villages in the Tanana
Chiefs Conference Region. The Air Force has a memorandum of agreement
with the Louden Tribe at Galena; the Army Corps is reportedly developing
something similar at Evansville. On a more practical level, at Northway
the Corps' principal vehicle for seeking public input is its attendance
at Village Council meetings.

TCC encourages this development, but there are situations where it may
be more practical - from both the military and native point of view -
for the military to deal with the TCC. The Defense Department should
consider ways to conduct government-to-government relations with
associations of tribes, such as the TCC, when member tribes agree that
it is appropriate.

The government-to-government relationship is new. More needs to be done
to figure out how to make it work; emerging success stories should be
publicized and emulated.

4. Local contractors. Native villages want to contract to manage removal
actions and provide support services. While their economic need for such
work is obvious, they also argue that outside contractors really don't
care how well they do their work. Furthermore, the military benefits
from local contracting because it is usually more cost effective, the
locals often have valuable knowledge of the land and past military
disposal practices, and they provide continuity of effort.

Both the Air Force and Corps have the tools to hire tribal contractors
at facilities under their management, but the Corps doesn't seem to
recognize the policy benefits. That is, it could use local contractors
much more of the time. Local contracting potentially raises conflict of
interest questions, particularly where government-to-government
relations are established, but there are examples where those obstacles
have been overcome.

Additional emphasis on hiring local property owners to do cleanup is
similar but not identical to the privatization trend at closing bases.
In fact, the Brownfields model of moving dirt only once - for cleanup
and reuse/redevelopment at the same time - seems directly applicable at
debris-impaired sites such as Northway.

5. Health. Native people throughout Alaskan are reportedly concerned
about the health impact of military contamination. While at urban
locations elsewhere - such as the San Francisco Bay - residents ignore
warnings to avoid eating fish, in Alaska subsistence eaters reportedly
avoid fish and game from particular areas because of unverified
contamination. Furthermore, in villages such as Northway residents
report the emergence, in recent years, of high rates of cancer
mortality, and they suspect that at least some of the disease results
from high exposure levels during periods of significant military
operations in the area.

The Federal Agency for Toxic Substances and Disease Registry is now
studying military health impacts in several native communities, but it
is unlikely to demonstrate much because of its conservative methodology
and reliance upon existing data. Conventional risk assessment protocols
do not consider the habits/lifestyles of native and other subsistence
eaters, so there is a need to adjust methodologies.

There is a need for community-managed health studies and fish/animal
tissue studies throughout Alaska. Both the state of Alaska and the
Native American Fish and Wildlife Society are initiating projects in
this area. They need resources and a guiding hand from affected native
communities. Such studies should help focus cleanup resources and
reassure subsistence eaters in locations where contamination is

It should be recognized that, despite the difficulty of proving
deleterious health affects, some communities will push for "pristine"
cleanup because of their holistic view of the relationship of humans to
their environment.

6. No further action. At Tanacross, local leaders are hoping to overturn
the Corps' No Further Action - now called No Defense Action Indicated -
determination. The Corps recognizes that there may be contaminants and
debris there - similar to that found at Northway, a similar installation
during World War II - but it does not accept responsibility for
initiating cleanup because the Bureau of Land Management has received
"beneficial use" of the property for about  50 years. Of course, BLM
lacks the funds and expertise to conduct cleanup. In fact, Village
leaders complain that BLM's meager activity thus far has placed
monitoring wells in the wrong locations.

Apparently, the Corps has a policy that it won't clean up property where
new owners are using old military facilities (not just the land), unless
it's ordered to or taken to court. That policy ignores the Defense
Department's moral responsibility and may actually be contrary to the
nation's hazardous waste laws.

7. EPA Policy. EPA's new draft policy on FUDS would appear to give the
agency additional clout in reversing Corps inaction at FUDS, but the
Tanacross situation illustrates the complexities. EPA's role in FUDS
site screening - unlike that of the state of Alaska - is contingent upon
the property being in private ownership. That needs to be clarified.
Does it apply to land owned by Native Corporations and native allotments
- individually assigned restricted lands? How about privately owned land
adjacent to FUDS now in the hands of other federal agencies? And what
role will EPA play in states, such as Alaska, where state regulators
believe they have the problem under control?

8. Corridor. The Upper Tanana Valley contains a number of similar sites.
In fact, one "FUDS" - the Haines-Fairbanks pipeline - transverses the
entire corridor. Some contaminated properties are owned by the active
Army. Some are FUDS. The FUDS are under many ownerships, including other
federal agencies, individual Native allotments, and local and regional
Alaskan Native corporations. 

The military and state regulators would gain efficiencies of scale by
bundling projects. Tribes and other communities might benefit through
the creation of area-wide public participation vehicles. In fact, it
would be possible to establish a regional RAB while maintaining direct
relations with tribal villages.

So I propose an Upper Tanana Valley corridor environmental restoration
program. Because of the partnerships it would necessarily entail, such a
program would have to be organized at the highest levels at the Defense
Environmental Security office.

9. Historical preservation. This is just my idea, based upon experience
at BRAC sites in the lower 48. There is an intact, but abandoned
pumphouse along the pipeline right-of-way. It could be restored as a
"living museum" memorializing the incredible World War II mobilization
along the Tanana Valley. The Army could transfer the property to a
native corporation or non-profit organization for this purpose.

10. Funding. Finally, in comparing the performance of the Air Force and
FUDS programs in Alaska, one cannot escape the thought that the Air
Force's stronger budget makes it easier for Air Force officials to get
their job done. Corps headquarters has recently pointed out that it will
take decades to pay for cleanups already identified at FUDS. Upping that
budget will reduce the pressure to ignore or cover up military pollution
at FUDS throughout Alaska. While the annual (Senator Ted) Stevens
plus-up helps, there is a long way to go before money is plentiful
enough that one can trust FUDS cleanup schedules.


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126

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