2003 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: 6 Jan 2003 20:45:34 -0000
Reply: cpeo-military
Subject: [CPEO-MEF] Vieques Environmental Assessment
The Navy has prepared an "Environmental Assessment for Proposed
Cessation of Navy and Marine Corps Training At Vieques Naval Training
Range (VNTR), Vieques, Puerto Rico." Dated November 1, 2002, the
Environmental Assessment is designed to meet the Navy's obligations
under the National Environmental Policy Act should the Secretary of the
Navy determine, under applicable statutes, that the Navy no longer needs
to continue training on the island.

Four sections of the Environmental Assessment, plus a Finding of No
Significant Impact, may be downloaded in English or Spanish as PDF files from
Note that the first section, a multi-color front cover page, may be
difficult to download or print on some computer systems. It is not an
essential part of the document.

Should the Navy decide to close the range, all of the property would be
transferred to the Department of Interior (DOI). The basic premise of
the Environmental Assessment is sound: Closing the range would probably
be good for the environment. The Environmental Assessment, in evaluating
the "no action alternative" of continued limited training, tends to
minimize the current environmental impacts of Navy activity, but those
findings are not central to the proposed action.

Perhaps most interesting, the Environmental Assessment (pages ES 3-4)
summarizes the Navy's position on the cleanup of the Vieques range:

"The Navy and DOI would work closely to coordinate the land transfer
ensuring that plans were in place for the identification, remediation as
necessary, and security of all sensitive sites. The Navy should perform
appropriate remediation of hazardous waste contamination and conduct
response actions, as appropriate, to address munitions and explosives of
concern (MEC) at VNTR, consistent with future use objectives as directed
and required under public law to protect human health and ensure public
safety. Because the Navy would have permanent responsibility for
remediation and munitions response actions and public access would be
prohibited from the LIA [Live Impact Area], it is anticipated that the
proposed action would have no adverse impacts on public health and
safety regarding environmental contamination."

Anyone who has followed the debate over the regulation of former
munitions ranges should quickly recognize: The degree to which the Navy
must clear munitions and explosives of concern (unexploded ordnance,
chemical explosives and propellants, etc.) will be subject to a long,
heated debate among the Navy, regulatory agencies, and the local
community. Many issues will need to be resolved:

Assuming that cleanup will be governed by a Corrective Action Order from
U.S. EPA, under the Resource Conservation and Recovery Act, to what
degree should future land use determine cleanup standards or remedies?

How will the public be kept out of the Live Impact Area?

Who will implement, and who will pay for such restrictions?

Will access controls be foolproof enough to justify leaving unexploded
ordnance on the surface? Beneath the surface?

Will explosives of concern migrate from the range through the air,
surface water, or groundwater, requiring cleanup at the source?

I understand the political reasons why Congress directed the Interior
Department to deny public access to the Live Impact Area, should the
Navy halt operations. However, I think it is bad policy and bad
precedent to declare an area to be a wildlife refuge or wilderness
simply because it might be too difficult or too costly to remediate. If
the area, for ecological reasons, deserves to be a refuge or wilderness,
then it may make sense to base cleanup strategies upon that. But if the
area is more suitable for public use, then such uses should be
"reasonably anticipated," and the Navy should conduct a cleanup to make
such uses are healthy and safe.

Finally, the Environmental Assessment clarifies a key point. The Vieques
Naval Training Range includes waters within 4 nautical miles of the
range coastline. These coastal waters are important, because it is there
that civilians are most likely to encounter ordnance. These areas will
not be "fenced off." Indeed, even now they are used by local fishermen.
The development of regulatory policies to govern the offshore response
will be particularly difficult, but fortunately the Navy is already
working elsewhere - such as Mare Island, California - to develop
underwater ordnance response technologies.


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

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