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(Note: Since this paper was written many new developments have taken place. A more current paper on the same topic was published Fall, 1997. If you would like a copy of this article, "Public Participation in the Cleanup of Contaminated Military Facilities: Democratization of Anticipatory Cooptation" by Andrew Szasz and Michael Meuser, International Journal of Contemporary Sociology, 34(2), October 1997, Contact me, sending your name and mailing address and I'll send you a copy right away.
STAKEHOLDER PARTICIPATION IN THE TOXIC
CLEANUP OF MILITARY FACILITIES AND ITS
RELATIONSHIP TO THE PROSPECTS FOR ECONOMIC REUSE:
THE CASE OF FORT ORD, CALIFORNIA
Andrew Szasz
Associate Professor
Board of Studies in Sociology
University of California, Santa Cruz

Michael Meuser
Ph.D. Candidate
Board of Studies in Sociology
University of California, Santa Cruz

March 30, 1995

"This Defense Adjustment Project was accomplished by staff of the University of California, Santa Cruz through support from Defense Adjustment Assistance Award No. 07-49-02657.45 and the University of California Center for the Study of Global Transformation, Santa Cruz, CA. The statements, findings, conclusions, recommendations, and other data in this report are solely those of the grantee and do not necessarily reflect the views of the Economic Development Administration."


SUMMARY

Fort Ord, a large base on California's Central coast has recently closed. The community is vitally concerned that reuse/conversion plans succeed and policymakers often cite Fort Ord as a "model" of base closure and conversion.
Fort Ord is also known to have serious environmental problems. These problems may interfere with planned conversion and reuse. All interested parties -- Department of Defense (DoD), state and federal regulators, environmental activists, the communities surrounding Fort Ord -- strongly support environmental restoration at the former base, either for its own sake or because it is a key to implementing a promising and attractive reuse plan.
More generally, the Department of Defense has acknowledged that toxic contamination of military facilities is widespread. DoD has committed itself to restoring the environment at these sites. DoD also understands that its traditional way of relating to communities that are contiguous to its facilities is no longer workable. It has embraced the idea that all stakeholders must be given a voice in the cleanup process. To that end, DoD has issued guidelines for the formation of Restoration Advisory Boards (RABs) and RABs have been set up a numerous military sites undergoing restoration.
Environmental restoration is a precondition for realizing various aspects of the Fort Ord reuse plan; in turn, achieving meaningful stakeholder participation seems, today, necessary if restoration is to be accomplished in an orderly and timely fashion. The adequacy of DoD's new enhanced stakeholder participation policy is, then, of central importance. In this paper, we critically examine the development of the basic RAB concept and report early results of our in-depth case study of the implementation of that concept at Fort Ord.
Examining policy design, we find: First, that DoD's RAB guidelines show that DoD continues to deeply distrust public participation in its affairs and that that distrust is operationalized in a host of policy details that, in a variety of ways, constrain and weaken the public's role in restoration decision-making. Second, that the RAB concept rests on flawed assumptions about the nature of contemporary American communities. If, as we believe, the point of RABs is to forestall community resistance and out-of-control "panic organizing," those flawed assumptions may mean that RABs will prove irrelevant to the goal of preventing such outburst of community mobilization, even if RABs are implemented fully and in good faith. Examining policy implementation at Fort Ord, we find that the actual workings of that RAB fall far short of DoD guidelines.
Although our findings are necessarily provisional -- RAB policy is quite new and the RAB at Fort Ord has existed for less than a year; both policy design and policy implementation may improve as DoD learns from its experience -- we think there is cause for concern. Experience suggests that communities can get spooked, lose trust in restoration decisions and decision-makers, organize to halt the restoration process. If RABs are poorly designed and implemented, the fact that they have been organized at a facility may do nothing to prevent such outbursts. Once under way, such events can take on a life of their own and acquire tremendous momentum. Unconstrained, such events can bring restoration to a halt, thereby delaying, if not outright blocking, the conversion of closed bases to new economic uses.

INTRODUCTION: BASE CLOSURE/CONVERSION; TOXIC CONTAMINATION; CITIZENS' FEARS

Military Base Closures: Economic Threat and Opportunity

In the past several years, the federal government has begun to close many military facilities. Three waves of base closings have been announced. In California, alone, 22 bases have closed or are in the process of closing.1
From the point of view of national interest, base closings are rational and desirable. Base closings can, however, mean severe economic hardship for the communities in which those bases are located. Such communities face the prospect of lost revenue, lost jobs, closed stores, falling property values, outmigration. It has been estimated, for example, that the closure of Fort Ord will cost the local economy $ 423 million annually.2
Understandably, communities feel threatened when a local base is slated to close. If, however, the facility is not merely abandoned but is put to new uses, the closure does not have to be the harbinger of local decline; it can, instead, be the vehicle for a burst of vigorous local economic development. At Fort Ord, again, the local reuse authority has developed a plan that promises to generate 60,000 jobs and 20,000 housing units.3
Because base closures can mean economic ruin for local economies, conversion has great political support. On July 2, 1993, the President announced a five part program "to aggressively reinvest in communities and create jobs where installations are being closed."4

Toxic Contamination; Restoration as Precondition for Conversion

The notion of base conversion is attractive because it promises to reconcile conflict between federal and local interests. Desirable though it may be, economic conversion is a complex, difficult, uncertain process. In our research, we are especially interested in how base conversion is affected by the presence of toxic contaminants at the closing facility.
Military facilities, it is now known, have serious environmental problems.5 Contaminants range from wastes that resemble hazardous wastes found at private-sector industrial sites (solvents, paint strippers and thinners; corrosives; heavy metals) to more exotic military wastes (pyrotechnics; radioactive materials; nerve agents; unexploded ordnance).6
The Department of Defense began to identify and clean up contamination at some bases as early as 1975.7 Restoration took on new urgency when bases began to close and communities expressed their desire that closing facilities be made available for other uses. Each potential new use for some parcel of a closed base requires a certain minimum level of cleanliness, though that level can vary greatly depending, say, on whether the parcel is intended to become an industrial park or a new community college campus. If the proposed site for conversion is contaminated, restoration seems to be a necessary precondition if reuse goals are to be realized. James M. Strock, California Secretary for Environmental Protection, stated the obvious when he said, "Without ... environmental clean-ups, it's a pipedream to think these bases can be quickly converted to civilian use."8
(In addition to making bases fit for new uses, restoration is said to have two other economic benefits: If cleanup funds go to local firms, restoration can partly offset the transition-shock of the base closure.9 Environmental cleanups at federal facilities could also contribute to national economic growth if those efforts spur the development of new remediation technologies and encourage the private sector to invest and create a large, sophisticated, globally-competitive remediation industry.)10
Though interest in cleaning up military facilities is high and is growing, policymakers must deal with a series of impediments or hurdles if they are to succeed. Cost11 and technical complexity12 are often mentioned as serious problems. In our work, we focus on a third concern, securing stakeholders' trust and their consent to let the restoration process go forward.

Stakeholders: Trust and Consent vs. Panic Mobilization

Local stakeholders' perceptions of risk is a concern because, as many studies have shown, the American public has developed a deep distrust of technology and of the officials and experts, both in government and in industry, who manage technology and its impacts.13 Industrial chemicals no longer mean progress and material well-being; rather, they evoke images of 55-gallon drums leaking toxic wastes, of cancer, miscarriages and birth defects, of contaminated communities and ruined lives.
Distrust of technology and fear of toxic contamination developed first in the context of communities' dealings with civilian industrial sites, but, with news coverage of contamination at several nuclear weapons plants, then reports of contamination at many, if not most, military facilities,14 such attitudes generalized to military facilities of all kinds. People's view of military facilities shifted from trust and studied indifference to disenchantment and the presumption of contamination guilt. Recent revelations that the military had, early in the Cold War, made some people into de facto nuclear guinea pigs, unbeknownst to them and without their consent, certainly did nothing to improve the public's view of the military establishment's regard for public health and safety.
The fabric of trust between military bases and their surrounding communities is everywhere in doubt, if not actually torn. People feel vulnerable. Consequently, even a minor event during the restoration process may occasion a flareup of fear and concern. Residents living near the contaminated base who, until then, seemed disinterested or indifferent may protest, organize, and refuse to let the restoration process go forward. Expressions of concern about such potential surges of community panic and mobilization are found throughout the literature on remediation at federal facilities.15
Implications for reuse planning are clear enough: If restoration is a precondition for reuse, and if there is a real danger that public distrust may bloom into community panic and mobilization that brings restoration to a halt, lay perception of environmental risks may be one of the most important potential impediments to successful conversion and realizing reuse goals requires the development of mechanisms that can secure local stakeholders' trust and consent.

Expanding Stakeholder Participation

Officials charged with the cleanup of federal facilities have realized the need to address the public's fears. They have realized, too, that the more traditional format for public participation -- tellingly referred to, these days, as "decide-announce-defend" -- does not work.16 Citizens, typically, have not felt that they can really affect the course of things, that opportunities provided them for comment and "participation" are little more than window-dressing, belated attempts to secure their consent to decisions others have already made. New ways to bring stakeholders into the process had to be found.
In early 1994, the Defense Department issued guidelines for the formation of Restoration Advisory Boards at installations undergoing remediation/restoration.17 RABs would be the vehicles for "achieving dialogue between the installation and affected stakeholders ... two-way communication between government decision makers and the community." The guidelines described in detail how community RAB members were to be selected, what role RABs would play in cleanup planning and implementation, even "how to" lessons on communications skills that make for better meetings. Since then, RABs have been organized at numerous installations.

RESEARCH QUESTIONS

That the military has admitted, taken responsibility for, and committed itself to correcting its toxic legacy is indeed a big step forward. Its recognition that stakeholders must be given a significant role in the cleanup process is also to be praised.
Considerable thought and effort have gone into developing DoD's new stakeholder participation policy. The RAB model is, however, at this point, new and untested. It is not known if that model is well-conceived or if it is being properly implemented. RABs must now be studied in detail to assess how they actually function.
Our work aims to contribute to what will certainly be an ongoing effort to evaluate and improve the RAB concept. We believe that the RABs should be examined at two different levels:

(1) Policy Design

We wish to examine the adequacy of DoD's RAB model: Can RABs "increase credibility ... improve community acceptance and support," thereby smoothing the way for environmental restoration and subsequent economic reuse, as DoD hopes? To put it more starkly, can the presence of a RAB forestall explosive outbursts of community panic and oppositional organizing? To date, we have taken two approaches to this question:


(2) Implementation

How are DoD's guidelines being implemented "on the ground"? How are community members chosen? Do community members reflect/represent the diverse segments and interests present in the surrounding community? What actually happens during RAB meetings? How does the RAB alter or impact the restoration process? Do RAB community members report back to the community, as they are supposed to? To answer these questions, we have undertaken a long-term, in- depth case study of the RAB at Fort Ord.
Why Fort Ord?18 Fort Ord is a large (28,000 acre) military base on California's central coast, near Monterey. It was selected for closing in 1992. We believe that Fort Ord is an excellent site for studying DoD's enhanced stakeholder participation policy:


THE DEVELOPMENT OF RAB POLICY

We have examined two key moments in the development of RAB policy. The first is the concensus recommendations of the Federal Facilities Environmental Restoration Dialogue Committee, presented in its Interim Report in February, 1993 -- commonly referred to as the Keystone Report.19 The second is the RAB guidelines jointly issued by DoD and the U.S. Environmental Protection Agency in May, 1994.20
Both documents reject past models of stakeholder participation (decide/announce/defend). Both call for a more open process and earlier, fuller stakeholder participation. The differences, however, are quite important. The DoD/EPA guidelines acknowledge both that they are based on the work of the Keystone group and that they modify the Keystone's recommendations in several ways.
Keystone's model for a community stakeholder organization, which it called a Site-Specific Advisory Committee, or SSAB, does not give that Committee power to actually make remediation/restoration decisions. But, taken together, several of its recommendations give that advisory committee an activist bent:

The DoD/EPA guidelines devote a great deal of space to matters of what one might call democratic form, carefully detailing the process for selecting community members, providing something like a primer course in how to practice good communications skills during meetings. The substance of the guidelines, however, establish an Advisor body that has significantly less independence and less authority than the body envisioned by the Keystone report.
The guidelines make it crystal clear in the very typesetting that the Restoration Advisory Board "is NOT a decision-making body." That differs from Keystone only in emphasis, but it does betray a fear of losing control that is evident in a host of guideline details. In summary, comparison of these two documents suggests that even as the DoD acknowledged that it can no longer operate in the traditional military manner, insulated from civilian supervision and input, it was hardly ready to embrace the process of democratic, public participation, but instead would regard these changes with considerable dread and ambivalence. That ambivalence is embodied in DoD/EPA guidelines that mandate stakeholder participation at the same time that it moves to ensure that DoD will continue to be in firm control.
One general concern is that DoD's efforts to maintain firm control even as it invites greater stakeholder participation may, in the long run, undermine the credibility and legitimacy of RABs, especially when they need that credibility and legitimacy most -- when distrust is rising and the potential for polarization and conflict is growing. More specifically, we are concerned about the implications of the shift from SSAB involvement in reuse/land use planning in the Keystone model to the firm separation of restoration and reuse issues in the DoD/EPA guidelines. Conceptually, the separation makes little sense. Intended reuse determines minimum cleanup goals, so one might argue that reuse plans are primary and restoration secondary and derivative. On the other hand, technical and financial constraints may determine the level of cleanup that can be achieved, independent of any reuse planning. In that case, reuse plans are secondary. It would seem most rational to build in maximum organizational communication between reuse and restoration planning bodies, rather than to seek to compartmentalize them. Furthermore, we are concerned that such efforts to compartmentalize and limit the scope of RAB deliberations is only likely to enhance feelings of powerlessness, both among RAB members and in the community supposedly represented by the RAB, thereby increasing the possibility that the RAB will have little credibility and legitimacy, as we have already discussed above.

A DEEPER CONCERN ABOUT THE RAB IDEA

It is fairly clear that enhanced stakeholder participation policies arose because policymakers were concerned about uncontrolled surges of community mobilization, moments of mass panic and rage that, once they develop, are tremendously difficult to contain and that, if they do develop, make restoration efforts much, much more difficult. The hope is that such moments of unproductive gridlock, familiar enough in the comparable case of cleanup of civilian sites, can be prevented with the introduction of a more open, inclusive stakeholder participation process.
We have some concern that the whole RAB concept, even the more populist Keystone version, is based tacitly on an unrealistic, fictitious, notion of how communities in contemporary American society actually function.
The notion that 12-20 citizen representatives can engage in ongoing, two-way communications with "the community" assumes that a community actually exists, that there is a collective entity that pays attention, that has the infrastructure for discussion and opinion-formation, a community that is, in effect, vibrantly alive and actively engaged with its collective interests.
We think it is much more plausible to offer a quite different image of the contemporary community. To simplify matters a great deal, imagine that communities exist, for the most part, in one of two "digitalized" "states":

(Consider the Monterey Bay communities that surround Fort Ord: This is a region in which, everyone agrees, there is a high degree of environmental consciousness and concern. How does one reconcile that with facts such as: There have been only small handfuls of comments submitted when the public has been asked to comment on proposed Ft. Ord restoration plans; there were only 19 applications for the 12 community member slots on the RAB? Such coexistence of seemingly irreconcilable conditions in public attitude and behavior toward environmental problems is the norm, not the exception. Public interest and concern is ambiguous, seemingly self-contradictory, both present and absent at the same time. Szasz discusses this in some detail in his book, pp. 56-68. For now, let us just say that such contradictions are typical of what we labeled, above, the 0-state.)
If so, the vibrant, engaged community that is the unacknowledged precondition for the SSAB/RAB is not the normal state of American communities. If so, we would then argue that, even at their best, RABs would not function as envisioned: This line of reasoning would suggest that, as presently conceived, RABs will have little effect on community acceptance/consent no matter what the course of events. It suggests that if the intent of RAB design is to prevent, or at least lessen the likelihood, of rapid shifts in communities to 1-state, the whole question of stakeholder participation has to be reconsidered from the ground up.
IMPLEMENTATION

The RAB at Fort Ord was organized in 1994. (The base had a Technical Review Committee made up of defense officials, their contractors, state and federal regulators. Community members were added to convert the TRC into a RAB. The first meeting at which community RAB members were present took place on May 11, 1994.) One of us (M. Meuser) has attended almost every RAB meeting and we have completed our first interviews with all but one of the RAB community members.
It is, of course, way too early to tell how the RAB at Fort Ord will affect the long-term prospects for successful restoration and base conversion. There have, to date, been only a handful of meetings. RAB bylaws are still in draft form; many important things, including how subcommittees will be defined and how they will operate, have yet to be decided. Both DoD and community cochairmanships have experienced turnover recently.
We will be able to report with more confidence once the process has settled down and we have followed the process for several years. However, based on observing numerous meetings and on initial interviews, we feel we can offer a number of observations:
(a) Although DoD lavished considerable attention on proper membership selection procedures, the results at Fort Ord were, at best, mixed. Few people applied to serve as RAB community members. The selection process does seem to have succeeded in having a wide variety of viewpoints represented on the RAB. Some community members are "fast-trackers" who trust and respect the military and want to see pieces of the base cleared for civilian uses asap; others worry more about environmental risks and are not convinced that DoD and regulators are seriously interested in citizen input. In other ways, the selection process was less successful. The most visible problem is that minorities are underrepresented at a base surrounded by communities that have significant Latino, African-American, and Asian population.
(b) Meaningful participation. RABs' legitimacy rests on the claim that even if RABs are not empowered to make decisions they can have some significant, meaningful impact on the course of restoration at the facility. At Fort Ord, claims of significant impact have been undermined, to date, in several ways:

(c) According to both Keystone and DoD, RABs are supposed to work by providing the vehicle for two-way communication between base decision-makers and community stakeholder interests. Parts of point (b), above, suggest that there isn't (yet) much substantive communication from RAB community members to base decision-makers. We also found, in our interviews, that only a small minority of RAB community members systematically report to anyone in the community about what goes on at RAB meetings; most do so only haphazardly; some not at all.
We hasten to emphasize, again, that the Fort Ord RAB is at a very early stage in its development and that things might improve over the next year. New community members might improve minority representation. Community members might gain confidence and take a more active role at meetings. They might develop more sustained ways of reporting back to the community. Difficulties, failure to live up to the ideals of policy design are to be expected at the beginning of implementation. What we have seen, however, does raise concerns, especially if other researchers report similar developments at other RABs.

DISCUSSION

Obviously, many of our findings, at this point, are necessarily tentative. As with any new, untested policy, it is to be expected that DoD will modify and improve its guidelines as experience with RABs accumulates.
Implementation at Fort Ord is also certain to look different once the RAB gets through its startup phase, settles into routine, "normal," operation, and members gain experience. We would hardly be surprised, on the other hand, if things never settled into a routine, if the current organizational tensions generate, instead, chronic discontent and periodic crises. It would be unwise to extrapolate the course of things at Fort Ord from what we have observed to date.
Nonetheless, our work to date is sufficient to raise concern. As we noted in the section titled, "A Deeper Concern About the RAB Idea," a community such as the one around Fort Ord may never "boil over" and travel down the road of panic mobilization and gridlock. If it does not, none of the problems of these recent efforts to enhance local stakeholder participation will matter. The community will remain quiescent, largely inattentive and will give it tacit consent. Restoration decisions and implementation will remain largely in the hands of DoD, its contractors, and various regulators. Once the required level of restoration is achieved, the road will be open to implementing reuse plans. But in the event that things do go wrong and there is panic, both DoD's efforts to limit the theoretical power of the RAB and the numerous implementation problems that are evident at a site such as Fort Ord become important. It is likely that at those moments the presence of a RAB would not be able to forestall the spiral of suspicion, fear, rage and protest. Restoration, and, along with that, economic conversion, might well be brought to a halt.
How should DoD rework its stakeholder participation policy if further research at Fort Ord and, as important, experience at other facilities, confirm our tentative findings? Since our analysis is, at this point, tentative and provisional, it would be inappropriate to specify the alternative in detail and with great confidence. But, briefly, if the above analysis holds up, policy revisions along three points might be indicated:

  1. Rethink how RABs are supposed to represent "the community." This point addresses our argument that the RAB model rests on an unrealistic notion of the state of American communities and RABs, consequently, will prove largely irrelevant to whether or not communities will mobilize and, if they do, the trajectory that that mobilization will take. Realistically, DoD can do little about the paradoxical qualities of the American community, but its current RAB model -- its insistence that RAB community members be selected as individuals, are not to represent an organized element of the community in any direct sense, and act and vote on the RAB as individuals -- only exacerbates its helplessness. We believe that it would be far better to adopt the polar opposite model and build RAB membership in a way that explicitly brings in and represents all of the relevant segments of the community that are already in existence at the time a RAB is formed. This would not only increase the likelihood that RAB members take matters back to the community, as intended, but would also tend to give the RAB legitimacy when and if community panic occurs.
  2. Give RABs more autonomy, more scope and more authority. In brief, push the guidelines back toward the Keystone model. The danger in weakening RABs is, as we have indicated above, that they are likely to be seen as lacking credibility and legitimacy, especially in moments when the public's trust is low and cynicism is high, just when one would like to be able to calm the community by pointing to the existence of the RAB as proof that DoD has been solicitous of people's concerns. In fact, one can imagine that a structurally disempowered RAB would itself become a target at such points and would be a rhetorical target, pointed to as an example of officials' duplicity and lack of good faith. DoD may worry about the loss of control, the extra time, effort, and trouble it would take to work with RABs that have real decisionmaking authority and that are in fundamental ways really autonomous, but that may be the only way to achieve the kind of legitimacy RABs must have in order to do what they were originally intended to do.
  3. Take implementation guidelines seriously. Here, we would include such matters as following guidelines for membership selection and practicing good communications skills. It is clear at Fort Ord that DoD officials need better training in such skills as providing information, running meetings in an open and democratic fashion, and, always of signal importance, listening and communicating real respect toward civilian stakeholders' views and concerns.
NOTES

1. U.S. House of Representatives, 1994; testimony of Mr. David Wang, Cal-EPA, page 4.

2. Raine, 1994. In communities where the facility is by far the largest employer and source of economic activity, the impact of closure is, obviously, "near-disastrous." Christodoulou, 1970:64.

3. Fort Ord Reuse Authority, 1994.

4. GAO, 1994a:8.

5. "By the end of 1992, DoD had identified 1,800 active installations, or facilities, containing 18,795 sites requiring evaluation for possible cleanup. On the basis of its own analysis so far, DoD has concluded that 46 percent of these 18,795 sites do not require further cleanup work. Dod Also has identified over 7,300 formerly used or owned DoD sites with the potential for inclusion in its cleanup program. On the basis of its own assessments so far, DoD has screened out about 3,000 of these sites." -- GAO, 1994b:20. GAO bases this on DoD's Defense Environmental Restoration Program Annual Report to Congress.

"According to DOD's 1993 Annual Report to Congress, DOD has identified nearly 20,000 potentially contaminated sites on 1,722 DOD installations and 8,000 potential sites on 1,632 formerly used installations in the United States. Of the 28,000 sites, DOD has determined that 9,245 sites on current installations and 6,189 sites on formerly used installations require no further action. Of the 10,449 active sites on current installations, 5,507 sites are on 244 installations considered as high priority. ... DOD has initiated or completed the study phases (preliminary assessment/site inspection and/or the remedial investigation/feasibility study) at 7.445 of the 19,694 sites, 3,825 sites have reached the remedial design/action phase. ... As of March 1994, none of the 92 NPL installations and 10 former used NPL installations had all sites cleaned up.

"There are 2,521 potential sites on 149 installations scheduled to be closed. Seventeen closing installations are listed on the NPL, and another 5 are proposed for listing. There are 862 potential sites on closing NPL installations, with 518 in the remedial design/remedial action phase. As of September 1993, 21 of the sites had remedial actions completed and no further action was required at 85 sites. ..." GAO, 1994a:4-5.

"DoD has 254 high priority installations that contain 7,448 sites. ... EPA has designated 102 of these installations as NPL or Superfund sites, which includes 5.029 individually contaminated sites. Another 25 installations with 760 sites are proposed NPL sites." -- GAO, 1994a:9.

6. "Types of hazardous wastes found at most DOD installations ... include solvents and corrosives; paint strippers and thinners; and heavy metals, such as lead, cadmium, and chromium found at most industrial operations. Other substances such as nerve agents and unexploded ordnance are found at some military installations. Contamination usually results from improper disposal, leaks, or spills. The primary contaminant found in a majority of all DOD and private sector waste sites are petroleum products or petroleum-related products such as solvents" -- GAO, 1994a:1.

Beyond such "common" contaminants, Defense site hazardous wastes also present special problems not found at private sector sites: "DoD facilities often have many wastes in common with private sites, but face a cleanup challenge due to the large quantity and variety of wastes. In addition, military-unique compounds such as pyrotechnics, explosives, and propellants are atypical of private industry and require special remedial investigative procedures and responses." -- EPA/DoD, 1992:6. "Unique Military Wastes [include:] Exotic fuels; Explosive compounds (TNT, DNT, etc.); Military chemicals (mustard gas, white phosphorous, Agent Orange, etc.); Mixed waste (low-level radiation and hazardous waste)" -- Ibid.

Military bases also have extensive problems with unexploded ordnance (UXO). James M. Souby, executive director of the Western Governors' Association testified in a Congressional hearing that, "there are some 2 million acres of land managed by the Bureau of Land Management, 15 national wildlife refuges, and some 900 Formerly Used Defense Sites that are contaminated by UXO." U.S. House of Representatives, 1994. UXO can include, as it does at Fort Ord, "rockets, rifle grenades, 60mm mortar shells, armor-piercing ammunition, cannon rounds, howitzer rounds (high explosive, white phosphorous, and illumination), and land mines." -- Fort Ord BRAC, 1994. The DO-IT Military Munitions Working Group states the obvious when it writes that "The risk from unexploded ordnance, both surface and subsurface, in the range area is very high." -- Federal Advisory Committee to Develop On-Site Innovative Technologies, and the Western Governors' Association, 1993c:40. Speaking about UXO contamination at Fort Ord, David Wang, Cal-EPA, told a Congressional committee that "until new technology is developed that can effectively locate and remove all buried UXO at a reasonable cost ... reuse opportunities and public access to the 8,000-acre impact area will be severely limited." -- U.S. House of Representatives, 1994, Wang testimony, page 3.

7. GAO, 1994a:1.

8. PRNewswire, June 14, 1993, Sacramento, Calif.

9. The experience at Fort Ord suggests that such hopes may not be fulfilled. Akeman, 1994, reports that as of the end of 1993, the Army had spent 40 million on environmental surveys and cleanup at Fort Ord. Of money spent to that point in time, only $45,250 has gone to Monterey County firms.

10. The central idea, here, is that environmental remediation promises to be a major, major new market, both in the United States and globally, in the immediate future: Clean Sites, Inc. estimates the future domestic remediation market, alone, at $750 billions. Clean Sites, Inc., 1992. Based on several studies, English, et al (1993:2) put the figure even higher: "the total site- specific costs of hazardous waste remediation in the United States over the next 25 to 30 years could run to as much as about 1 trillion in 1990 dollars ... A sizable chunk -- perhaps as much as a half -- is expected to be consumed by the cleanup of sites owned by the federal government, especially DOE." Vice President Al Gore, in a recent press release, stated that "World markets for environmental technologies are expected to exceed $400 billion per year by the end of the decade." -- White House press release, July 15, 1994. The American economy would be well-served, then, if remediation at federal facilities would be done in a way that develops and demonstrates new remediation technologies and then encourages "commercialization," the private investment that would create a large, sophisticated, globally-competitive remediation industry. The idea of using federal facility remediation as a vehicle for speeding the development of such an industry is the idea that motivated the formation of the Federal Advisory Committee to Develop On-Site Innovative Technologies. See 1993a, 1993b.

11. It is estimated that it will cost at least 25 billions of dollars to clean up contamination at military sites, possibly much more. EPA's 1993 estimate was $25 billion for DoD (and, in addition, $200 billion for DoE, $18.7 for state and federal Superfund sites). -- Comments by James M. Souby, Federal Advisory Committee to Develop On-Site Innovative Technologies, and the Western Governors' Association, 1993a. Clean Sites, Inc. estimates the future domestic remediation market at $750 billions. Clean Sites, Inc., 1992. Based on several studies, English, et al (1993:2) put the figure even higher: "the total site-specific costs of hazardous waste remediation in the United States over the next 25 to 30 years could run to as much as about 1 trillion in 1990 dollars ... A sizable chunk -- perhaps as much as a half -- is expected to be consumed by the cleanup of sites owned by the federal government, especially DOE."

All such estimates are subject to potentially upward revision: "Since 1985, DOD has made several estimates of its long-term cleanup costs. These estimates have grown steadily from an initial estimate of $5 billion to $10 billion in 1985 to its latest estimate of $24.5 billion, made in 1991." -- GAO, 1994b:7. "DOD officials, in June 1993, stated the estimate to clean up all sites had risen to about $30 billion." -- GAO, 1994a:6.

The GAO reports, furthermore, that estimates are uncertain and that costs are likely to be quite a bit higher: "DOD's $24.5 billion estimate does not represent the Department's full cleanup liability because (1) it may not include all potential sites to be cleaned up, (2) most studies of known sites have not been completed, (3) the time required for studies and cleanups could be longer than expected, and (4) some facilities are requiring more cleanup than originally anticipated." -- GAO, 1994b:7-8. "DOD's cost estimates for each NPL installation are based on the scope of work called for in the Federal Facilities Agreements.

However, these agreements are usually signed prior to the completion of the remedial investigation/feasibility studies. Until the studies are completed, usually little is known about the nature and extent of contamination at known sites and before many sites have been identified." -- GAO, 1994a:7.

Experience suggests that actual costs usually exceed projected costs. Take, for example, the Army's experience with chemical weapons: "In 1984, the Army estimated that destroying its 70-million-pound chemical arms stockpile would cost $1.2 billion and take until the end of 1994. Ten years later, the estimated cost of the program has soared to nearly $10 billion, and just two of the nine incinerators the Army says it needs for the project have been built." Schneider, 1994. "According to a March 1994 report by the Congressional Budget Office, DOD's estimates of environmental restoration costs might be understated by $20 billion, or by about $4 billion annually over the next 5 years. ... Congressional Budget Office officials testified that the average cleanup costs at military bases slated for closing are 60 percent higher than initially projected and that increasingly strict cleanup standards will drive DOD's costs even higher." -- GAO, 1994c:9-10.

To some degree, ultimate cost depends on how thorough the cleanups will be. James Souby, of the Western Governors' Association, testifying at the Congressional Committee hearing on UXO, cited the example of the Umatilla Army Depot in northwest Oregon. 1750 acres at Umatilla have UXO. According to Souby, Surface cleaning would cost $1.2 million; cleaning to a depth of five feet, $13.7 million; cleaning to a depth of twenty feet, $900 million. U.S. House, 1994: Souby testimony, page 3. David Wang, Cal-EPA, spoke about UXO at Fort Ord, at the same hearing. It is usually estimated, he said, that cleanup of UXO at Ord -- 8000 acres to a depth of 10 feet -- would cost $800 million. However, "$800 million would not even provide for a complete UXO cleanup. Excavation activities below 10 feet would have to be prohibited ... Regular monitoring would be required in perpetuity to detect UXO that may be migrating to the surface." Wang testimony, page 4 [emphasis added].

No wonder, then, that "In recent testimony before the Senate Budget Committee, the Secretary of Defense characterized environmental restoration and pollution prevention as one of the fastest growing items in the defense budget." -- GAO, 1994c:9.

The problem, of course, is that in the United States today, governmental bodies at every level, city, county, state, federal, face severe fiscal constraints and, consequently, must constantly make hard decisions about budgetary tradeoffs. In this kind of fiscal situation, sustained adequate funding for toxic cleanups is far from guaranteed. The GAO notes that even as funding for cleanups continues to grow, that funding is already becoming somewhat restricted: "Until the fiscal years 1993 and 1994 appropriations, Congress had funded DOD's cleanup program usually near the level DOD requested. In 1993, Congress reduced DOD's budget request by #313 million and appropriated $1.2 billion. In 1994, Congress reduced DOD's budget request by #347 million and appropriated $2 billion." -- GAO, 1994a:7. One can already find instances where funds already appropriated for DoD cleanups were subsequently diverted when Congress had to find funds to deal with unexpected fiscal demands. David Wang of Cal/EPA noted, in Congressional testimony, that "... in January, [1994] Congress rescinded $507 million from military base cleanups and redirected it to disaster relief for the Northridge earthquake." -- U.S. House, 1994, Wang testimony, page 4.

12. Experience shows that the remediation of "ordinary" contamination at the typical civilian Superfund site has proven extraordinarily costly, time- consuming, fraught with uncertainty and complexity. Szasz, 1994: 137-139. DoD installations are only more likely to present technical challenges: "DoD facilities often have many wastes in common with private sites, but face a cleanup challenge due to the large quantity and variety of wastes. In addition, military-unique compounds such as pyrotechnics, explosives, and propellants are atypical of private industry and require special remedial investigative procedures and responses." EPA/DoD, 1992:6. See, also, the Keystone report: "As the sheer magnitude of federal facility environmental contamination has become clear, so have the technical complexities of these problems. In many instances ... [those problems] are similar to those that are found at private sector sites. However, in numerous other situations, especially those found at the major defense production facilities owned and operated by the DOE, the technical dimensions of the environmental contamination problems are perhaps as complex as those found anywhere in the world." Federal Facilities Environmental Restoration Dialogue Committee, 1993:1. [emphasis added] Although this statement was made with DoE installations and high-level radioactivity especially in mind, it is certainly true of some forms of contamination found at "average" military bases, such as unexploded ordnance (UXO). As David Wang of Cal/EPA testified in front of a Congressional Committee: "It does not appear that long-term cleanup of all UXO contamination at Fort Ord will be feasible until new technology is developed that can effectively locate and remove all buried UXO at a reasonable cost." U.S. House, 1994. At a recent UCSC-sponsored UXO conference held at Ft. Ord, experts from various national labs agreed that there was, currently, no technology that could reliably detect buried UXO.

13. This literature upon which this discussion is based is reviewed and discussed in Szasz, 1994, pp. 38-68, 84-88.

14. Hardert, 1993; Lodwick, 1993; Sheak and Cianciolo, 1993.

15. Two examples: "citizen opposition can be costly, both in terms of financial resources which must be committed to responding to the opposition, as well as in the cost of project delays ... in extreme cases, litigation or political initiatives to inhibit or stop remediation activities." -- DOIT/WGA, 1994b:6. A recent Army Corps of Engineers publication suggests that it would be prudent to find ways to "channel stakeholder participation productively. By including interested individuals and groups in decision making, potential critics may become supporters of environmental programs. ... Certainly there is little point in building open, trusting, and empowered relationship with other agencies only to have implementation blocked by citizens who have been left out of the process." -- Institute for Water Resource, U.S. Army Corps of Engineers, 1994:19.

16. See, for example, DOIT/WGA, 1994b:6, DoD/EPA, 1994.

17. DoD, 1994; DoD/EPA, 1994.

18. The discussion that follows is based on our examination of documents published by the Fort Ord Base Realignment and Closure (BRAC) Ordnance Remediation Program, the Fort Ord Environmental Office, the Fort Ord Reuse Authority, minutes of meetings of the Fort Ord RAB and minutes of meetings of the Fort Ord Technical Review Committee (TRC).

19. Federal Facilities Environmental Restoration Dialogue Committee, 1993.

20. DoD/EPA, 1994.

REFERENCES

Akeman, Thom, 1994, "Local role small in Ord cleanup," The Monterey County Herald, August 5.

Anderson, Julie (Director, Federal Facilities Cleanup Office, US EPA Region IX), 1994, letter to Lewis D. Walker, Deputy Assistant Secretary of the Army (Environment, Safety and Occupational Health) Installation Logistics and Environment. July 25.

Biondo, Valerio and Curt Gandy, 1994, "Draft Memorandum Re: Lack of Meaningful Input by the Fort Ord Restoration Advisory Board Regarding Critical Decisions on the Transfer of Property to CSU at Monterey and UCSC" August, 10.

Browner, Carol M., 1993, "The Interim Report of the Federal Facilities Environmental Restoration Dialogue Committee," cover letter, dated 4.19.1993.

Christodoulou, Aris P., 1970, Conversion of Nuclear Facilities from Military to Civilian Uses: A Case Study in Hanford, Washington. New York: Praeger.

Clean Sites, Inc., 1992, "Strawman Proposal for Joint Industry-Government Evaluation of Innovative Technologies and Treatment Trains at Federal Facility Sites," Alexandria, VA: Clean Sites, Inc.

English, Mary R., Amy K. Gibson, David L. Feldman, and Bruce E. Tonn, 1993, "Stakeholder Involvement: Open Processes for Reaching Decisions About the Future Uses of Contaminated Sites," Knoxville: University of Tennessee Waste Management Research and Education Institute.

Federal Advisory Committee to Develop On-Site Innovative Technologies, and the Western Governors' Association, 1993a, "Commercialization Roundtable, San Francisco, August 19, 1993 -- Selected Background Papers."

________, 1993b, "Regulatory Barriers Roundtable, San Francisco, October 20, 1993 -- Selected Background Papers."

________, 1993c, "Report," Military Munitions Working Group, Federal Advisory Committee to Develop On-Site Innovative Technologies, Nov. 30.

________, 1994a, "DOIT Committee Implementation Guidance: Model for Local Stakeholder Involvement," draft, march 10, 1994.

________, 1994b "Local Stakeholder Involvement to Enhance Technology Acceptance," Material for July 14th Western States Remediation Technology Meeting, Denver, CO.

Federal Facilities Environmental Restoration Dialogue Committee, 1993, "Recommendations for Improving the Federal Facilities Environmental Restoration Decision-Making Process and Setting Priorities in the Event of Funding Shortfalls," Interim Report, [a.k.a. the Keystone Report] February, 1993.

Fort Ord Base Realignment and Closure (BRAC) Ordnance Remediation Program, 1994, "Fact Sheet," No. 7, March 26, 1992, updated April 29, 1994.

Fort Ord Environmental Office "Advance: Fort Ord's Quarterly Environmental Newsletter," various issues.

________, 1991, "The Army's Environmental Cleanup at Fort Ord," brochure, September.

________, 1992, "A Fort Ord Success Story: The Fort Ord Soil Treatment System," brochure, October.

________, 1993a, "Fort Ord's Hazardous Waste Management Program," brochure, March.

________, 1993b, "The Groundwater at Fort Ord," brochure, February.

________, 1993c, "Ordnance and Explosive Waste at Fort Ord," brochure, May.

Fort Ord Restoration Advisory Board (RAB) meeting minutes (various).

Fort Ord Reuse Authority, 1994, "Preliminary Draft: Summary of Base Reuse Plan," February 8, 1994, Marina, CA: Fort Ord Reuse Authority.

Fort Ord Technical Review Committee (TRC) meeting minutes (various)

Gandy, Curt (Fort Ord Toxics Project), 1994, Letter to Ms. Youngblood, Oct. 16, on Ft. Ord Draft Basewide Remedial Investigation/Feasibility Study.

Hardert, Ronald A., 1993, "Public Trust and Governmental Trustworthiness: Nuclear Deception at the Fernald, Ohio, Weapons Plant," pp. 125-148 in William R. Freudenburg and Ted I.K. Youn, eds., Research in Social Problems and Public Policy, Vol. 5, Greenwich, CN: JAI Press.

Harding Lawson Associates, 1991, "Community Relations Plan, Fort Ord, Monterey County, California," Novato, CA: Harding Lawson Associates.

Hinds, Cathy (Military Toxics Project), 1994, Letter to Ms. Gail Youngblood, October 20.

Institute for Water Resources, United States Army Corps of Engineers, 1994, "Draft: Partnering Guide for Department of Defense Environmental Missions," Fort Belvoir, Va, July.

Lodwick, Dora G., 1993, "Rocky Flats and the Evolution of Mistrust," pp. 149- 170 in William R. Freudenburg and Ted I.K. Youn, eds., Research in Social Problems and Public Policy, Vol. 5, Greenwich, CN: JAI Press.

Nussbaum, Stephen D. (Project Manager, Federal Facilities Management Unit, Remedial Project Management Section, Bureau of Land, Illinois Environmental Protection Agency), 1994, letter to Alan Balliett (BRAC [Base Realignment and Closure] Environmental Coordinator, Fort McCoy, Dept. of Army) and Gary Schafer (US EPA Region V). August 17.

Public Affairs Office, Fort Detrick, 1993, " Community Involvement," "Fort Detrick Environmental News," December 14, 1993, Frederick, MD: Public Affairs Office.

Raine, George, 1994, "Battle of Fort Ord begins," San Francisco Examiner, January 9, page B-1.

Schneider, Keith, 1994, "Toxic Messes: Easier Made Than Undone," The New York Times, October 5.

Sheak, Robert J. and Patricia Cianciolo, 1993, "Notes on Nuclear Weapons Plants and Their Neighbors: The Case of Fernald," pp. 97-122 in William R. Freudenburg and Ted I.K. Youn, eds., Research in Social Problems and Public Policy, Vol. 5, Greenwich, CN: JAI Press.

United States Department of Defense [DoD], 1994, "Management Guidelines for Execution of the FY94/95 and Development of the FY96 Defense Environmental Restoration Program," Washington, DC: DoD, April 14.

_______ and United States Environmental Protection Agency [DoD/EPA], 1994, "Restoration Advisory Board Workshop Guidebook," Joint DoD/EPA Restoration Advisory Board Workshop, San Francisco, August 14-16.

United States Environmental Protection Agency [EPA], 1991a, "Superfund Innovative Technology Evaluation Program: SITE Program Fact Sheet," OSWER, May, 1991.

________, nd, "A Public-Private Partnership: Evaluating Innovative Hazardous Waste Treatment Technologies," EPA/Technology Innovation Office

________ and United States Department of Defense [EPA/DoD], 1992, "The ROAD to ROD: Tips for Remedial Project Managers: Working Together to Get There Faster," Pre-publication version, January, 1992.

________, 1994, "Final Draft: Restoration Advisory Board Implementation Guidelines," Draft Version 2.4, May.

United States General Accounting Office [GAO], 1994a, "Environmental Cleanup: Too Many High Priority Sites Impede DOD's Program," GAO/NSIAD-94-133.

________, 1994b, "Federal Facilities: Agencies Slow to Define the Scope and Cost of Hazardous Waste Site Cleanups," GAO/RCED-94-73.

________, 1994c, "Future Years Defense Program: Optimistic Estimates Lead to Billions in Overprogramming" GAO/NSIAD-94-210.

________, 1994d, "Superfund: EPA's Community Relations Efforts Could Be More Effective," GAO/RCED-94-156, Washington, DC: Government Printing Office.

United States House of Representatives, Committee on Natural Resources, 1994, "Managing Unexploded Ordnance on Federal Lands," Hearing held May 2, 1994, Seaside, CA.

White House Office of the Press Secretary, 1994, Press Release, July 15.

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