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Pentagon Lobbies for Environmental Legal Relief 

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by Sandra I. Erwin 

An escalating dispute between the Pentagon and environmental advocacy groups is not about to be settled any time soon.

The Defense Department—which brags about being a responsible environmental steward that complies with the laws—has been under fire in recent months from critics who accuse the Pentagon of unfairly trying to circumvent the rules.

Specifically, the Pentagon submitted to Congress a package of legislative reform proposals that would make it more difficult to keep military trainees out of certain ranges when those ranges are deemed “critical habitats” for endangered species.

The changes sought, however, should not be viewed as an attempt by the Defense Department to receive “blanket exemptions” from environmental laws, said John P. Woodley, assistant deputy undersecretary of defense for installations and environment. He recently was nominated to become assistant secretary of the Army for civil works.

“We want to be able to manage the military lands in ways that allow us to continue realistic military training,” he said in an interview. Repeated entreaties for regulatory relief have been “mischaracterized” as a desire to overturn laws, which is not the case, said Woodley. The Pentagon primarily is concerned about environmental laws being “interpreted in ways that are making it increasingly difficult to conduct realistic training in some of our installations.” A number of judicial rulings, Woodley said, “are having a disproportionate impact on our ability to use our facilities for what they were intended.”

Courts throughout the United States, he said, “have been encouraged to adopt interpretations that make it more difficult to manage our property.”

He cited an ongoing lawsuit involving Camp Pendleton and Miramar Marine bases, in California. The Pentagon argued that a ruling under the Endangered Species Act was unduly restricting the Marines’ ability to conduct amphibious landings along the coast.

The plaintiff, the Natural Resources Defense Council, is seeking to have more than half of the land on both bases designated as “critical habitats,” which would curtail the training severely, said Woodley. The NRDC claims that training activities are imperiling endangered species such as the California gnatcatcher, a local songbird.

“Critical habitat designation is the most restrictive form of remedy under the Endangered Species Act,” said Woodley.

The Pentagon would like to work out a compromise that would address conservation needs without hampering training, he said. Last year’s proposals were defeated in the Senate, which was then under Democratic control. This year, with Republicans in charge, things could change, Woodley said.

Separately, Defense officials are working on internal reforms designed to satisfy training requirements vis-à-vis environmental restrictions. A January 2003 directive from Deputy Defense Secretary Paul Wolfowitz instructs the deputy undersecretary of defense for installations and environment, Raymond DuBois, and the undersecretary for training and readiness, David Chu, to collaborate on a plan to improve the quality of U.S. military training ranges, and determine to what extent environmental regulations and “encroachment” undermine training priorities. Encroachment is a Pentagon buzzword used to describe the trend of urban growth around military bases.

“Environmental encroachment is not just the Endangered Species Act and critical habitat management issues that we face every day,” said DuBois. “It’s also urban sprawl ... airspace management. It’s also spectrum competition.”

Wolfowitz’ directive also asks Defense Department environmental professionals who typically have operated in relative isolation to work more closely with military training and testing organizations. The mandate aims to satisfy complaints from uniformed commanders that the Pentagon’s environmental office is not always in tune with their needs.

“We’ve been criticized that our environmental professionals are in a stovepipe,” said Woodley. In the future, “they will be closely tied to the operators and the trainers, the test and evaluation community.”

The Defense Department manages more than 620,000 facilities, valued at around $600 billion, and more than 46,000 square miles of real estate. These lands are home to a number of threatened and endangered species and historical resources, including 68 registered National Historic Landmarks and 14,000 properties listed or eligible for the National Register of Historic Places.

During a recent hearing of the Senate Armed Services Committee, DuBois sought to make a case for regulatory relief. “The impacts on readiness must be considered when applying environmental regulations to military-unique training and testing activities,” he said. “We are addressing the effects that encroachment poses to our ability to ‘train as we fight.’”

The reform package proposed by the Pentagon is called “Readiness and Range Preservation Initiative.” Last year, Congress approved two provisions. One allowed the Defense Department to request permanent legislative authority to enter agreements with non-federal entities to manage lands adjacent to military installations. Congress also granted the Pentagon a temporary exemption from the Migratory Bird Treaty Act for the incidental taking of migratory birds during military readiness activities.

Additional reforms are needed, however, said DuBois. “Today, we are developing a long-term process to address encroachment by creating a multi-year, comprehensive program to sustain training and testing.”

The administration, he explained, “will seek legislative clarification where laws are being applied beyond their original legislative intent.

“We believe that modest legislative reforms are needed to ensure the preparedness of this nation’s armed forces, and we will continue to work with Congress to seek enactment of legislation to address these concerns.”

Critics of the Pentagon’s efforts to reform environmental regulations, meanwhile, accuse the Defense Department of exaggerating the problem.

“Environmental laws in no way prevent the military from training for combat,” said Robert Perks, a spokesman for the Natural Resources Defense Council. “The Pentagon tried, last fall, to exploit the war on terrorism and building tensions with Iraq to get full-scale exemptions from environmental laws,” said Perks. “Now, they are about to drop new legislation, indicating they are looking to expand those exemptions.”

Perks said all this is unnecessary, because there are articles in the laws that accommodate military training needs. “All our environmental laws have provisions in them that waive those requirements for national security,” he said. “If the Defense Department really needs a waiver to train, they can invoke an exemption and get a waiver.”

In his opinion, said Perks, “They are cataloguing any grievance they have against environmental laws and saying this justifies waiving wholesale environmental protection. ... They are trying to blow this out of proportion. It’s unfortunate they are doing that.”

When the nation is on a war footing, it is difficult to convince people that environmental conservation matters, said Perks. “They can wave the flag, say our troops need this and can get whatever they can. They are exploiting the situation, because of the perilous times we live in.

The Defense Department historically has “always wanted to be less constrained by environmental laws,” he added, because it is the “largest polluter in the country,” with hundreds of toxic waste sites, where fuels and materials seep into the ground water. Military bases, however, have some of the best-maintained habitat, because they have not been developed.

As it turns out, “the Defense Department has proven itself to be a good steward, because of the laws,” said Perks. “In many cases, when they are forced to do these things, they do a good job. And they like to brag about it.”

According to Perks, “they are trying to have it both ways. They [complain about] environmental laws, but at the same time, they say, ‘trust us. We do such a good job abiding by environmental laws.’”

He cited a June 2002 General Accounting Office Report that concluded the Pentagon has not made a compelling case that the laws undermine military readiness.

The Pentagon, in fact, oversees many of the toxic waste and polluted properties of the United States. Most of the contaminated sites date back to World War I and World War II. They are ammunition storage facilities, testing and bombing ranges, and ordnance depots. There are about 9,000 such sites, 2,000 of which need environmental restoration, said Woodley.

Cleaning those 2,000 sites will cost about $19 billion. Further environmental cleanup needed on active bases adds another $10 billion to the projected price tag. Bases closed under previous BRAC rounds will cost about $4 billion to decontaminate. The $33 billion liability does not even include removal of unexploded ordnance from training ranges. A plan to begin to tackle the UXO program will get under way next year, under a so-called “military munitions response program,” said Woodley. A top priority is to prevent chemicals from contaminating the groundwater near the ranges.

The Pentagon’s mammoth cleanup job could be completed during the next two decades, said Woodley. BRAC properties will be cleaned up by 2005, he said. The others will have to wait until 2014 and beyond.

In fiscal year 2004, the Pentagon requested $3.8 billion for environmental programs, compared to $4.2 billion in 2003. The 2004 budget includes $1.3 billion for cleanup, $412 million for BRAC facility restoration, $1.6 billion for compliance, $173 million for pollution prevention, $153 million for conservation and $191 million for new technology.

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