Arming the Department of Defense's Environmental Liabilities Program

commentary

Jun 23, 2021

Naval Research Lab Chemical Engineer Katherine Hinnant prepares to test an experimental aqueous film-forming foam to replace firefighting foams containing fluorine at the NRL in Washington, Sept. 23, 2019, photo by Navy Petty Officer 3rd Class Manuel Najera/U.S. Department of Defense

Naval Research Lab Chemical Engineer Katherine Hinnant prepares to test an experimental aqueous film-forming foam to replace firefighting foams containing fluorine at the NRL in Washington, Sept. 23, 2019

Photo by Navy Petty Officer 3rd Class Manuel Najera/U.S. Department of Defense

This commentary originally appeared on RealClearDefense on June 23, 2021.

With a new emphasis on sustainable environmental conditions coming to the fore just as budget pressures are increasing, the Department of Defense (DoD) might want to use this renewed focus as an opportunity to develop a systematic approach to addressing its environmental liabilities.

As of 2019, the Government Accountability Office (GAO) estimates that DoD's costs associated with addressing these liabilities are $33 billion. They note that the cost of this liability ranks second only to the department's personnel benefits. The mission of DoD “is to provide the military forces needed to deter war and ensure our nation's security.” The department's environmental liabilities represent risks to the health and well-being of those forces, to the communities where they live, and to the nation that they protect. To strengthen the military and support its readiness, a systematic approach could help support the assessment, monitoring, and prioritization of DoD's substantial effort to remediate its chemical hazards.

The impending water contamination risks of per- and polyfluoroalkyl substances (PFAS) provide a case in point. These ubiquitous chemicals are considered “forever contaminants” because they do not degrade under normal conditions. Research associates them with cancers and suppressed immune function, including reduced vaccine response in children. PFAS exposure may even increase the severity of COVID-19 for anyone who contracts the virus.

The DOD's environmental liabilities represent risks to the health and well-being of the forces, to the communities where they live, and to the nation that they protect.

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The total obligation authority for DoD's environmental restoration accounts (PDF) for 2021 is over $1 billion and outlays for FY22–FY25 also are estimated at around $1 billion each year. The omnibus appropriation for 2021 specifically provided over $300 million for PFAS research and regulation across various agencies. The Pentagon estimates the costs of DoD's PFAS cleanup at $3 billion and growing, with a timeline of 30 years for the work.

Among its prior applications, PFAS played a critical role in aqueous firefighting foams used by DoD and now contaminates some 651 military facilities. The State of New Jersey recently filed suit against the department for PFAS contamination of the groundwater near Joint Base McGuire-Dix-Lakehurst and two other sites, and the city of Dayton, Ohio, is seeking $300 million in damages for PFAS contamination from Wright-Patterson Air Force Base. Five other states have established PFAS standards and are weighing similar actions.

DoD's environmental liabilities, such as the cleanup of PFAS on military installations, are an expensive and challenging problem fraught with uncertainties. PFAS are only one of DoD's environmental liabilities, which also include munitions clean up, radioactive wastes, and heavy metals. Because climate-related risks to installations are not considered “environmental cleanup, closure or disposal costs (PDF),” they are not considered part of DoD's environmental liabilities. Tackling PFAS cleanup, specifically, could benefit from systematic programming, transparent prioritization, and rigorous processes to capture lessons learned at each impacted installation.

DoD knows how to develop programmatic rigor and adaptive management to “wicked problems” like this. For example, Secretary of Defense Lloyd J. Austin considers climate change an “existential threat,” and DoD has invested in the development of a Climate Assessment Tool. The tool is designed to allow consistent assessments of installations to prioritize adaptation efforts across the impacted installations. In addition, through its environmental programs, DoD has led efforts to research, replace, and remediate PFAS (PDF) used in military training and operations, but only $10 million went to this work between 2011 and 2019.

As America enters an era of shifting national focus and uncertainty over Defense budgets, this could be an opportunity to invest in programmatic transparency and efficiency. Given the need to reckon with DoD's looming environmental liabilities, the department might benefit from an updated, systematic process for managing its chemical hazards. The GAO notes that DoD presently does “not have the information they need to monitor the effectiveness of their actions to address their environmental liabilities.” The department could benefit from addressing the threats it faces from chemical hazards with the same rigor and planning it applies to consideration of any other readiness issue. If policymakers were to opt to take this path, this budget cycle could be an opportunity to develop practical, robust approaches to analyze all DoD's environmental liability investments to track progress, reduce risk, and save money in cleaning up chemical hazards.


Christy Foran is a senior physical scientist, R. J. Briggs is an economist and Kristin Van Abel is a technical analyst at the nonprofit, nonpartisan RAND Corporation.