Why not Camp Grayling?

Early this year, the firing ranges at a National Guard training facility -- Camp Edwards of the Massachusetts Military Reservation -- were shut down because of extensive toxic contamination and the threat to the groundwater and hence the drinking water of many who live on Cape Cod. Many other military firing ranges in the U.S., and indeed around the world, have been tested and toxic contamination has been found. Range 40 at Camp Grayling has also been tested under the supervision of the Michigan National Guard and the Michigan Department of Environmental Quality (MDEQ), and serious contamination was initially reported and then, both ignored and refuted.

With this story I want to begin a series of articles that address primarily the question: Why Camp Edwards, why all the others, why not Camp Grayling? With your assistance we could also look at such subsidiary questions as: Are combat troops really needed in the National Guard? Should the central highland pine barrens of Michigan become a National Sacrifice Area? Possibly our readers would suggest additional relevant questions.

To begin, a brief history of our struggle with the National Guard at Camp Grayling is in order. The Riverwatch of five years ago (August 1995) contained a special section on Camp Grayling. [Webmaster's Note: The original article in the hardcopy Riverwatch contained a reference to the Angler's web site at that time. This has been removed and the HTML link above—August 1995—inserted.] In that issue, Dan Alstott had a story on the history of the Au Sable Manistee Action Committee (AMAC) which was formed late in 1987 about nine months after the formation of The Anglers and about the time of our first annual meeting. Dan began his story by highlighting the first five years of our struggle with the Michigan National Guard over Camp Grayling. I believe it prudent to begin this account by quoting these highlights, with some minor editing and additions. The following items, in chronological order, highlight the first five years, from late in 1987 to the summer of 1992:

The Hanson Lawsuit is filed.
Governor Blanchard appoints the Camp Grayling Management Advisory Committee (CGMAC) and extensive hearings take place. Dick Daane testified for The Anglers.
The Camp Grayling Environmental Impact Statement (CGEIS) is released, attacked, and destroyed by critics. The Guard retreated to rewrite the document.
Governor Blanchard appoints a Camp Grayling Advisory Council (CGAC) to follow up on the findings and recommendations of the CGMAC. I really don’t know if this offshoot ever had a meeting.
The CGAC goes defunct when Governor Engler is elected. No one was surprised.
Heavy weapon firing ceases three hours after sunset and on major holiday weekends. I believe that still is the case.
Aircraft are supposedly rerouted and assigned higher altitudes. Has this remained true?
An official complaint office is established. Is it still operative?
The Michigan Department of Natural Resources (MDNR) forces the Michigan Department of Military Affairs (MDMA), i.e., the Michigan National Guard, into a legally binding Consent Order demanding environmental compliance. This gave us great hope for a short period of time.
Camp Grayling installs noise monitors for monitoring and control. Are they still in place?
A pollution testing project begins on Range 40 as a result of the Consent Order. Even though it is my understanding that this should continue, I don’t believe it has.
The MDMA hires seven new environmental staff members with four full-time at Camp Grayling. I do not know how many are there now.
Camp Grayling evidently begins following the environmental stewardship directive of the Secretary of Defense. I do not know if this has continued.
The Multiple Launch Rocket System (MLRS), the Assault Landing Strip (ALS), and the Multi-Purpose Range Complex (MPRC) are put on hold pending the future revisions in the CGEIS, which was soon to come.

For those readers who are somewhat unfamiliar with this struggle I should briefly clarify some items. The Hanson Lawsuit was a suit about the original donation of land which started Camp Grayling. (I believe this lawsuit was then expanded to include questions about the language in the relevant documents regarding the extensive lands the military leases from the people of Michigan through the DNR, but I’m uncertain of this.) Because of the escalated use of Grayling, the ever increasing nuisance of military activities, and the threat of camp expansion, the CGMAC was formed and extensive hearings were held. About the same time the original CGEIS was issued wherein twenty projects intended to expand activities at the camp were proposed.

The list for the first five years should include these items: a document ("TOTAL FORCE" AND THE RAPE OF THE AU SABLE) which alerted the Anglers to the expansion of Camp Grayling and which brought a threat from the top General in Michigan to sue us; this document also initiated a series of exchanges between The Anglers and the Guard; a Freedom of Information Lawsuit (FOIA) the Anglers brought against the MDMA, where we won a partial victory which didn’t matter since the Guard didn’t supply the information requested anyway; the installation of an improved sewage disposal system at the camp which stopped the dumping of raw sewage into Bear Swamp at the headwaters of the Manistee River; the dispute over the testing of an experimental guided missile on one of the ranges which expanded into the subject of other uses of the camp unrelated to military training; the attempt in our first year by the Guard to appropriate another 60,000 acres of state-owned land to expand the camp (we helped to stop that); disputes over fires started by military activities and then left unchecked; disputes regarding other polluted sites under military control such as the airfield and the facility where vehicles were cleaned; training activities that took place on the Au Sable River itself; and many others, including the Kirtland’s Warbler, an endangered species which seems to love Crawford County, for some strange reason.

The above takes us to 1982. With the help of Dan’s story I will give a brief and possibly inadequate summary of the past eight years:

The Hanson lawsuit was won by the MDMA, a victory I will never understand.
A revised CGEIS, rewritten several times after the initial 1989 hearings, and which now addressed but three projects (a new bulk fuel facility, some new storage buildings, and the MPRC) was released, and even though badly flawed, was approved.
AMAC sued the Guard regarding CGEIS but only with regard to the MPRC.
As a result of the Consent Order the military began testing Camp Grayling’s ranges beginning with Range 40, the north range, sometimes known as the artillery range. Contamination was found and the range was listed as a 307 site. Some cleanup of contamination around propellant burn areas was done. Further testing around the periphery of the range has been done but not in the impact areas. Contamination has been found but no remediation has been undertaken.
The Guard won the CGEIS lawsuit (more about this later).
The MPRC has been built and put into operation, for whatever that was worth. Combined arms training (tanks, infantry, aircraft, helicopters, etc.) remains questionable.
An EIS for the deployment of the MLRS was released and the weapon has been deployed on Range 40 which is obviously a polluted range.
To my knowledge there has been no further testing on any other range at Grayling including the tank range (Range 30), any mortar range, or any small arms range, even though when the testing began on Range 40, the Michigan DNR stated that its consent order with the MDMA required the testing of all ranges. Since then the DNR has been split and now the MDEQ has the responsibility of oversight on the MDMA at Camp Grayling.
As we became bolstered by the good news regarding the efforts there to shut down the ranges at Camp Edwards, Dan Alstott representing AMAC in May 1997, asked EPA Region 5 to intervene in the environmental testing at Camp Grayling. After four months of investigation, the EPA rejected intervention primarily on the basis that it had no rationale for intervention under provisions of the Safe Drinking Water Act.

In the August 1995 "Riverwatch", Pete Gustafson, the attorney who represented AMAC in the CGEIS lawsuit, had a story which we should all reread. I will quote a couple of passages:

"Those who love the Au Sable must not forget how the government ‘won’ the case in court. The military must be held to the representations it made to persuade the court that the MPRC would cause no environmental harm. Many of these representations were referred to in the court’s opinion. Remember these National Guard assurances in the coming months and years:

The MPRC will result in no increase in training frequency and intensity. The Guard stated that the same number of troops will use Camp Grayling for tank training as in recent years.
The MPRC will reduce noise levels from tank training activities.
That only inert, non-explosive rounds will be used on the MPRC, containing no contaminants in the propellants of the rounds or the rounds themselves.
That no white phosphorous, mercury, or other hazardous substances will be used in and around the MPRC for any purposes.
There will be no negative impact on fish and wildlife in and around the MPRC.
That, in general, the MPRC will improve environmental conditions at Camp Grayling, resulting in less noise, pollution, and interference with the peace, tranquility, and environmental quality of the Au Sable River system than the former uses of Range 30."

"The government prevailed in its case by making these assertions. It is up to all of us to make sure that our state and federal environmental agencies hold the Michigan Department of Military Affairs to these promises."

As a footnote to Pete’s comments I would only now add that there is sufficient scientific evidence to show that toxic contaminants remain in the residues of propellants of rounds from military weapons. There was sufficient documentation in possession of the plaintiff at the trial but the Judge would not allow this documentation to be admitted as evidence. Since this information was available to the military, and since it could be presumed by a rational person that the military knew of even more evidence than that possessed by the plaintiff, one is led to the conclusion that the DMA lied to the court in the above assurances.

We now have even more knowledge regarding propellants when burned in gun tubes. We know more about the characterization of weapon propellants and it would appear to be impossible that all of the constituents are completely burned without a trace of residue, or as the military language puts it in their official environmental documents, "consumed in use." Because of this, at least one of the assertions of the military which allowed the MDMA to prevail in court, is false and has been false since it was made. Yes, I know your question. There has been no action by the Michigan DEQ because those involved with the Guard probably would also say that the toxic components are "consumed in use."

Moreover, I found the last assertion somewhat humorous. How does the MPRC result in less pollution and noise when the Guard asserted continuously in the years leading up to the lawsuit that there was no pollution on the tank range and that inert rounds were always used?

Developments on other firing ranges throughout the world including both active ranges and those under closure should eventually have an impact on the firing ranges at Camp Grayling and other active ranges. Military firing ranges at Jefferson Proving Ground in Indiana, Fort Ord in California, Vieques in Puerto Rico, Fort McCoy in Wisconsin, Camp Edwards at the Massachusetts Military Reservation on Cape Cod, Grafenwohr in Germany, the Western Training Center at Wainwright in Canada, the base at Valcartier in Quebec, and many others are polluted and undergoing serious review and possibly an expensive cleanup. (It is conservatively estimated by the military that it will take more than $300 million to clean up Camp Edwards.)

The developments at Camp Edwards have been the most interesting for us and will likely have the most serious impact at Grayling and other active military ranges. On April 10, 1997, the EPA suspended any military training at Camp Edwards, prohibiting any use of gunnery propellants and pyrotechnics at the Upper Cape base, maintaining that artillery, mortar, and small-arms firing at the base threaten public health and the ground water under the firing ranges. For over a year this order has been in contention by the military and Congress. To make a too-long story short, by June of this year it became clear that with detailed testing the impact area was polluted with explosive contaminants and so was the groundwater. Faced with overwhelming evidence the National Guard then agreed that high-explosive training, not just improper disposal of munitions, or the existence of unexploded ordnance, has played a part in the groundwater contamination, something that was long asserted over the past two years by the Environmental Protection Agency. Senator Kennedy, angered by the decades of environmental violations, asserted that "I am outraged that this environmental contamination was not prevented, or at least detected soon after it occurred. . . . It is unfathomable that such contamination could occur at the MMR without any regulatory or military agency being aware."

(If you want to read more about Camp Edwards and the controversy there just go to the Cape Cod Times web site at www.capecodonline/cctimes and search for "MMR" or "Camp Edwards.")

My question: Why Camp Edwards MMR? Why not Camp Grayling? The answer is not simple, nor is it comforting. But let me give you a few reasons that I think relevant.

The MMR has had a longstanding groundwater contamination problem. A Superfund cleanup is underway that involves eleven VOC plumes (from Otis Air Force Base on the MMR) and contamination at the range galvanized public sentiment against the ongoing military activity. On the other hand, Camp Grayling has had no egregious, well-publicized long-term history of known groundwater contamination. There has been some, such as the pollution from the small airfield north of Grayling and the dumping of raw sewage into the headwaters of the Manistee River. But there has been nothing like what has happened at Cape Cod.
There have been, for some time, going back more than a decade, epidemiological studies of high rates of cancers in communities surrounding Camp Edwards and MMR and there have been concerns about the effects of both air quality and groundwater contamination from activities at the military firing ranges. There have been no reports of high rates of cancer in connection with Camp Grayling, but neither, as far as I know, have there been any studies to determine such.
The representatives of Cape Cod have in the past been an outstanding Republican Governor who was truly environmentally oriented, two outstanding Democratic Senators, namely John Kerry and Ted Kennedy, and a strong Democratic Congressman, William Delahunt. Whom do we have to represent the Au Sable and Manistee Rivers? I really can’t name the congressman, Democrat or Republican. The senators are Abraham and Levin. Abraham: well, look at his record, it speaks for itself. Levin has an outstanding long-term environmental record, but he seems to have great love for the military and for pork at Camp Grayling -- and he wouldn’t know a trout if he stumbled across it. The Governor: what can I say about John Engler that hasn’t already been said? (If you’ve been a Riverwatch reader, you know we have said it all.)
The area surrounding the MMR is densely populated and overlies a single continuous aquifer, the Sagamore Lens, which has been designated a sole source aquifer serving more than 200,000 permanent residents and possibly more than 500,000 peak seasonal residents of Cape Cod. The area surrounding Camp Grayling is relatively sparsely populated. A petition for sole-source aquifer designation was never developed even though it has been suggested. There is some question that the aquifer affecting Camp Grayling would not meet the criteria for such a designation. However, I disagree; at least until I am given evidence to the contrary, and I have long asked for it. I think, however, that not requesting sole-source aquifer designation has been our biggest mistake over the past decade. The criteria do not and should not include any minimum population; it only requires that the aquifer be the only one available and that it be a community aquifer. I know of no other aquifer available to those living along the Au Sable North Branch and along the Mainstream. Possibly, one of our readers could enlighten us on this subject.
We all know that money and power reside at Cape Cod. Maybe if I had one or the other I would also reside there; I’ve been there many times and it was a lovely place. (But to be honest, I would greatly prefer the Au Sable.) Money and power do not exist in the Grayling-Lovells-Mio-Roscommon complex. Some money is certainly there but not power, and in either case, nothing like that at Cape Cod. Where there is money and power there will be action. Where there isn’t, there are inertia and apathy.
The training range and impact area for the MMR are directly above several wellhead protection areas on Cape Cod. It has sometimes been suggested that Range 40 at Camp Grayling does not intersect any such area at or near Grayling. Since I have often puzzled over what a wellhead protection area actually is, I suggest that this designation is a somewhat frivolous one. However, if a wellhead protection area is really what I think it is, then there are many candidates for wellhead protection areas near Range 30 and the many other firing ranges at Camp Grayling. In fact there are many candidates on the North Branch and the East Branch that lie close to Range 30.
Publicity! That’s the name of the game. Besides the Boston newspapers, there is an outstanding newspaper on Cape Cod. If you don’t believe me just go to its web site: www.capecodonline/cctimes/ and check it out. You won’t be disappointed. Well, what do we have? The answer: Nothing useful around Grayling and two defunct newspapers in Detroit.
There has been a regional planning agency looking at the potential for developing future water supplies on Cape Cod and it has found the aquifer affected by military activities to be very critical for future demands. The Michigan DEQ evidently believes there are abundant uncontaminated groundwater resources available to the Au Sable River communities and that even if the groundwater is contaminated by the firing ranges that fact would not affect drinking water supplies for the foreseeable future. My answer: I don’t believe it. But then I believe very little what the DEQ says. In any case has anyone who lives near the Camp Grayling complex seen such an analysis?
A master plan has been developed to assume control of the MMR for community expansion. At Camp Grayling there has been no such plan. I believe that this has had a big impact at Cape Cod. However, do we need a master plan to rid ourselves of pollution?
There is strong support from the local communities on Cape Cod, the Massachusetts Governor’s Office, and state and federal representatives for implementation of the EPA’s Order at Cape Cod. I would guess that there is mixed support for the termination of activities at Camp Grayling. There are those whose living seems dependent on the existence of Camp Grayling. There are others who are independent of the Camp. I suspect it’s pretty much a 50-50 split. But there also has been a strong alliance of local groups supporting Camp Edwards.

It may also be useful to finish our summary with some similarities of Camp Edwards and Camp Grayling:

They are both National Guard training sites even though Camp Edwards is a fraction of the size of Grayling. Moreover, Grayling has an intensity of training (which includes the amount of ordnance expended) over the years that is an order of magnitude greater than Edwards. Similar weapons are used except I don’t believe there are any tanks at Edwards.
They both have had a long history of use with Camp Grayling being a little older.
The soils are similar and so are the aquifers, i.e., the aquifers are shallow. However, the aquifer for the town of Grayling is deep but it is connected to the shallow aquifer. I am not really qualified to go further on this subject except to suggest there are undoubtedly many diverse aquifers or lenses that compose the complete hydro geologic system in the Grayling area, involving the Manistee and Au Sable headwaters.
As suggested earlier, both have had similar citizen constituencies that have lobbied heavily to keep the bases alive and expanding. One of the triggering items in the demise of Edwards was an attempt to expand it. This then led to it being investigated more thoroughly for contamination.
It was, probably even up to recent times, common practice to bury unspent shells or at least unused propellant bags at the ranges at both bases. (How do I know this? Because I was in the artillery on active duty at Fort Knox and in the reserves at Fort McCoy and I saw this happen, and sometimes participated. I also have talked to former Guard officers who did the same at Camp Grayling. At Edwards, many buried sites have been found.)

So there you have it: my cursory analysis of why Camp Edwards is being cleaned up, and why the military encampment at the headwaters of the best two trout streams east of the Mississippi is being ignored and allowed to fire lead into berms and toxic waste into the soil and forests that nurture these waters. I have undoubtedly missed some points and probably have misstated some. I would hope our readers will set us straight. You will notice that I have asked a lot of questions. Do any of you have the answers?

With your permission I will continue with the next issue of The Riverwatch and give you additional analysis and opinions. RWOL

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