Early Property Transfer and Privatized Cleanup at Former Military Bases The McClellan Air Force Base Experience Kathleen Johnson, Federal Facilities and Site Cleanup Branch Chief US EPA Region 9
Traditional Process: DOD cleans up a site with EPA and State oversight under an FFA. Privatization: DOD funds a private party to conduct the cleanup. EPA and State oversee the work through an enforceable document. The FFA is held in abeyance. Privatization Paradigm
Privatization Potential Benefits Environmental Cleanup that is: Faster Cheaper More Efficient
Privatization The Challenges Novel approach Accurate assessment of cleanup costs, resolving the financial package Balance risk priority sites with development priority sites Legal and technical staff resource intensive Coordinating multiple CERCLA processes at one site
Privatization The Players US EPA DOD – Air Force, Army, Navy Department of Toxic Substances Control Regional Water Quality Control Board LRA – Sacramento County or other government entity Developer – McClellan Business Park
Privatization Reassigned Roles and Responsibilities Air ForceEPA/State MBPLRA
Privatization Reassigned Roles and Responsibilities Air ForceEPA/State MBPLRA 3. ESCA 2. AOC and SOW 5. Comfort Letter 1. FFA Amendment 4. Contract
Privatization Property Transfer Air ForceEPA/State MBPLRA 3. ESCA 2. AOC and SOW 5. Comfort Letter 1. FFA Amendment 6. FOSET 7. Land Use Covenant 9. Deed 8. Deed 4. Contract