1. DoD Relative Risk and Indian Lands
March 2000
Environmental Security -- Defending Our Future

2. Environmental Security -- Defending Our Future
Purpose
Provide information on DoD programs using risk based analysis in decision-making
Show how we are modifying our programs to consider tribal unique factors in decision-making
Environmental Security -- Defending Our Future

3. Environmental Security -- Defending Our Future
DoD Programs
Active Installations (IRP)
Base Realignment and Closure Installations (BRAC)
Formerly Used Defense Sites (FUDS)
Native American Lands Environmental Mitigation Program (NALEMP)
Environmental Security -- Defending Our Future

4. Environmental Security -- Defending Our Future
For IRP, BRAC, & FUDS:
DoD uses relative risk methodology—
to evaluate the relative risk posed by a site in relationship to others based on:
Source of Contaminants
Pathways of Contaminants
Receptors of Contaminants
Environmental Security -- Defending Our Future

5. Environmental Security -- Defending Our Future
Site Evaluation Framework is a Method for Placing Sites into Relative Risk Categories
It evaluates source, pathway, and receptor relationships in:
Groundwater (human endpoint) Surface water (human and ecological endpoints) Sediment (human and ecological endpoints) Surface soils (human endpoint)
Contaminant Hazard Factor (CHF) How high are contaminant concentrations relative to standards?
Migration Pathway Factor (MPF) Is the contamination moving or likely to move?
Receptor Factor (RF) Are there humans or sensitive environments affected or potentially affected by the contamination?
Based on:
Environmental Security -- Defending Our Future

6. Relative Risk Site Evaluation Concept Summary
Sites at each Installation
Sites
Data Assembly
Source
Pathways
Receptors
Evaluation Factors
Contaminant Hazard Factor
Mitigation Pathway Factor
Receptor Factor
Medium
Relative Risk Categories
High
Low
Stakeholders
Environmental Security -- Defending Our Future

7. FUDS on Indian Lands Based on Relative Risk
million
million
Environmental Security -- Defending Our Future

8. Funding Trend on Indian Lands
Environmental Security -- Defending Our Future

9. Why are proportionately less funds going to Indian Lands?
High priority sites under relative risk have already been addressed
Most sites are located in rural areas
Lower public participation in decision-making
Environmental Security -- Defending Our Future

10. Why are proportionately less funds going to Indian Lands?
Scientific approach does not fully consider tribal unique factors
Methodology pre-dates DoD policy
Does not fully consider indirect impacts to tribes
Environmental Security -- Defending Our Future

11. Environmental Security -- Defending Our Future
How Can We Change?
Signs of change: Nov 1998 DoD policy --Trust Responsibilities --Government-to Government Relations --Consultation --Natural and Cultural Resources MOU’s with tribes, Training,Tribal liaisons Contracting and procurement initiatives
Environmental Security -- Defending Our Future

12. How Can We Change? NALEMP—Congressional Action
Provides“… not less than $8,000,000 shall be made available only for the mitigation of environmental impacts … on Indian lands resulting from DoD activities.”
Environmental Security -- Defending Our Future

13. Setting Priorities Health, Safety, & Environment Relative Risk
UXO Risk Assessment
Abandoned Building and Debris 2

14. Setting Priorities Life-ways Economic Programmatic
Impacts and access to traditional and subsistence items
Economic
Access to natural resources for commercial use
Access to land for development
Programmatic
Impacts to Tribal Programs
Leveraging Opportunities 2

15. Environmental Security -- Defending Our Future
Indirect Impacts
As part of the DoD’s trust responsibility we are trying take in to account the indirect impact to health, safety, and environment ….
Environmental Security -- Defending Our Future

16. Environmental Security -- Defending Our Future
Indirect Impacts ...
Example 1
Tribe must spend money to secure abandoned DoD buildings adjacent to tribal housing to prevent injuries to children playing around them … as the result of spending this funding the tribe can not upgrade drinking water system
Environmental Security -- Defending Our Future

17. Environmental Security -- Defending Our Future
Indirect Impacts ...
Example 2
Former practice bombing range prevents the tribe from pursuing an economic activity on affected trust lands … loss of revenue prevents tribe from developing additional housing for tribal member
Environmental Security -- Defending Our Future

18. Environmental Security -- Defending Our Future
Indirect Impacts ...
Example 3
Tribal elders belief that local fish are contaminated with PCBs results in their abandoning their traditional diet resulting in an increased rate of heart disease and diabetes
Environmental Security -- Defending Our Future

19. What’s in the future? Implement Congressional direction
Implement DoD policy
Trust Responsibilities
Government to Government Relations
Consultation
Natural and Cultural Resources
Increase Consideration of Tribal-Unique Factors
Maintain the Native American Environmental Tracking System 2

20. Native American Environmental Tracking System
Track impacts to Indian lands
Track mitigation activities
Set funding priorities
Track resolution of DoD–tribal issues
Environmental Security -- Defending Our Future