Your knowledge of basic environmental laws and your role as PAO in supporting your command's efforts is critical to your ability to support your command's public information efforts.
If you have ever worked on an environmental issue affecting your base, post or station, you know that it may become a topic of high interest to the local and regional media—and may sometimes become a national issue. If you haven’t been involved with environmental issues, you need to prepare yourself to deal with them at some point in your career.
The issues are diverse, ranging from water pollution, to land use, to wildlife preservation and protection, forest fire management and scores of other “green” issues.
Environmental Issues & Public Affairs
This course of instruction is designed to prepare you to understand your role as a public affairs officer in support of the National Environmental Policy Act (NEPA) and other laws on DOD environmental projects, administered under:
● DOD Environmental and Occupational Health Network and Information Exchange (DENIX)
● The Defense Environmental Restoration Program (DERP),
● The Installation Restoration Program (IRP),
● The Military Munitions Response Program (MMRP), and● The Base Realignment and Closure (BRAC) Program.
Key Environmental Laws
The National Environmental Policy Act of 1969 made your knowledge of key environmental laws and your role as a PAO a critical factor in how well equipped you are to support your command's public information efforts.
A frequently occurring environmental issue many military facilities deal with is the potential for groundwater contamination. Take a moment to look at a website with information about the impact of ground water contamination at Camp Edwards, Mass. http://mmr-iagwsp.org/
Similar issues that you can look up involve the childhood leukemia clusters near Naval Air Station Fallon, Nev., in the early 2000s, or long-term issues with marine mammals and U.S. Navy training at sea.
You will find a copy of Key Environmental Laws located in your lesson’s additional resources folder.
This document provides more detail than the description of specific environmental laws here, which is abbreviated so we may focus the lesson more on PA issues.
National Environmental Policy Act
The National Environmental Policy Act is the basic national charter for protection of the environment.
Its basic policy is to assure that all branches of government give proper consideration to the environment prior to undertaking any major federal action that significantly affects the environment.
NEPA established the United States' national environmental policies. It was the first major environmental law in the U.S. and is often called the Magna Carta of environmental laws.
NEPA requires federal agencies to integrate environmental values into their decision making processes by considering the environmental impacts of their proposed actions and reasonable alternatives to those actions.
To meet NEPA requirements, federal agencies prepare a detailed statement known as an
Environmental Impact Statement). The EPA reviews and comments on EISs prepared by other federal agencies, maintains a national filing system for all EISs, and ensures that its own actions comply with
NEPA.
The Resource Conservation and Recovery Act RCRA gives the EPA the authority to control hazardous waste from the "cradle-to-grave." This includes the generation, transportation, treatment, storage, and disposal of hazardous waste.
Comprehensive Environmental Response Compensation & Liability Act
CERCLA provides a federal "Superfund" to clean up uncontrolled or abandoned hazardous-waste sites as well as accidents, spills, and other emergency releases of pollutants and contaminants into the environment.
Through CERCLA, the EPA was given power to seek out those parties responsible for any release and assure their cooperation in the cleanup.
Defense Environmental Restoration Program (DERP)
DERP includes all environmental restoration activities undertaken by a DOD Component (DODM 4715.20, pp.
15, 16) such as remediation and cleanup of contamination from hazardous substances and pollutants or contaminants; correction of other environmental damage that creates an imminent and substantial endangerment to the public health or welfare or to the environment; demolition and removal of unsafe buildings and structures.There are three categories of environmental restoration at DOD sites within DERP: Installation Restoration Program (IRP), Military Munitions Response Program (MMRP), and Building Demolition/Debris Removal (BD/DR).
DENIX
DOD Environment, Safety and Occupational Health Network and Information Exchange An essential resource for PAOs is the DOD Environment, Safety and Occupational Health Network and Information Exchange. DENIX may be found at http://www.denix.osd.mil/.
Each year, DOD submits an Annual Report to Congress on its Defense Environmental Programs.
The report describes the DOD's accomplishments during the past year in its restoration, conservation, compliance, and pollution prevention programs.
It does this by addressing plans and funding needs for protecting human health, sustaining the resources DOD holds in the public trust, meeting its environmental requirements, and supporting the military mission.
The report also details DOD's efforts for reinforcing environmental programs to ensure the safe and effective use, protection, restoration, and preservation of the Department's natural and cultural assets.
Additionally, it examines DOD's environmental restoration activities at sites on its active and Base Realignment and Closure installations and former properties.
Why do you suppose that it is so important for PA personnel to be aware of environmental regulations?
Simply because every post or station has environmental concerns that are important to the local community, to the region—and possibly to the nation as a whole. You must be knowledgeable about environmental issues, funding, laws and practices if you are to be an effective spokesperson for your command.
Now, let’s take a look at what your role as a PAO will be in regard to NEPA.
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PA Role in the NEPA Process
The NEPA Process
Environmental issues will be a significant concern to your commander, and they will be a significant priority for you as you plan your communications plans to support the commander’s intent to
accomplish your unit’s mission. To do that, you need to understand the NEPA process.
A key part of any successful environmental
program is the environmental team, which includes the installation commander, the installation
Environmental Quality Control Committee, senior representatives from tenant activities, and other specific members, such as:
● Environmental coordinator;
● Director, plans, training and mobilization;
● Director of public works;
● Director of logistics;
● Legal advisor;
● Post management coordinator;
● Preventive medicine activity;
● Public affairs officer;
● Safety officer; and others as required.
The environmental management team is the standard bearer for the integration of environmental values into your command’s mission to sustain readiness, improve quality of life, strengthen community relations and provide sound stewardship of your installation’s resources.
PA’s Role
You will serve as a contributing staff member to planning and decision-making. You will also manage all aspects of your command’s public communication, including command information, public information and community engagement activities.
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PA Role in the NEPA Process (continued)
Commander's Role is essential for a strong installation environmental program.
Regular meetings between the commander and the environmental management team can demonstrate command emphasis and serve to nourish and encourage a healthy environmental program.
The environmental management team—of which you as the PAO are a core member—should
regularly brief the commander on specific installation environmental issues.
Categorical Exclusion (CATEX)
Some activities have minimal environmental impact.
Service headquarters maintains a list of these activities to avoid the need to repeatedly assess their impact. These include routine grounds or facilities maintenance. However, CATEX cannot be applied to operations or maintenance in environmentally sensitive areas such as wetlands or estuaries. Here are a few examples of different types of NEPA scenarios:
Scenario 1: The existing runway needs to have the centerline repainted. Will there be a significant environmental impact? Not really. Painting is normally considered routine maintenance, and so can be “Categorically Excluded” from the NEPA process.
Scenario 2: The existing runway needs to be repaved. Will there be a significant environmental impact? Well, we’re not sure, so let’s do an
Environmental Assessment. An internal review finds there will be no significant environmental impact, so a
“Finding of No Significant Impact,”
FONSI, is published in the Federal Register for 30 days. If there are no objections, the installation can begin the paving project.
Scenario 3: The installation wants to lengthen the runway by 1,000 feet and there are woods, wetlands and marshes at the end of the existing runway where we want to put the extension. Can we do a Categorical Exclusion? No. First, it’s not just routine maintenance. Second, it involves sensitive
environmental areas, which cannot be categorically excluded. Significant environmental impact caused by the runway may require the installation to complete an Environmental Impact Statement. For you as a PAO, that means public meetings, hearings, comment periods and possibly court challenges to both the draft and the final EIS.
Working with the Community
Typically, the public becomes involved in environmental issues when they feel left out of the decision-
making process. Offering citizens some part in the environmental process may avoid delays of your command’s projects.
It may also be a good strategy to offer interested groups and other stakeholders an opportunity to participate in the process.
You should be aware that adverse public reaction may tie up technical resources and expertise that should be dedicated to accomplishing the environmental tasks.
Experience shows that a progressive and successful program helps move a project forward.
All of these activities should be managed by you as the PAO in close coordination with other members of the environmental management team.
It is your responsibility as the command’s PAO to identify issues and to prepare communication plans that address public involvement considerations associated with environmental programs.
PA Role in the NEPA Process (continued)
First, you must understand that public information is one-way communication with the public that conveys information about decisions and events to interested people. It relays news to the public using such tools as press releases, fact sheets, newsletters and electronic and print media. Public information is founded on the basic principle that the public must have access to information to be responsible, informed citizens.
On the other hand, public education is explicitly aimed at reaching public audiences with carefully crafted materials or performances that make people think. By pulling public audiences into active consideration of a problem, public education points the way for people to devise actions that will address a particular problem or set of problems.
Understand that the environment belongs to
everyone. Your role as PAO is to know the difference between public relations and public involvement.
Public involvement is the process of seeking out, considering and addressing public opinions and a range of public perspectives in the decision-making process. It emphasizes citizen participation in the formation of public policy or in site-specific decisions.
In contrast to public relations, which promotes and or sells a product or idea, public involvement is the process by which interested parties have structured opportunities to actively influence the direction of technical or analytical work at the key decision points in the life of a project .
Public relations involves promotional work to gain favorable responses to particular products or points of view.
Tips for success
● You must understand that the average citizen distrusts the government's representation of issues, so openness and honesty are crucial.
● Do not take criticism personally.
● Establish an expert contact, preferably in the PA office.
● Invite comment, even from potential opponents.
● Strive for objective and accurate, but not necessarily positive, news coverage.
● Never release information selectively or stretch the truth.
● Maintain current fact sheets and question-and-answer papers.
● Provide any requested information as soon as possible.
● Don't be afraid to say, "I don't know." Be prepared to explain why you don't and search for answers as appropriate.
● Offer briefings, site visits, and tours of your facility, consistent with safety protocol.
● Publicize internal and external environmental awards to recognize excellence and inform the public of specific positive actions.
(Installation Environmental Program Management Guide. (2002). U.S. Army Environmental Center, pp.
33-34.)
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PA Role in DERP and IRP
The Defense Environmental Restoration Program and The Installation Restoration Program
You have seen the role that you will play in NEPA as your command’s PAO. Now, let’s see how your role may change when you are supporting DERP, and, specifically, the IRP process.
You will find that your role as a PAO will not be very different for DERP and IRP when it aligns with NEPA.
You will not only need to reinforce the communication requirements for the overall NEPA process, but also address DERP’s needs, which you’ll find outlined in DODM 4715,20, pp. 81, 82, which says:
● DOD shall involve the local community in the environmental restoration process as early as possible and shall seek continued community involvement throughout.
● The DOD component shall ensure opportunities for public review and comment on proposed RCRA corrective actions, which includes developing a community engagement plan.
● You should ensure that the command point of contact for environmental issues, who serves as the
entry point for community inquiries or comments, is identified to the local community, perhaps through a newspaper notice and on the command web site. Also, ensure that the contact information for the public affairs office is publicized.
● Information on environmental restoration activities shall be made available to the public in a timely manner, as provided for in a community engagement plan. However, where litigation exists involving environmental restoration activities, the DOD component legal staff shall be consulted on the
appropriate or required means for providing documents to the litigating party or the public.
As you can see, as the PAO you must be actively engaged with your command’s staff on executing an environmental restoration program. DOD component guidance for an installation’s action plan typically emphasizes the importance of command elements relying on input and feedback from environmental, legal and public affairs. Your challenge will be to use “best practices” to engage the staff in order to achieve your commander’s communications priorities.
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Conclusion
Your mission during this training module was to understand and explain your role as a public affairs officer as it relates to the National Environmental Policy Act and the Defense Environmental
Restoration Program. When you assume your role as a public affairs officer, you will face a spectrum of issues that shape public communication. One category of issues that evokes a spectrum of emotions and legal ramifications is the environment.
The more you understand basic environmental regulations and policies, the better you will be able to focus your PA efforts to shape positive public communication on the topic at hand.
References and Additional Resources
Defense Environmental Restoration Program (DERP) Management. (2012). Department of Defense 4715.20 A Citizen's Guide to the NEPA: Having Your Voice Heard. (2007). Council on Environmental Quality, Executive Office of the President
Key Environmental Legislation
Key Environmental Legislation Vocabulary
Summary of the Resource Conservation and Recovery Act. Retrieved from http://www.epa.gov/lawsregs/laws/
rcra.html
Resource Conservation and Recovery Act (RCRA) Enforcement. Retrieved from http://www.epa.gov/compliance/
civil/rcra/index.html
Summary of the National Environmental Policy Act. Retrieved from http://www.epa.gov/lawsregs/laws/nepa.html Summary of the Comprehensive Environmental Response, Compensation, and Liability Act (Superfund).
Retrieved from http://www.epa.gov/lawsregs/laws/cercla.htm
Military Munitions Response Program (MMRP). Retrieved from http://aec.army.mil/usaec/cleanup/mmrp00.html DOD Financial Management Regulation, Volume 2B, Chapter 13
Army Defense Environmental Restoration Program: Management Guidance for Active Installation (2004).
U.S. Army Assistant Chief of Staff for Installation Management
Installation Environmental Program Management Guide. (2002). U.S. Army Environmental Center
