State Action Plans Capture Environmental Liabilities

An agency of the Department of Interior, the Bureau of Land Management (BLM) manages approximately 245-million-acres of land and 30 percent of the nation’s minerals in the west and southwestern portions of North America, as well as Alaska. Its key responsibilities include oil and gas wells, dams, livestock grazing, timberlands, wilderness, national monuments, and conservation areas. It also provides significant access for military training and mining activities of other federal users.

Historically, both the Department of Defense (DOD) and Department of Energy (DOE) have used and leased land from BLM to support military training activities or mining activities for minerals. Current defense agencies conducting restoration activities on BLM land include the U.S. Army Corps of Engineers, Army National Guard, Army Installation Management Command, Air Force Civil Engineer Center, and Naval Facilities Engineering Systems Command.

These training and mining activities also have created environmental liabilities that require restoration of the lands. Additionally, through its historical missions and operations, the bureau has created or assumed environmental liabilities that require active restoration.

To address these concerns, BLM identified a need to support each state’s respective field, district, state headquarters, and center managers in providing better visibility and a common operating picture that documented the status and budget for active environmental restoration projects and activities. Additionally, the bureau needed better visibility on the status, budget, and cleanup decisions and actions for DOD and DOE restoration activities on which it was a stakeholder or partner.

As result, an opportunity emerged to take advantage of a process utilized by Army Environmental Command to manage environmental liabilities. Working with the Omaha District of the U.S. Army Corps of Engineers, BLM crafted a scope of work that used the Installation Action Plan process to develop state action plans (SAPs) that would be specifically tailored to its environmental restoration budgeting and cleanup programs.

PUTTING PLANS IN ACTION

The goal of SAPs is to assist managers with long-term budgeting and planning for the remediation of contaminated sites as well as provide situational awareness of environmental restoration activities being performed by other government agencies on BLM land. SAPs are designed to integrate and coordinate with BLM headquarters and external stakeholder efforts in achieving environmental restoration goals and costs-to-complete.

SAPs are modelled after the Army’s Installation Action Plans, which provide an overview of site cleanup status, a phase schedule for either the Comprehensive Environmental Response, Compensation, and Liability Act or the Resource Conservation and Recovery Act, an estimated cost-to-complete budget, and future phases/budget by fiscal year that require execution. In addition to phase schedule/budgets, the action plans identify stakeholder (regulator, other federal agency, public, and tribal) issues on the remedy for cleanup projects.

A similar process will be used to develop state-specific SAPs and assist BLM with developing guidance to issue to the field, district, state headquarters, and management centers. This guidance will be a tool to improve environmental compliance and engage federal, state, and tribal stakeholders and the public on cleanup and associated planning and coordination activities.

BUDGETING AND PLANNING

The goal of SAPs is to assist managers with long-term budgeting and planning for the remediation of contaminated sites as well as provide situational awareness of environmental restoration activities being performed by other government agencies on BLM land. SAPs are designed to integrate and coordinate with BLM headquarters and external stakeholder efforts in achieving environmental restoration goals and costs-to-complete.

Over the next two years, the team will prepare and execute a number of activities to further develop SAPs.

• Review and extract needed information from databases such as the Abandoned Mine and Site Cleanup Module, the Department of the Interior Environmental Disposal and Liabilities Database, the Department of the Interior Locations of Concern Database, and the Central Hazardous Materials Fund Database.
• Conduct a workshop and pilot SAP for Utah.
• Develop and track restoration requirements in support of annual work planning, programming, and budget execution system to support BLM’s programming of budget requirements.
• Host a Technical Project Planning session to identify key stakeholder input to support the development and implementation guidance associated with SAPs.
• Develop state-specific workshops to generate and update state-specific SAPs for Alaska, Washington, Oregon, California, Nevada, Arizona, New Mexico, Utah, Idaho, Montana, Colorado, and Wyoming.
• Develop a contract action plan to support restoration program management and better visibility on restoration budgeting requirements and track BLM’s overall environmental liability.

BETTER OPERATING PICTURE

SAPs will provide the bureau with a better common operating picture in each state on active restoration activities as well as other federally led restorations being conducted on its lands.

With many agencies from DOD and DOE conducting restoration activities on BLM lands, it can become unclear as to what role the bureau plays as a stakeholder for each project and which offices and level of involvement should be engaged. While DOD and DOE agencies executing restoration projects on BLM land do initially reach out to in an attempt to coordinate, these approached offices do not always know that they should participate or coordinate with the BLM headquarters representatives.

SAPs will attempt to identify the federal entities by BLM state office and engage the project and program managers to provide status updates as well as open lines of communications. With the SAP being a living document, all BLM offices will have a better common operating knowledge on who is doing what in the state and which offices should be involved and providing input.

SAPs will provide the bureau with a better common operating picture in each state on active restoration activities as well as other federally led restorations being conducted on its lands. They also will provide the necessary restoration budget data and requirements data to better support planning, programming, and budget execution, serving as a valuable tool to inform senior leadership on the scope of environmental liabilities across the portfolio.

Col. William Myer, PG, M.SAME, ARNG (Ret.), is Vice President, Business Development/ Program Manager, GSI North America Inc.; wmyer@gsisg.com.

Dee Lloyd, PG, is National Program Lead, Abandoned Mine Lands & Hazardous Materials, Bureau of Land Management; dlloyd@blm.gov.

Adam Plack, P.E., is Program Manager, USACE Omaha District; adam.r.plack@usace.army.mil.

[This article first published in the January-February 2021 issue of The Military Engineer.]