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FOCC asks Clark County to take important steps in management of Camp Bonneville

May 10, 2024 in Accountability, Climate Change, Parks, Trails, & Open Spaces, Rivers, Lakes & Aquifers

FOCC asks the County to permanently close the Camp Bonneville shooting range, establish a permanent Camp Bonneville Citizens Advisory Group (CAG), and establish a Camp Bonneville Safety Evaluation Panel (SEP) which will allow the county to regain control of and properly manage the property in order to protect the health, safety, well-being, and interests of its citizens.

Following is our justification for these actions based on the record, which we will present in 2 sections discussing the issues surrounding both the shooting range and the cleanup/general management of Camp Bonneville:

I. Permanently close the Camp Bonneville shooting range. 

The ongoing use of the Camp Bonneville shooting range conflict with the federal restrictions of the conservation conveyance and deed restrictions that govern the Camp Bonneville transfer (Quitclaim deed, MOU, EPA study in 2003 Reuse Plan). These actions have jeopardized the proper cleanup of Camp Bonneville.

Public records of communications between staff, the FBI, and Clark County Sheriff’s Office (CCSO) show years of apparent violations of the FBI and CCSO shooting range agreement. Staff has been alerted that the Oregon FBI and CCSO activities continue to contaminate this property. These actions contradict the county’s efforts to simultaneously review the cleanup of Camp Bonneville to determine further needed restoration of the property from its history of use as a military training facility.

Some of the most concerning revelations from public records include:

        1) The Oregon FBI agreement expired in Dec, 2022. Despite this, the FBI and other law enforcement units (such as the Portland Police Graffiti  Squad) have continually used many areas of the property primarily for SWAT team training. Since the FBI does not provide Clark County documentation of its use of the property, it is unknown how many other law enforcement entities have been allowed by the Oregon FBI to use the property. This, again, creates potentially serious liability and security issues. 

        This also means that Clark County citizens are bearing the financial and liability burdens of Camp Bonneville while a federal agency uses the property however they wish, for free while negotiations for use of the property have dragged out.

       2) The original Camp Bonneville Reuse Committee, including a private contractor and a separate subcommittee on the range, concluded that the current range was wholly inappropriate, citing health and safety issues. It proposed some options to move a range or ranges to the south. The FBI agreed to move the range but did not, and instead expanded the range and increased use. This is inconsistent with the information and the characterization of the Reuse Plan provided at the FBI shooting range meeting.

       3) The Oregon FBI has invited law enforcement organizations (LEOs) from over 100 agencies to use the property since 2012. Some question whether the term “guests” implies that the FBI has the authority to allow other organizations to use Camp Bonneville for training. More importantly, the FBI has maintained no records of law enforcement activity, thus the county has no information to assess the FBI’s liability for future remediation.

       4)  Law enforcement has conducted activities and operational training outside of the 450’ x 600’ footprint allowed under the FBI agreement, including unknown areas (not the range) for night training, canine training (including in the creeks and sensitive wetlands), and long-range shooting (referenced in public records correspondence). This is inconsistent with the characterization of the Oregon FBI as a “good tenant” at the March 6, 2024 Council Time briefing on the FBI shooting range. Records show staff was alerted that numerous activities were continually taking place outside of the shooting range.

       5) Public records show that staff has reminded unauthorized individuals about the terms of the agreement for alleged violations of the agreement on multiple occasions.

       6) It appears that the FBI refused a lawful records request by a Clark County citizen to provide information from the Camp Bonneville entry logs. It also appears the County has no control over who accesses Camp Bonneville and has no way to determine if a person entering the property ever leaves. The Oregon FBI controlling access to this Clark County property is not specified in any agreement and raises huge liability and security concerns. 

       7) According to several residents, the FBI uses the property even when the state has closed all state forests due to heightened wildfire risks, putting the citizens of Clark County who live near the property in danger. Use of firearms in forests is a wildfire risk. (US Forest Service: Hot undercarriages of vehicles parked during times of heightened wildfire risks can also start a fire. (US Forest Service,

       8) The range is dangerous. Twenty five years of lead pollution has never been cleaned up, and the shooting range agreement along with the records indicate that the FBI should have cleaned up the range when it was closed in 2011. This never happened.

       9) Firing weapons that are not in compliance with the limitation to “small arms”, including at least one instance of the detonation of an explosive device by CCSO, that occurred without serving notice to nearby residents and in which a resident alleged it “shook” their house. On this occasion, a staff member simply okayed the use of detonations going forward as long as notice was given, even though this activity is outside the terms of the agreement and the restrictions of a natural resource reserve. (From public records communications)

The County can address these matters and get the management of Camp Bonneville back on track. Many of these issues have been raised for years but have gone unaddressed, even as the FBI and CCSO have continued activities for 2 years without a contract—again, raising potential security and liability concerns. Non-enforcement of county agreements, permitting use without an agreement in place, continued contamination, and inadequate management of the many facets of this property can stop with this Council.

FOCC has found a lack of transparency and a lack of cooperation with the public in Clark County’s Camp Bonneville cleanup review process and in the briefing on renewing the shooting range contract. 

Among the concerns raised in our previous letters regarding Camp Bonneville, one issue remaining is the refusal to share written public comment about Camp Bonneville with the public, the Camp Bonneville Community Advisory Group (CAG), or Council. FOCC and others have repeatedly requested written public comment sent to the email address be made publicly available. Staff have refused to do so, have offered no justification, nor acknowledged the request. 

According to public records, many emails were sent to staff but not councilors. These emails contain the aforementioned issues regarding the FBI’s tenancy at Camp Bonneville, as well as the conflicts of operating a shooting range on a conservation property. The records show that staff were made aware but did not disclose this information to the elected members of Clark County or the public during their briefing, and in fact described the FBI as a “good tenant” and the shooting range consistent with the transfer restrictions. As a result, the Clark County Council did not have all relevant information nor correct information available to them from which to base their decisions.

Use of the facility by the Oregon FBI has no clear benefit to the residents of Clark County. The Portland Division of the FBI is responsible for Oregon, not Washington state. The Portland FBI and CCSO have other, more appropriate options for firearms training than a property that is restricted by the conveyance to be used for the conservation of natural resources. Given the potential liability issues related to UXO, contamination and wildfire risks, allowing the FBI to use this property rent-free is a disservice to county residents.

CCSO has its own concerns about use of Camp Bonneville. Public records show that the CCSO, a county agency that does provide a direct benefit to the people of Clark County, have been hindered in conducting state mandated training activities by the shared use of the range with the Portland FBI, have been unhappy with the lack of maintenance of the facilities, are concerned with the location because of its disturbance to residents, and are concerned with the unsafe condition of this facility since the range’s berm does not meet established safety standards. Lead contamination at this range has never been remediated, risking the health and well being of law enforcement officers who use this facility. CCSO has expressed in communications they would rather the county locate them somewhere more suitable for their activities.

The FBI contract is in direct conflict with the county’s plans for the property. Issuing a new contract does not fit with the county’s own goal of closing out the cleanup for this property, as the continued operation of the range will not allow for the Ecology closeout of the cleanup.

II. Establish a permanent Camp Bonneville Citizens’ Advisory Group (CAG)  and Safety Evaluation Panel (SEP)

FOCC has no confidence in a Camp Bonneville cleanup review that dissolves the CAG and is managed without any public input. We instead implore the Council to constitute the CAG as a standing citizen’s advisory group, and extend the terms of current CAG members to demonstrate the County’s commitment to appropriately managing the many unique and important issues this property poses other than only the cleanup. Mounting instances of false information, lack of expertise, and a conflict of interest clearly show that the County needs a new approach.


Perpetuating misinformation about the property means Council is basing its decisions on an erroneous characterization of the property. This is also a disservice to the public that may also complicate the County’s liabilities for this property. Following is a chart of false information provided by staff to the Council and public regarding Camp Bonneville in the last few months:

False Statement When/Where Facts/Full Context Source Outcome
The FBI was paying $150,000 a year to rent the Camp Bonneville shooting range (which would have amounted to $1.2 million in revenue since 2012).  March 6, 2024 briefing to council during Council Time FBI pays no rent to the people of Clark County Internal staff memo, former FBI contract Council directed staff to draw up a new FBI shooting range contract at Camp Bonneville.
Camp Bonneville is a parks conveyance (implies that it must be used for a public park) March 20, 2024 Camp Bonneville CAG Meeting Camp Bonneville is a conservation conveyance (conveyed and must be used for the purpose of conservation) Deed, MOU, and several presentation documents presented to previous commissioners  Camp Bonneville is included in the PROS Plan, staff basing cleanup review on incorrect information
Central Impact Target Area (most dangerous 572 acres of Camp Bonneville (CITA) was cleaned, including both surface and subsurface January 10, 2024 briefing to Council 455 acres of the CITA were not cleared in any way (Only 20% of the CITA has been cleaned). Ongoing sitewide groundwater issue, deteriorated roads and trails, 2,900 acres have not been surveyed. Site-specific final report Central Impact Target Area and Northern CITA expansion, January 2021 Public and Council likely have a belief that Camp Bonneville is safe and adequately cleaned up based on the erroneous characterization of the cleanup.
FBI has been a “good tenant”. March 6, 2024 Council Time *See aforementioned documentation of the FBI operating outside of agreement terms. *See aforementioned documentation of the FBI operating outside of agreement terms. Council directed staff to draw up a new FBI shooting range contract at Camp Bonneville, and continued contamination of the property, uses outside of allowed uses.
FBI mentioned 47 times in the Reuse Plan March 6, 2024 Council Time Omissions: the Reuse Plan notes that the current range would have to be moved and that the FBI agreed. The plan also discusses how the FBI use of the property would have to be restricted to less than 6 months to allow other uses (that is the range is not compatible with other uses). Some mentions of the “FBI” explicitly do not support maintaining a firing range at CB.
Additionally, the 2003 version of the Reuse Plan includes several extensive studies of problems associated with the current firing range, and the EPA study explicitly states that firing ranges are incompatible with conservation uses of a property.
Reuse Plan Council directed staff to draw up a new FBI shooting range contract at Camp Bonneville, and continued contamination of the property, uses outside of allowed uses.
When asked directly by a council member responding to constituents whether or not the shooting range was “incompatible with the conservation transfer documents (referring to the conservation conveyance),” staff responded about documents other than the conservation conveyance, giving the impression upon playback that the conservation conveyance allowed a shooting range. March 6, 2024 Council Time Firing ranges are incompatible with conservation uses of the property. 2003 Reuse Plan Council directed staff to draw up a new FBI shooting range contract at Camp Bonneville, and continued contamination of the property, uses outside of allowed uses.
County has a recent building permit for an old building at Camp Bonneville April 16, 2024 Council Time No such building permits exist Public records correspondence between county public records department and Clark County citizen Council authorized use of Building T-1980 for residential use by 7 Department of Natural Resources (DNR) employees while there is no occupancy permit for this building, and most concerningly this building has no potable water, has structural deficiencies, and has a failing septic system that is out of compliance with the health code.

The sheer number of instances of misinformation presented about Camp Bonneville to Council in the last few months and the public is serious and dangerous, resulting in real life risks to the safety and well-being of Clark County citizens (and in one instance, DNR employees), liabilities to the County, as well as eroding the public trust.

Lack of expertise. The Washington Department of Ecology (DOE) has reminded the county that there must be some staff who have UXO certification. If the county wants a true evaluation of the integrity of the cleanup, then approaching this review without a single unexploded ordnance (UXO) expert involved is, quite frankly, irresponsible given the stakes to public health and safety. Did the county ever look to hire a UXO expert as the property manager for this review, and if not, why not? 

Public records show that in January of this year, staff stated in an email to a citizen: “You are correct that we do not have a Level I certified UXO Specialist. We have identified a program and will be sending a staff person in April 2024. An additional staff person is planned to attend training in 2025.” A Level I certified UXO Specialist is the minimum level of training. Anyone with this training would still require oversight by a UXO Qualified Person who has many additional levels of training and years of supervised experience. It is May, so has this training begun? Why did this training not take place prior to starting the cleanup review? 

Conflict of interest. Assigning a staff member to lead this process who is a long-time and current member of the U.S. Army Reserve is a plain conflict of interest when the Army is the institution that would foot the bill for more cleanup should Clark County find that more cleanup is necessary. This person has no relevant expertise that could possibly justify ignoring this conflict of interest. Working for the Army for 16 years and familiarity with using weapons does not equal understanding of environmental contamination and cleanup of Base Realignment and Closure (BRAC) sites. 

FOCC believes that based on these facts, a cleanup review of Camp Bonneville performed and a report presented to Council without a CAG process or UXO experts on hand would not be accurate, which could create lasting liabilities for the county and its taxpayers, as well as threaten the health, safety, and well-being of nearby residents.

 Remedies. FOCC asks that the county:

1) Establish a permanent Camp Bonneville Citizen’s Advisory Group

There needs to be an on-going avenue for public discussion of the unique challenges posed by this property such as groundwater contamination, wildfire risks, security of the property, the financial burdens to mitigate contamination introduced by a firing range, and other issues. Just like the Heritage Farm Advisory Group and the Railroad Advisory Board (RRAB), this public property requires its own CAG. Council should convert the existing limited duration advisory group for cleanup into a longstanding committee with a broader, comprehensive mandate, and with members serving 3 year terms.

2) Permanently close the shooting range Camp Bonneville

The county should cease actively implementing reuses that apparently ignore restrictions on the property, disenfranchise public concerns, and continue to contaminate the property. The county should immediately issue notice to the FBI to cease using Camp Bonneville. The County should close the shooting range and regain control over Camp Bonneville.

3) Establish a Camp Bonneville Safety Evaluation Panel (SEP)

This panel would compile a comprehensive summary focused on the cleanup. The Camp Bonneville SEP should be tasked with reviewing all documents to map which areas have not been cleared, describe what contamination and other hazards remain in areas that have been cleaned up, and then assess the status of Institutional Controls such as fencing. This evaluation would be updated yearly to provide both the Council and the public with timely and accurate information about the property.

You can view our previous news on Camp Bonneville here:

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