News From Your Friends

Transparency for the Camp Bonneville Community Advisory Group (CAG) – Position Statement

April 4, 2024 in Accountability, Parks, Trails, & Open Spaces, Position Statements & Policy Recommendations, Rivers, Lakes & Aquifers

After attending the March 20th Camp Bonneville Community Advisory Group (CAG) meeting and learning of subsequent developments regarding Camp Bonneville, we’d like to reiterate old concerns and express new ones, all falling under the theme of transparency. They are as follows:

1)  Spoken Public Testimony and the Uniqueness of the Proposed Charter:

When asked about whether other County advisory groups had charters, the Heritage Farm Sustainability Plan was cited by staff as having a charter like the one being presented to the Camp Bonneville CAG.  But when comparing the HF Sustainability Plan charter to how staff’s proposed Camp Bonneville charter was described, it is markedly different.

First, it states that “…meetings will be recorded and posted on the project website to ensure transparency of the process,” which was not the case for Camp Bonneville, the reasoning provided from staff being that, “These meetings are not subject to RCW 42.30.020(2) (Open Public Meetings Act) since this group is not a governing body of a public agency.” Members of the public had to press for staff to change course on this.

Second, there is no statement that members “shall report immediately” any contact with the media as the proposed Camp Bonneville charter apparently states. While staff also cited the Heritage Farm Sustainability Plan charter as an example of when public testimony was also not allowed, the last open house on the Sustainability Plan held a Q and A session with the public. Additionally, the Heritage Farm Advisory Group allotted time for public testimony on the Sustainability Plan.

So, in the case of Heritage Farm, the public has avenues for speaking comments into the record. These options do not exist for the public to speak about Camp Bonneville outside of the Camp Bonneville CAG meetings, which is why public testimony should be included. The fact remains that no other board, commission, or group at Clark County disallows the public from speaking, except possibly the Arts Commission, as we were unable to confirm this from their website.

The county manager said that there is no good reason for public comment because of the nature of the CAG’s mission to review cleanup. Why should no one be allowed to provide relevant information or be able to ask questions in public? The public is not without skills, and there are military veterans and others who wanted to speak their knowledgeable concern at this meeting, but were not allowed to under this flawed process.

More information makes a better product, and there is high physical risk to the public if public input and expectations on cleanup of Camp Bonneville are not done adequately. For example, at the 2022 WA Department of Ecology listening session, a member of the public provided information that a child had found a fully loaded round with live ammunition, an M4 magazine on top of the ground about 3 years prior inside the boundary, around the same time as the very last cleanup action. This is an example of how the public can provide meaningful information to the CAG for the record during this process.

2)     Written Public Comment:
All written public comments about Camp Bonneville must be sent to an email address, but links have not been provided for a viewable record of those comments. All written public comments should be viewable and easily accessible by the public in the spirit of keeping this a transparent and collaborative process between staff, the CAG, and the public.

3)     Issues with Keeping an Accurate Record by Recording Audio Only:
While it is wonderful that these meetings are now being recorded with audio, staff did not grant unmute abilities to CAG members that were attending online, and did not make a point to make sure that online CAG members were having their written chat statements read into the record, as staff noted they would only be providing audio of the meetings. We urge staff to fix the issue of granting virtual CAG members the ability to speak or be prepared to read CAG member’s written chat statements into the record going forward.

4)   Dismissing of Requests to Ensure an Accurate Record
A CAG member raised the issue of a discrepancy on one of staff’s slides during the last meeting one month ago, and at the March meeting staff had still not addressed it. They would not concede that their information was wrong and would not agree to removing the slide from the record until it got sorted out. 

Furthermore, the county manager commented that this particular information about what kind of conveyance Camp Bonneville was transferred under was irrelevant to the task at hand, and that potential reuses of the site have “nothing to do with the cleanup”, so it doesn’t matter whether or not the record contained factual information on this item. We strongly disagree that this factual discrepancy is irrelevant because reuse plans and what is or is not allowed for reuse under certain conveyances is very much relevant to safety and risk reduction standards that are set for cleanup at sites like Camp Bonneville. To illustrate this, we can look to a letter from the EPA to Washington Department of Ecology (WADOE) from 2006, in which the EPA expresses to WADOE that their cleanup plan was not adequate on the very basis that the cleanup would not be thorough enough to ensure safety for public reuse:

An additional important consideration, and one that EPA and States are grappling with nationwide, is the implementation and enforcement of institutional controls (ICs). ICs, which are designed to provide protectiveness where ‘waste’ is left in-place, are a serious challenge to make effective in the long-run, and this is particularly true when it comes to discarded military munitions and unexploded ordnance…Based on our recent national experiences at both Adak, Alaska and Fort Ord, California, ICs have not consistently performed adequately to prevent public exposures to military munitions…I encourage Ecology to be especially cautious and thoughtful considering the appropriate role of ICs…given this site’s history and intended reuse as a county park.”

Furthermore, EPA made clear their divergence in standards from the cleanup action described in the Ecology CAP, stating: 

“EPA believes that 14 inches is insufficient to ensure proper risk management. Especially in the Central Valley Floor where future camp activities and the presence of visitors (children and adults) on site means that penetration below 14 inches is likely.” (Note they do not merely say “possible,” but likely)

Additionally, during a presentation to Council on January 10th, staff made the statement that the park was “cleaned based upon the reuse plan,” and the fact that Camp Bonneville is listed in the current PROS Plan as a way to make up a significant amount of level of service (LOS) deficit for parks means that surely the evaluation of the cleanup and standards set for the cleanup should happen upon the basis of its intent for use as a county park. If the plan for the culminating staff report includes not just presenting the bare facts about the cleanup, but an evaluation of whether that cleanup met a certain standard, and if those standards vary based upon what the intended reuse is (as referenced by the EPA), then uses matter.

For this reason, it is inappropriate to extricate facts about planned or allowed uses of the site from the cleanup review. Furthermore, even if there was no relationship to the cleanup, it is still important to ensure that factual mistakes uncovered in the CAG’s review process are corrected, as this information will ultimately be presented to Council.

More broadly, we find it concerning staff’s unwillingness to correct a simple but very important mistake in the record, which, compounded with other issues that have been raised, we fear hints toward an adversarial and non-collaborative relationship with the CAG and the public.

We emphasize that these issues are being raised in the interest of transparency. The adequacy of cleanup at Camp Bonneville has been very much in dispute for years. There is much documentation of data to demonstrate this. The stakes for public safety, liability, and costs to the county and its taxpayers are extremely high, and this CAG review process is the last chance to establish clear facts about the cleanup so that the county can know how to proceed responsibly in the interest of its citizens.

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