Formal Comments on Nellis Range Renewal
From: campbell@ufomind.com (Glenn Campbell, Las Vegas)
Date: Fri, 1 Jan 1999 13:46:09 -0800
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Below are excerpts from the comments I submitted on the Renewal of the Nellis
Range, which includes a proposal to transfer Area 51 from the Department of
Energy to the Air Force.
The web document includes links and the complete text of "Part II", which is
remove from except below. (To understand Part II, you need to have access to
the environmental document it refers to.)
The comment period for the renewal ended on Dec. 31.
As stored at: http://www.ufomind.com/place/us/nv/nellis/renewal/campbell/
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COMMENTS ON THE
DRAFT LEGISLATIVE ENVIRONMENTAL IMPACT STATEMENT
FOR THE RENEWAL OF THE NELLIS AIR FORCE RANGE
Submitted By
Glenn Campbell
Las Vegas, Nevada
December 1998
As a Nevada resident, I am submitting the following comments
on the Draft Legislative Environmental Impact Statement for the
Renewal of the Nellis Air Force Range, which was released in
September 1998.
Since my comments are quite lengthy, I have divided this
document into three parts: In Part I, I summarize my comments
and the philosophy behind them. In Part II, I list specific
inadequacies I see in the Draft LEIS, moving sequentially
through the pages of the report. Finally, in Part III, I offer some
general conclusions and recommendations.
Part I: Summary of Comments
Most of my comments are relevant only to Alternatives 1B and
2B in the report. This is the proposal for "administrative
realignment" of certain areas, in addition to the renewal of the
Nellis Range as it now exists. In Alternatives 1B and 2B, some
lands currently under Department of Energy control would be
transferred to the Air Force, while some lands under Air Force
control would be transferred to DOE.
Specifically, DOE would obtain control of the Pahute Mesa area,
which it is currently using, while the Air Force would obtain
control of the lands currently withdrawn by DOE under Public
Land Order 1662 (PLO 1662). These latter lands, popularly
known as "Area 51", are the site of a classified Air Force facility
at Groom Dry Lake.
My primary criticism throughout this report is that virtually no
environmental information has been provided for the PLO-1662
lands, and that this omission threatens the integrity of the rest of
the report as well.
I understand from reading local newspapers that under a recent
federal court ruling (in Frost vs. Perry) and an annual exemption
from the President, that the Air Force may be entitled to withhold
from the public certain environmental data about the Groom Lake
base which is deemed a risk to national security. If this is true, I
believe that the report should state this explicitly, specifying the
general parameters of what is being withheld and the legal
authority for doing so.
As it stands, the Draft LEIS omits most data regarding the
PLO-1662 land, with no mention of what is being omitted or
why. This, I believe, jeopardizes the integrity of the entire report,
since the reader cannot distinguished between "Negative Data,"
"No Research," "Classified Data" or "Overlooked Data."
To take a simple example, Figure 3.5-5 on Page 3.5-8 of the
Draft LEIS provides a map of earthquake faults throughout the
Nellis Range, the Nevada Test Site and surrounding areas. There
are no earthquake faults shown within the block of land defined
by PLO-1662. This strikes me as curious, because faults are
often associated with mountain ranges, and a portion of one small
range, the Papoose Range, is located within the PLO-1662 lands;
yet, the map shows no faults associated with these mountains.
Knowing that other environmental data on PLO-1662 has been
withheld, the reader is left in the dark about what the absence of
data means. He must choose between these possible alternatives:
1.Geological surveys have been conducted within the
PLO-1662 lands, and no faults have been found.
(Negative Data.)
2.No faults have been found because no survey has been
conducted within this area. (No Research.)
3.Faults have been identified, but information about them
has been deemed a risk to National Security and thus has
been withheld. (Classified Data.)
4.Faults have been identified, but information about them
has been omitted due to an administrative error.
(Overlooked Data.)
The fact that the authors of the report chose to include the fault
map implies that this kind of data could conceivably have an
impact on the environmental process. The fact the most faults in
this area seem benign does not remove the need for complete
data. If one is going to create such a map, it should be reliable,
and the absence of data on PLO-1662 lands elsewhere in the
report leaves the reader questioning the map. If we look at
another portion of the map where there are no faults shown, we
must ask the same question: Is this no fault, a classified fault, or
a "fault" in the report itself?
Likewise, on page 1-16 of the Draft LEIS, a map of area roads
omits all roads within PLO 1662 land. In addition, it omits
several prominent roads in the NAFR that lead to PLO 1662 land.
It even omits the extensions of these roads into public land and
the Nevada Test Site. If facilities within PLO 1662 land are kept
secret through a special exemption, the reader is left to wonder
where this exemption ends. Does it end at the boundaries defined
by PLO 1662, or does it include wide portions of the current
NAFR, public land and the NTS as well? As a citizen who might
have some valid environmental issues to raise, I cannot comment
intelligently on any omission anywhere in the report so long as
undefined parts of the data are withheld without notation.
In the specific case of the fault map, the ambiguity would easily
be resolved by a simple statement in the text like this: "Complete
surveys have identified no faults within the lands described by
PLO-1662."
Similarly, most of the other objections I raise in Part II would be
resolved by a statement at the beginning of the report saying what
kind of data is being withheld and under what authority. Later in
the report as specific environmental issues are reviewed,
one-sentence statements can refer back to the original statement.
(E.g. "This data is being withheld under Presidential exemption,
see Section XX.")
Further suggestions are provided in Part III.
Part II: Specific Inadequacies
[ For this section, see the complete document at
http://www.ufomind.com/place/us/nv/nellis/renewal/campbell/ ]
Part III: Conclusions and Recommendations
The renewal of the Nellis Air Force Range, as its borders now
exist, is a relatively straightforward and non-controversial action.
Matters are greatly complicated by the inclusion of Alternatives
1B and 2B, which attempt to merge a highly secretive facility into
a relatively open one. While some activities on the existing Nellis
Range may be classified, basic geographic and environmental
data is not. In the case of PLO 1662 and the facilities located
there, the Air Force is attempting to withhold nearly all
geographic and environmental information, even that which is
available from open sources and that could have no possible
bearing on national security.
In a series of annual Presidental Determinations (95-45, etc.),
President Clinton has exempted the Air Force from certain
environmental reporting requirements which all other military
facilities, classified or unclassified, must obey. The President
states:
I hereby exempt the Air Force's operating
location near Groom Lake, Nevada from any
Federal, State, interstate or local provision
respecting control and abatement of solid waste
or hazardous waste disposal that would require
the disclosure of classified information
concerning that operating location to any
unauthorized person.
It is plausible that certain environmental data concerning
hazardous waste disposal could pose a risk to national security.
For example, if a hostile foreign power had access to the exact
composition of soil samples from a classified location, it might be
able to deduce something about the secret weaponry tested there.
There is no need, however, for the Air Force to provide that kind
of detailed data in the LEIS. The LEIS is mainly a broad
summary of environmental data and compliance. It is not
necessary that the Air Force reveal the activities at a classified
location, but it should be able to state that it is in compliance with
environmental regulations there. It should also be able provide
routine information about the natural environment and manmade
artifacts (such as roads) that are plainly visible. Congress and the
public may not need to know the exact nature of a certain
hazardous waste site, but they should be informed that sites have
been identified and be told how environmental clean-up will be
affected by each of the proposed alternatives.
One weakness of the Presidential Determination is that it provides
no geographic definition of the "operating location near Groom
Lake, Nevada." We don't know if it includes only areas
immediately adjacent to the base, the entire extent of PLO 1662
lands, or lands extending far into the existing Nellis Range and
NTS. Judging from the omission of roads on Page 1-16 of the
LEIS (as mentioned in Part II), the exemption seems to cover
hundreds of square miles of the existing Nellis Range, the NTS
and even portions of public land.
Another weakness is that the President provides no guidance on
what "would require the disclosure of classified information"
about the facility. Would the release of information about flora,
fauna and geology require the disclosure of classified
information? I am sure that certain conservative military managers
would interpret it that way (and evidently they have prevailed in
the preparation of this LEIS). By the same reasoning, though,
one could argue that acknowledging the existence of the state of
Nevada might, in some obscure way, reveal classified
information about the Groom Lake facility. The fact is, the state
of Nevada does exist, as a matter of public record, as do the
roads, wildlife and water resources of the PLO 1662 lands.
Withholding this kind of routine information may protect the Air
Force politically, but it fails the test of reasonableness for the
disclosure of classified information.
Without a geographic definition and without any guidance as to
interpretation of the Presidential Determination, there are
effectively no boundaries for the exemption, and the Air Force is
free to apply it arbitrarily to any area within its control, inside or
outside of the PLO 1662 land. An arbitary exemption means that
the entire LEIS is meaningless, because any environmental data
anywhere in the report can be omitted without notice. The
bureaucratic risk is that the only information appearing in the
LEIS might be that which is supportive of the sponsor's political
agenda.
Recommendations
To preserve the integrity of the LEIS, I see two possible
alternatives. One is to entirely remove PLO 1662 lands from the
proposals for Alternatives 1B and 2B. The reallignment of those
lands can then be handled by some other petition to Congress
which is specifically designed for the special circumstances of
this operating location.
The other alternative is to provide clear statements in the LEIS
about what data is classified and withheld from the public. As
mentioned in Part I, the Air Force could provide a statement at the
beginning of the LEIS outlining what kind of data is classified
and under what authority it is being withheld. Then, elsewhere in
the report where classified information is omitted, a single
sentence can be inserted referring readers back to the original
statement.
If the Air Force feels that it is not legally required to provide
environmental data to Congress about PLO 1662, then it should
say so in the beginning of the report. Likewise, if the Air Force
chooses instead to prepare a classified supplement for the PLO
1662 land, at least its existence should be mentioned in the public
report. Making these statements explicitly, with clear definitions
of what kind of data is withheld and within what geographic area,
protects the reliability of the rest of the LEIS.
Unfortunately, a classified supplement also presents some
problems. One of these is that most members of Congress will
not have adequate clearances to read it. However, they will be
able to read the rest of the LEIS with the confidence that nothing
is being silently omitted.
Another problem with a classified supplement is determining
what kind of data belongs in it. For example, should information
on area roads be withheld from the open LEIS, even if they
appear on USGS topographic maps? Should the classified
supplement include inherently unclassified data such as natural
and cultural resources on PLO 1662 land, or should this data be
provided in the public LEIS?
The Air Force has never had to deal with these problems because
it has never said more than a few sentences publically about
anything within the PLO 1662 land. About all it has
acknowledged is that it "does have facilities at Groom Dry Lake."
This longstanding silence about the area presents a "Catch-22" to
the Air Force, because a generation of secretive behavior and
protocols must now be modified. If the Air Force acknowledges
that roads exist, then can employees reveal that they use the
roads? If a survey has been conducted of natural resources, can
the person who conducted it come forward to acknowledge his
role?
For years, the official policy about the base at Groom Lake is that
it "doesn't exist," and personnel who work at the facility or who
are professionally aware of it are instructed to say nothing at all.
Now, somebody must say something, at least to define what is
classified, or the LEIS will be an ineffective document.
Glenn Campbell
Dec. 30, 1998
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RELEVANCE OF THIS MESSAGE: Area 51
See: http://www.ufomind.com/place/us/nv/nellis/renewal/
Created: Jan 1, 1999
