Order Code RS22065
Updated August 31, 2007
Military Base Closures:
Role and Costs of Environmental Cleanup
David M. Bearden
Specialist in Environmental Policy
Resources, Science, and Industry Division
Summary
Near the end of its first session, the 109th Congress approved a new round of
military base closures and realignments. As the Department of Defense (DOD)
implements the new round, issues for the 110th Congress include the pace and costs of
closing and realigning the bases and the impacts on surrounding communities. The
disposal of surplus property has stimulated interest among affected communities in how
the land can be redeveloped to replace lost jobs. Environmental contamination can
present a challenge to economic redevelopment if funding or technological constraints
would limit the degree of cleanup needed to make the land safe for its intended use.
Most of the land on bases closed under prior rounds has been cleaned up and transferred
for redevelopment. However, some bases have yet to be cleaned up to an extent that
would be safe for their intended use. Bases closed under the 2005 round could face
similar delays in reuse if a community’s preferred land use requires a costly and time-
consuming degree of cleanup. This report explains cleanup requirements for the transfer
and reuse of properties on closed bases, discusses the status of properties transferred for
reuse, and examines estimates of costs to complete cleanup at those awaiting transfer.
Introduction
Following the collapse of the former Soviet Union, Congress authorized four rounds
of military base closings and realignments in 1988, 1991, 1993, and 1995. Although
closure of installations under all four rounds is complete, environmental cleanup and
economic redevelopment of some of these properties continue. The pace and cost of
cleaning up environmental contamination on closed bases has been an ongoing issue
because of concern about human health and environmental risks and the public’s desire
to redevelop these properties for civilian uses. The completion of cleanup is often a key
factor in economic redevelopment, because the land cannot be used for its intended
purpose until it is cleaned up to a degree that would be safe for reuse.
A new round of base closures and realignments has made communities concerned
that the cleanup of environmental contamination may pose obstacles to redeveloping more

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surplus military property for civilian reuse. The Base Realignment and Closure (BRAC)
Commission submitted its report on the 2005 round to President Bush on September 8,
2005. This report lists the military installations that the Commission approved for closure
or realignment and its reasons for altering DOD’s recommendations.1 The President
notified Congress of his approval of the Commission’s recommendations on September
15, 2005. Near the end of its first session, the 109th Congress approved the 2005 round,
which must be completed within six years under federal statute. However, this time frame
applies only to the closure or realignment of bases. The cleanup of contaminated surplus
property to make the land suitable for civilian reuse could take significantly longer.
Consequently, the cost and pace of long-term efforts to clean up these properties are likely
to continue to be issues for many years.
Cleanup Requirements for Property Transfer and Reuse
Section 120(h) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA, commonly referred to as Superfund) generally requires the
United States (in this case, DOD) to clean up closed bases prior to transfer out of federal
ownership.2 Property on a closed base is typically transferred to a local redevelopment
authority (LRA) responsible for implementing a plan for civilian reuse. To speed
redevelopment, CERCLA authorizes early transfer under certain conditions.3 Early
transfer can be advantageous in terms of redevelopment, if the intended land use would
not present the potential for harmful human exposure to contamination, and therefore not
require cleanup. Conversely, redevelopment could be delayed despite early transfer if
cleanup is necessary to make the intended land use safe.
Whether a property is transferred after cleanup or transferred early, the degree of
cleanup varies from site to site, depending on the cleanup standard used and the remedy
selected to attain it. Rather than specify standards for particular substances, CERCLA
requires that cleanup comply with legally applicable, relevant, and appropriate
requirements (ARARs) to protect human health and the environment, including a host of
federal and state standards for various hazardous substances.4 Although CERCLA does
not explicitly require the consideration of land use in determining the degree of cleanup,
in practice, land use is a key factor in selecting a cleanup standard and remedy to attain
it. Cleanup standards generally are stricter for land uses that would result in greater risk
of human exposure to contamination. For example, cleanup is typically more stringent
and more costly for land uses such as residential development, which could pose a higher
risk of exposure to sensitive populations including children and the elderly. Cleanup is
typically the least stringent and the least costly for industrial land uses, such as
manufacturing, which could pose less risk of exposure.
The Environmental Protection Agency (EPA), or the state in which an installation
is located, is responsible for determining whether the selected remedy would attain the
1 The BRAC Commission’s report is available online at [http://www.brac.gov/finalreport.html].
2 42 U.S.C. 9620(h).
3 42 U.S.C. 9620(h)(3)(C).
4 42 U.S.C. 9621(d).

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cleanup standard for a specific site.5 EPA has issued non-binding guidance for
considering the “reasonably anticipated land use” in selecting cleanup remedies.6 DOD
and the community, usually through the LRA, are responsible for determining how the
land will be reused, in negotiating the terms of the property transfer. However, the
community’s ability to attain its preferred use is constrained, as the Defense Base Closure
and Realignment Act does not require DOD to dispose of property on a closed base for
a particular land use, nor within a certain time frame. Impediments to conveying the land
for redevelopment may surface if DOD is resistant to transferring it for a purpose that the
community desires, because of cost considerations or technological limitations affecting
cleanup of the contamination. EPA’s guidance acknowledges that some land uses may
not be practical due to such challenges, and indicates that the cleanup objective may need
to be revised, which may result in “different, more reasonable land use(s).”7
In addition to land use, numerous other factors can determine the degree and cost of
cleanup, raising further issues. For example, cleanup does not necessarily require the
removal of contamination, if a safe method of containing it is available to prevent
exposure. Although containment is typically less costly than removal, some of the
savings of containment can be offset by the costs of maintaining the containment method
over the long-term to ensure that it remains effective in preventing exposure. Tensions
may arise between DOD and the community, if there is disagreement over the method
selected to prevent exposure. Communities frequently prefer removal rather than
containment, because of concerns about lingering risks and continuing costs if the method
of containment were to fail over time. However, DOD may prefer containment to save
costs, due to limited funding for the cleanup of many closed bases across the country.
Once DOD and the community agree on a land use, and a cleanup remedy is selected
to make that land use safe, DOD generally administers and pays for the cleanup.
However, the recipient of the property voluntarily can agree to accept responsibility for
the cleanup, including the costs. In such cases, DOD typically sells the land at a
discounted price to offset the cleanup costs borne by the purchaser. A discounted price
may lower a purchaser’s initial costs to buy the land, but the purchaser does assume some
financial risk if the cleanup costs are greater than expected. The cost of environmental
insurance to assume this financial risk also may offset some of the initial savings gained
from a discounted price.
If DOD takes responsibility for the cleanup, the department remains obligated after
cleanup is complete in the event that more contamination is found later that requires
remediation. However, DOD is obligated for further cleanup only to the extent that the
degree of contamination found later would exceed applicable standards for the land use
originally agreed upon for the transfer. If a community decides to use the land for another
purpose that would require further cleanup, DOD would not be responsible for paying for
5 EPA is required by statute to take the lead in overseeing cleanup at federal sites on the National
Priorities List (NPL). States usually take the lead in overseeing cleanup at non-NPL sites.
6 EPA. Office of Solid Waste and Emergency Response. Land Use in the CERCLA Remedy
Selection Process. OSWER Directive No. 9355.7-04. May 25, 1995.
7 Ibid., p. 7.

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it. In such cases, the additional costs of cleanup to make the land safe for a different
purpose would be the responsibility of the property recipient.
Status of Property Transfer on Closed Bases
DOD is in the early stages of implementing the 2005 round and will transfer surplus
property as bases are closed and the land is found to be environmentally suitable for
transfer. Although DOD has transferred most of the land on bases closed in prior rounds
for redevelopment, certain properties have yet to be transferred because cleanup is not
complete, raising questions about the potential for similar delays in the 2005 round. The
most readily available information on the status of property transfer on bases closed in all
four prior rounds was released by the Government Accountability Office (GAO) in
January 2007. GAO reported that 78% of the acreage on these closed bases had been
transferred for reuse, as of the end of FY2006.8 Of the acreage awaiting transfer, 15% had
been leased for reuse prior to the completion of cleanup. However, pending cleanup had
delayed the permanent transfer of these properties, with reuse limited to purposes that
would be safe relative to the degree of contamination and potential for human exposure.
The remaining 7% of the acreage on bases closed under the four prior rounds had not been
leased or transferred for reuse primarily because of cleanup challenges.
Estimates of Cleanup Costs
The total amount of funding required to clean up closed bases to prepare them for
civilian reuse is difficult to determine. Uncertainties about the degree of cleanup that will
be required at many sites make it challenging to accurately estimate the outstanding costs
to complete cleanup. Although DOD estimates these costs based on its current knowledge
of individual site conditions, the estimates are periodically revised as more is learned
about the type and extent of contamination present at each location, and the actions that
federal and state regulators will require to address potential health risks. In effect, these
estimates are “moving targets” that change as more information becomes available to
project the costs of future actions.
The net costs to clean up closed bases to prepare them for civilian reuse also is
difficult to determine because the closure of these facilities results in annual “savings” in
operational costs that can offset the costs of cleaning up contamination. Estimates of
annual savings resulting from the closure of all bases under the previous four rounds
range from $6.6 billion to $7.3 billion.9 The BRAC Commission estimated additional
savings of approximately $4.2 billion annually that would result from the closure of bases
selected for the 2005 round. These estimated savings are based on the operational
expenses that DOD would have incurred if these installations had remained open, and
aptly are often referred to as “cost avoidances.”
8 Government Accountability Office. Military Base Closures: Opportunities Exist to Improve
Environmental Cleanup Cost Reporting and to Expedite Transfer of Unneeded Property. GAO-
07-166. January 2007. p. 20.
9 DOD estimates an annual savings of $7.3 billion in operational expenses it would have incurred
if all of the bases closed under the four prior rounds had remained active. GAO calculated a
lower estimate of $6.6 billion in annual savings.

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However, an important factor to consider is that a portion of the cleanup costs would
have been incurred regardless, as DOD is required to clean up its operational installations
at least to a degree that would be safe for military uses. The incremental cost and time to
clean up a closed base depend primarily on how extensive the cleanup must be to make
the land safe for uses that would be less restrictive than military purposes, and result in
a higher risk of human exposure to contamination. When taken into consideration, this
factor can somewhat reduce the offsetting effects of operational savings on the costs to
clean up contamination on a closed base.
Further, the reporting of cleanup cost estimates by DOD is fractured among several
documents that present different categories of cleanup expenditures and liabilities. The
lack of a comprehensive source of information makes it difficult to determine the total
estimated costs associated with the cleanup of closed bases. In its January 2007 report,
GAO observed this difficulty and recommended that DOD report all costs to clean up
closed bases in one single source in order to provide “more complete and transparent cost
information” to aid Congress in its oversight of this effort.10 While the differing reporting
mechanisms raise challenges in identifying total cleanup costs, all of the estimates DOD
has reported indicate that the cleanup of closed bases is a multi-billion dollar effort that
will require many years to complete, even decades in some cases. For example, DOD
expects cleanup to require more than 50 years at three closed bases with extensive
contamination, including Mather Air Force Base and McClellan Air Force Base in
California, and Williams Air Force Base in Arizona.11
Among the various reports, the most detailed information on cleanup costs and time
frames at individual installations is provided in DOD’s annual Defense Environmental
Programs Report to Congress. This report provides information on the status of cleanup,
past costs incurred, and estimates of future costs for activities administered under the
department’s Defense Environmental Restoration Program. Although this program
accounts for the vast majority of cleanup costs at individual installations, it does not
reflect associated program management and support costs, nor does it reflect the costs of
other activities related to cleanup, such as the closure of landfills, storage tanks, and other
waste disposal facilities that DOD used when an installation was active. It also does not
reflect the closure of operational training ranges, which can require extensive and costly
cleanup to remove unexploded ordnance (UXO) and other munitions.
As indicated in the following table, DOD reports that it had spent $6.9 billion
through FY2006 under its Defense Environmental Restoration Program to clean up closed
military bases. DOD estimates that another $3.9 billion would be needed in the future to
complete cleanup, including bases to be closed in the 2005 round. While these amounts
exclude costs of certain activities identified above, they represent the bulk of the costs.
However, continuing uncertainties about the degree of cleanup that will be required at
many sites make the estimates of future costs still preliminary at best. For example, the
actual costs could be higher if new or more stringent regulations are issued that require
10 Government Accountability Office. Military Base Closures: Opportunities Exist to Improve
Environmental Cleanup Cost Reporting and to Expedite Transfer of Unneeded Property. GAO-
07-166. January 2007. p. 4.
11 Department of Defense. Defense Environmental Programs Report to Congress for FY2006.
March 2007. Appendix M. p. M-125, p. M-127, and p. M-208.

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a greater degree of cleanup than anticipated. Future costs also could be more than
expected if unknown contaminants are discovered. On the other hand, costs at some sites
may prove lower if more cost-effective cleanup technologies become available.
Table 1. Defense Environmental Restoration Program:
Cleanup Costs at Closed Military Bases
for All Five Rounds Combined
Military
Costs Incurred
Costs FY2007 to
Total Costs
Component
Through FY2006
Completion
Army
$2,122,536,000
$1,323,998,000
$3,446,534,000
Navy
$2,354,135,000
$1,519,753,000
$3,873,888,000
Air Force
$2,364,259,000
$1,023,520,000
$3,387,779,000
Defense Logistics Agency
$95,708,000
$28,631,000
$124,339,000
All Components
$6,936,638,000
$3,895,902,000
$10,832,540,000
Source: Department of Defense. Defense Environmental Programs Report to Congress for FY2006.
March 2007. Appendix N, Table N-4, p. N-4-1 and p. N-4-2.
Key Issues
The amount of money and time required to complete the cleanup of closed bases will
depend on the type and extent of contamination present on those properties, and the
actions that will be necessary to make the land safe for civilian reuse. Cleanup can take
many years, as the continuing cleanup of certain bases closed between 1988 and 1995
demonstrates. As in prior rounds, availability of funding and capabilities of cleanup
technologies could limit the degree of cleanup on bases closed in the 2005 round, making
certain land uses infeasible and posing challenges to economic redevelopment.
Whether DOD’s estimates are a reasonable approximation of what the actual cleanup
costs might be has been the topic of much debate. Because the civilian uses of bases to
be closed in the 2005 round have yet to be finalized, DOD’s cost estimates so far are
based on a degree of cleanup that would be safe relative to the recent military land use.
If a property were to be used for a purpose that is less restrictive than military use, and
would result in a higher risk of exposure to contamination, a greater degree of cleanup
likely would be required to make the land safe for that use. In such circumstances, more
funding and time could be needed to complete cleanup than DOD has estimated.
In deliberations over the 2005 round, some Members of Congress and the BRAC
Commission expressed concern that DOD’s estimates could be undervalued because they
do not reflect all possible land uses and the corresponding degree of cleanup that may be
necessary to redevelop these bases. Some states also assert that DOD’s estimates are
based on less stringent cleanup actions that the department prefers, rather than on more
extensive actions that they could require under their regulatory authorities. Accordingly,
communities have questioned whether more funding and time may be needed than DOD
has estimated to clean up closed bases to make them safe for civilian reuse. Considering
the inherent uncertainties in cleaning up environmental contamination, DOD’s cost
estimates are likely to continue to evolve as more is learned about the actions that will be
needed to make the remaining properties on closed bases suitable for reuse.

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