HAGÅTÑA (The Guam Daily Post) — The Guam Environmental Protection Agency is “completely overwhelmed” with trying to enforce on-base construction regulations, the agency said in comments submitted on the proposed 360-degree missile defense program.
Commentary submitted to the federal Missile Defense Agency outlines a number of environmental impacts that the new Guam Defense System will have to assess, from prevention of groundwater contamination to the disposal of hazardous waste and the destruction of habitats for native species.
But the agency is “particularly concerned” on the impact that increased military presence will have on Guam EPA’s ability to enforce mandatory regulations.
Comments note that Guam EPA previously estimated in a supplemental environmental impact statement, or SEIS, issued in 2015, that it needed another 10 full-time employees just to keep up with with the Marine Corps relocation to Guam.
“In reality, Guam EPA has shrunken in total staffing since the SEIS publication, and with peak Marine Corps construction nearing, permitting and inspections resources are completely overwhelmed,” the agency wrote.
Former Guam EPA Administrator Walter Leon Guerrero during a budget hearing last June told lawmakers that his agency lacked the staff and resources to regulate erosion, hazardous waste and wastewater as the military buildup ramped up. He said at the time the agency had less than half of the full-time staff it needed to keep up with the increased workload and permitting required for military construction.
Permitting involves more than just signing off on construction plans, he said. The agency also is required to conduct regular inspections to ensure that proper environmental safeguards are in place.
Notably, EPA failed to identify ahead of time a lack of erosion control measures for the Mangilao Solar Project in 2021, which resulted in damage to surrounding property owners and the historic Marbo Cave, a freshwater well. Military contractors also commit violations, such as when a 100-gallon jet fuel leak went unreported for months in 2018, Post files show.
A new environmental impact statement for the upcoming Guam Defense System, “must provide an additional estimate of Guam EPA (full-time employees) needed to accommodate the proposed new Missile Defense activities, and also must propose mechanisms by which these additional (employees) will be provided, in addition to how the current … gap will be addressed,” Guam EPA wrote the Missile Defense Agency.
Recruitment problems
“As has been proven, Guam EPA has been unable to obtain additional funding or to even recruit additional qualified (employees, e.g. engineers and inspectors) due to wage competition driven by military construction.”
Well-funded Department of Defense projects promise to lure more capable staff away from Guam EPA, the agency said.
“Several extremely important and experienced staff have already made this move in the last year,” the agency noted.
Recent GovGuam salary increases continue to fall far short of federal and industry salaries, leaving the local agency unable to recruit badly needed professionals.
“This is crippling the ability to fulfill Guam EPA mandates, while the demands and workloads are simultaneously greatly increasing,” Guam EPA stated in the comments.
Other demands
Beyond behind-the-fence activity, increased workforce demand will require more temporary housing and worker barracks, which, along with higher traffic and increased government services, will require Guam EPA’s attention, the agency stated.
“The (Department of Defense) may not assume primary responsibility for these impacts, making the work of Guam EPA even more difficult,” the agency noted.
Demands on sewage, water and solid waste disposal from new workers “will only aggravate the existing severe violations of environmental standards, which will be further compounded by Guam EPA’s staffing shortfalls.”
New road construction needed for the missile defense project will add another burden for the agency. As will the need for “massive amounts of quarried materials,” the agency wrote. “The government of Guam as a whole has already observed severe abuses of Guam’s regulatory system for quarrying, with massive environmental impacts on private property and public resources.”
The agency wrote: “Wherever they are located, military developments, private and public developments triggered by the DOD expansion and even plans for expanded programs, will generate extensive … documents with strict timelines for review and comment. Guam EPA is already understaffed in manpower able to conduct these reviews.”
The comment also points out that nearly all of Guam’s public water systems already may have higher-than-acceptable levels of PFAS, a so-called “forever chemical” linked to congenital birth defects and other illnesses, if pending regulations from the U.S. EPA are enacted. U.S. EPA has linked high levels of the chemical to hundreds of military bases.
“The (draft environmental impact statement) should address alternate forms of drinking water and/or the installation of treatment systems to be sure that safe drinking water is provided not only to the new personnel expected as part of the proposed (missile defense) system, but also to existing residents whose water supplies are impacted by the increased population demand.”
Greater cooperation with the local regulator is requested from the Department of Defense in several areas, to manage environmental concerns.
The Guam Environmental Protection Agency board of directors meets July 20, 2023, at the agency’s conference room in Tiyan.


