To everyone concerned with the closure of the Umatilla Army Depot and the Base Realignment and Closure Act (BRAC) process:

I have been researching the ramifications of the recent announcement by the U.S. Army that the BRAC law will expire on Sept. 15, 2011, and what that would mean for our local communities.

At this time I believe I have adequate information to share some thoughts with you. I have avoided making any statement until I understood the difference between the BRAC process and closure under the General Services Administration for the Umatilla Army Depot. I believe that the information presented here to be correct, but the opinions expressed are my own and do not reflect the stated position by the City of Irrigon or any other agency.

Prior to BRAC, the military closed many bases as a cost-saving measure. The communities affected by closures were not happy and implored Congress to get involved. BRAC was a way to have congressional oversight on the bases that were to close. The BRAC process was set up to involve the communities in the process by requiring an LRA (Local Reuse Authority) to make recommendations to the military for minimizing the adverse impact to the local communities. If the LRA functions properly, they will consider the community needs and include those in the reuse plan. There is also an opportunity to form an implementing local reuse authority (ILRA) to manage the property after the military disposes of the property. Our local LRA has not reformed as an ILRA and we have no assurance that they will. However, in the Umatilla Army Depot Reuse Authority Reuse Strategy, the LRA recommended the formation of an ILRA to receive the Depot property through an Economic Development Conveyance (only ILRAs can use an economic development conveyance). 

According to my research, there may not be much difference in the direct effect to the local communities if the BRAC law sunsets on September 15, 20ll. Although the LRA may no longer have any authority under BRAC, the communities may still be eligible for assistance from the Office of Economic Adjustment and others. The Army would continue to own and maintain the base until the property was conveyed to another entity under either a BRAC scenario or under the GSA disposal process. 

It has been argued that if BRAC expires, the Reuse and Implementation Plan will have been a waste of time and money as the Army would not be obligated to follow the plan.

I dont believe this is the case. What I have found out is that the Reuse and Implementation Plan is only a guide. According to my research, the Army is not required to follow the Reuse Plan in either case, but under the BRAC process it must consider the plan. Under BRAC, the Army is required to give substantial deference to the plan, but may decide not to follow it. Also, the Army does not have to dispose of the real estate through any particular conveyance mechanism; so long as it follows one of the predefined paths.

According to my research, the main difference between the disposal of the property under BRAC is that under BRAC the Army would directly handle the disposal process. Without BRAC the General Services Administration (GSA) would dispose of the property under (apparently) the same process as defined under BRAC, except that the LRA and the Economic Development Conveyance are not part of the GSA process.

Under the current BRAC process, we understand that the Oregon Army National Guard will need special legislation to obtain a portion of the Umatilla Army Depot since it was overlooked during the initial process. If BRAC goes away, the Guard will have the opportunity to request all or a portion of the Depot property through the normal GSA conveyance process. Naturally, it would be easiest politically for the Army to follow the Reuse and Implementation Plan for apportioning the property to the Guard, but again, it is not required to.

Also, the Department of the Interior missed the boat on requesting a portion of the Depot through the BRAC process. If the BRAC goes away, the Fish and Wildlife Service would be able to submit a request for a portion of the property through the federal screening process. It would also be simpler for the Deptartment of Fish and Wildlife to obtain the property following the Reuse and Implementation Plan.

Lastly, the Port of Morrow and the Port of Umatilla, along with others, could request a portion of the Depot through the GSA conveyance process after the military and federal agencies make their bid if the BRAC process expires. The LRA may lose the opportunity for the Economic Development Conveyance if the BRAC expires, but there is no guarantee that the Army would allow that conveyance mechanism, anyway. It is clear that the Army is in control of the disposal process and the LRA is a mechanism to allow the communities to tell the Army what they want to do with the property.

Although the closure of the Depot will have a huge impact on the local communities, in my opinion, there would be very little difference in the direct effect on the local communities between the BRAC process and the GSA process. The GSA process does not include an LRA; however, the GSA could consult with the local communities in the disposal process. If BRAC expires, the Army National Guard and the Fish and Wildlife Service may be in better position to receive property without special legislation. Depending on the level of community involvement in the LRA, and the decisions of the Army, the BRAC process may or may not help the local communities.

The disposal process through the GSA is very similar to the BRAC process; it is just not done directly by the military or through an LRA. The LRA has provided the required reuse plan, the Umatilla Army Depot Reuse Authority Reuse and Implementation Strategy. The Army will probably use that document as a guide for either process, but it is not required to follow it.

In my opinion there are too many variables involved with the process and the various agencies involved to fully evaluate the potential benefit from extending BRAC. Personally, I would not press my congressional delegation to extend BRAC without knowing the end result. 

I hope this helps when making your own individual decisions as to how to respond to requests to lobby congress.

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Gerald Braezeale is the Irrigon City Manager.