The K2 Veterans: The First Boots on the Ground After 9/11 Were Put on Poisoned Ground, and the Paperwork Is Still Catching Up
They were among the first Americans sent to war after September 11, 2001 — soldiers, airmen, Marines, and special operators staged through a borrowed Soviet air base in Uzbekistan called Karshi-Khanabad, known as K2, or Camp Stronghold Freedom. The Department of Defense's own survey teams, working in 2001, 2002, and 2004, documented what was in that ground and air: petroleum-soaked soil under the tents, depleted uranium beside the tent city, burn pits upwind of the ammunition point. The surveys stayed classified for nearly two decades. The veterans who lived on that ground have spent the years since — through a congressional investigation, a landmark toxic-exposure law, two rounds of cancer rulemaking, and a Freedom of Information Act lawsuit still in court — trying to get their own government to finish the accounting its survey teams started. Parts of it are now done. This page records which parts, and which are not.
The service and the promise
K2 was established in October 2001, weeks after the September 11 attacks, at a former Soviet air base in Uzbekistan, a few hundred miles from the fighting in northern Afghanistan. It was the logistics and command hub for the opening of Operation Enduring Freedom. The United States occupied it until 2005. The Stronghold Freedom Foundation, the nonprofit formed by K2 veterans and families, puts the number who deployed or transited there at at least 15,777; VA and the Defense Department work with the same cohort figure, and Military Times rounds it to about 16,000. At any one time, the Foundation says, as many as 1,300 were on the base.
The promise is the standing one: a service member sent somewhere on orders does not bear the cost of what the ground there does to them. At K2, that promise had a complication from the first month. The hazard was not the enemy. It was the base itself — inherited from the Soviet military that had used, and by the survey record contaminated, the site before the Americans arrived — and the institution knew it in writing while the troops were living there.
What happened
The declassified record begins almost immediately. DoD provided the House Oversight Subcommittee on National Security with its classified 2001, 2002, and 2004 environmental hazard surveys and health risk assessments, and the subcommittee’s July 9, 2020 summary of those documents — released when Chairman Stephen Lynch and Representative Mark Green got them declassified — is the spine of what is publicly established:
- Petrochemical contamination. Subsurface testing in 2001 found “[e]levated levels of volatile organic compounds (VOCs) and total petroleum hydrocarbons (TPH) … at numerous locations throughout Stronghold Freedom, including tent city.” A November 2001 assessment warned that inhaling vapors from the fuel-contaminated soil “could potentially cause adverse health effects” and recommended: “Prohibit digging into soil contaminated with jet fuel.” VA attributes the fuel to a leaking Soviet-era underground distribution system.
- Compounds in the air. A June 2002 assessment estimated that “between 50% and 75% of personnel at Stronghold Freedom will be exposed to elevated levels of compounds in air.” A September 2004 assessment called exposure to particulate matter (PM10) “frequent.” A few air samples showed elevated tetrachloroethylene.
- Burn pits. A September 2004 inspection found multiple open fires near the base: “The smell of burning plastic was evident, and ash was noted blowing from the fire site over the ASP [ammunition supply point].”
- Radiation. A former missile site — “Site 1,” adjacent to the tent city — was found in 2001 to contain small pieces of depleted uranium, left, VA says, when Soviet missiles were destroyed there years before. Radiation measurements in 2002 ran four times above background. Site 1 was declared off-limits in November 2001, but a September 2004 assessment still found “the potential for daily contact with radiation exists for up to 100% of the assigned units,” while rating the risk “low” — with “low confidence,” by its own admission, because of thin sampling data.
VA’s own public-health summary adds asbestos — in roof tiles and dirt, though not detected in air samples — and lead-based paint, in one in-processing building. The same VA page states that assessments “confirmed the absence of chemical warfare agents and ionizing radiation on K2.” That sentence matters, because the wider record is broader than the survey record. In December 2019, McClatchy’s Tara Copp reported, from Defense documents, contamination including missile propellant, solvents, fuel, lubricants, trace amounts of chemical weapons, and depleted uranium. Veterans and advocates have described more still — DAV’s Shane Liermann cited enriched uranium in the soil and cyanide in the showers, and Army environmental sampler Matthew “Nick” Nicholls, whose team worked the site in late 2001, has described yellowcake uranium in the ground. In its October 1, 2025 response to public comments, VA reported that DoD “maintains there is no evidence that enriched uranium was present at the site,” while VA continues to investigate depleted uranium, jet fuel, airborne dust, and contaminated surface water. This page keeps those layers separate: what the surveys documented, what VA lists, and what veterans, samplers, and advocates say beyond both.
What the troops saw, they named themselves. Runoff ponds ran bright green — in some accounts the ponds changed colors, green and red — and the men called them the “Skittles” ponds, for the unnatural candy colors. “Black goo” seeped up through soil and tent floors. What they were not given was the survey record itself. Air Force Master Sergeant Paul Widener Jr., retired, who served at K2 and later tracked its illnesses in a veterans’ Facebook group, testified on February 27, 2020: “K2 members were told repeatedly that no significant risk from hazards existed. … There were no briefings on toxic exposures, no protective equipment recommended, issued, or employed.” The September 2004 inspectors had recommended the opposite — “aggressive health risk communication efforts” so personnel would know the threats. Mark T. Jackson, an Army Criminal Investigation Division agent who arrived in the summer of 2003 and is now the Foundation’s advocacy director, kept a journal whose first entries record his throat and eyes stinging from a rotten smell. Kim Brooks’s husband, Army Lieutenant Colonel Timothy Brooks, wrote home about black gunk through his floorboards; he collapsed two years after coming home, was diagnosed with stage 3 brain cancer, and died at 36, leaving four children. Air Force veteran Clayton White came home with thyroid disease, seizures, respiratory and gastrointestinal illness, and pancreatitis; the only condition VA service-connected for him was tinnitus, DAV records. He died in his sleep the day after his 41st birthday, while his wife Natalie was thirty weeks pregnant.
What the institution did afterward
For most of two decades, the institutional answer was that there was nothing to answer for. Claims were decided case by case, against a record the claimant could not see — the surveys were classified, and, as Jackson has put it, Uzbekistan was not recognized in the statutes as a place American troops had even been. The fight to change that ran on separate tracks, and they did not move together.
The science, disputed in the open. In 2015, the U.S. Army Public Health Center produced an initial study of cancer outcomes among K2 deployers, compared with service members who deployed to South Korea. As VA’s own K2 web page summarizes it, the study found higher risks of malignant melanoma — 368 percent higher — and of neoplasms of the lymphatic and hematopoietic tissues — 564 percent higher. Representative Lynch’s office rendered that, in February 2020, as K2 veterans being “more than five times as likely to develop cancer than their counterparts deployed to South Korea,” and Representative Green said in July 2020 that “K2 veterans’ cancer rates are 5 times higher than those of counterparts who served elsewhere.” VA’s caution is also on the record, and specific: the findings rested on very few cases and are not definitive evidence of a causal link. Dr. Patricia Hastings, VA’s chief consultant for post-deployment health, told the subcommittee on November 18, 2020 that the central comparison came down to seven cases at K2 against five in Korea — numbers that “could be a coincidence, but it could also be an early signal,” and that VA was taking seriously. What VA told the committee earlier that year was blunter: responding to its January 2020 inquiry, VA reported, as the committee’s March 4, 2020 letter records, that there was “no indication of increased cancers” among K2 veterans. Both documents exist. The advocates cite the first; the department spent years standing on the second.
Congress. The Oversight investigation opened with letters on January 13, 2020, heard Widener, fellow veteran Scott Welsch, and Kim Brooks on February 27, and got the surveys declassified on July 9, 2020. That same February day, Lynch and Green — Green himself a K2 veteran of the 160th Special Operations Aviation Regiment, who told the hearing he had been diagnosed with colon and thyroid cancers at the same time — introduced the K2 Veterans Toxic Exposure Accountability Act. Its core was folded into the Fiscal Year 2021 National Defense Authorization Act, signed at the turn of 2021: a mandated Defense Department study of K2 toxic exposure, and registry access — VA confirms Uzbekistan was added as an eligible location for the Airborne Hazards and Open Burn Pit Registry. On January 19, 2021, President Trump signed an executive order on K2 that Representative Green’s office describes as using the Act as its template and asking the Secretary of Defense to recognize Uzbekistan as a combat zone for purposes of medical care. The follow-on K2 Veterans Care Act of 2021, which would have created a direct presumption, did not pass.
The PACT Act — what it did and did not do. The Sergeant First Class Heath Robinson Honoring our Promise to Address Comprehensive Toxics Act, signed August 10, 2022, is the largest single change in the K2 record, and precision about its mechanics is the whole point. Under its toxic-exposure framework (38 U.S.C. § 1119), service in Uzbekistan on or after September 11, 2001 carries a presumption of exposure to burn pits and airborne hazards. For a veteran with that service, the statute’s presumptive list (38 U.S.C. § 1120) applies — eleven cancers, from brain and gastrointestinal to kidney, lymphoma, melanoma, pancreatic, reproductive, and respiratory, and twelve respiratory illnesses, including chronic bronchitis, COPD, chronic rhinitis and sinusitis, constrictive bronchiolitis, emphysema, interstitial lung disease, pleuritis, pulmonary fibrosis, and sarcoidosis. Asthma, rhinitis, and sinusitis diagnosed after service are separately presumptive under VA’s particulate-matter rule (38 CFR § 3.320), which has listed Uzbekistan since 2021. Health-care eligibility widened with the same law, fully from March 5, 2024.
What the PACT Act did not do is just as specific. It amended the definition of a “Persian Gulf veteran” for the undiagnosed-illness law (38 U.S.C. § 1117) to add Afghanistan, Israel, Egypt, Turkey, Syria, and Jordan — not Uzbekistan. So the Gulf War framework’s presumptions for undiagnosed illness and medically unexplained chronic multisymptom illness (MUCMI) did not attach to K2 service by statute. And the § 1120 list is a burn-pit list: conditions the veterans attribute to K2’s particular chemistry that are not on it — thyroid and bone disease, autoimmune and reproductive conditions among them — remained individual fights, proven case by case. The Foundation’s verdict on passage, in its own newsletter, was that the Act “does not go nearly far enough”: many chronic conditions unaddressed — its executive director, Matt Erpelding, gave his own osteoporosis, denied by VA and priced out of his private insurance, as the example — and spouses, children, survivors, DoD civilians, and contractors left outside it. Jackson, to The War Horse, called K2 “the most egregious” of the PACT Act’s gaps.
The courts. Because the paper record stayed incomplete even after declassification, the Foundation and the Connecticut Veterans Legal Center, represented by Yale Law School’s Veterans Legal Services Clinic, sued the Defense Department under the Freedom of Information Act on April 3, 2023 (Case No. 3:23-cv-408, District of Connecticut), challenging the adequacy of DoD’s searches and its withholdings. On April 2, 2026, the court granted DoD’s summary-judgment motion in part and denied it in part, and granted the plaintiffs’ cross-motion for further discovery in part — three years on, what the government must still hand over about K2 remains contested in federal court.
Where it stands now
Since 2024 the department that once reported “no indication of increased cancers” has moved, in steps that can each be dated — and whose limits can also be dated.
On August 9, 2024, VA announced it would treat K2 service as a toxic exposure risk activity (TERA), naming jet fuel, volatile organic compounds, particulate matter and dust, asbestos roofing tiles, and lead-based paint; would train every claims processor and examiner on K2 exposures; and would put K2 claims through pre-decisional review, required from November 4, 2024. It also announced it planned to make undiagnosed illness and MUCMI presumptive for K2 veterans under the Gulf War framework. The instrument was a proposed rule — cited by VA as AR75 — published October 1, 2024 (89 Fed. Reg. 79815), which implemented the PACT Act’s § 405 changes and expressly invited comment on adding Uzbekistan and four other countries to the undiagnosed-illness regulation, 38 CFR § 3.317. The comment period closed December 2, 2024. As of VA’s own most recent accounting — its October 1, 2025 Federal Register notice (Notice 2025-19310) responding to the separate November 27, 2024 request for K2 exposure comments — that proposed rule had not been finalized, and no final rule adding Uzbekistan to § 3.317 has been published since. The presumption announced in August 2024 remains a plan with a docket, not a finished regulation. VA’s processing steps are in force; the regulation is not.
The cancer track, by contrast, closed. On October 29, 2024, Secretary Denis McDonough announced VA would begin rulemaking to make bladder, urethra, and other genitourinary cancers presumptive for K2 veterans and the wider burn-pit cohort, after Senators Tester and Blumenthal and Representative Takano pressed the department that month to use its PACT Act authorities. VA did not wait for a comment cycle: on January 2, 2025, an interim final rule (90 Fed. Reg. 23) made urinary bladder, ureter, and related genitourinary cancers presumptive, effective that day, for veterans who served in Uzbekistan on or after September 11, 2001, K2 expressly included; a second interim final rule followed on January 10, 2025, for acute and chronic leukemias, multiple myelomas, myelodysplastic syndromes, and myelofibrosis. These are interim final rules — operative law, issued without prior comment, with post-comment finalization still the department’s to complete — but the presumptions are in effect and claims are being paid under them. By VA’s October 2025 figures, 73 percent of identified K2 veterans have filed claims, 68 percent are receiving benefits — averaging 13.6 service-connected conditions at about a 70 percent rating — and 84 percent are enrolled in VA health care.
The scientific argument continues underneath, and the current record cuts in both directions. VA’s K2 Surveillance Program, begun in 2021, published initial findings in May 2024: no increased disease or mortality risk — a result VA itself flags as preliminary, in a cohort averaging 52 years old with about fifteen years of follow-up, for diseases that typically declare themselves later. The program is committed for at least ten more years, and VA’s urine assays for depleted uranium — 556 by August 2025 — have all come back negative. A larger nested case-control study, published in the Journal of the National Cancer Institute in 2026, examined 619,403 service members, 15,031 of them K2 deployers, and found no association between K2 deployment and seven of eight cancers studied — and a dose-dependent association with the eighth: each additional month at K2 raised the odds of non-Hodgkin lymphoma by 13 percent, deployment over 180 days carried 78 percent higher odds, and the association strengthened when exposure was lagged twelve to fifteen years. VA’s October 2025 notice holds the department’s line — “to date, there is no evidence supporting an increased risk of disease or mortality associated with service at K2” — while the newest peer-reviewed study reports exactly one such association, for exactly the family of cancers the 2015 study flagged. The mandated Defense study from the FY2021 NDAA has no public completion in the record: in June 2025, Representative Green was still writing to the Secretary of Defense and the DoD Inspector General demanding it, and reporting on those letters records that the study “has yet to be completed, as far as Congress and the general public are aware.”
The legislative remainder is one bill. The K2 Veterans Total Coverage Act of 2025 (H.R. 3441, 119th Congress), introduced May 15, 2025 by Representative Green with Representative Lynch, would write the full K2 list into § 1120 directly — any cancer, and thyroid, bone, cardiovascular, skin, neurological, reproductive, respiratory, endocrine, liver, and kidney disease, blood disorders, primary immune regulatory disorders, medically unexplained chronic multisymptom illness, and cataracts. It was referred to the House Committee on Veterans’ Affairs on introduction and, on the latest public record, has not moved since. Twenty-five years after the first boots touched that ground, that is the state of the promise: the burn-pit account largely settled, the cancer presumptions of 2025 in force, and the K2-specific account — the illness framework, the full disease list, the Defense study, and the last of the records — still open.
The ledger
The accounting, in three lines — what the record shows has been done, what it shows has not, and what is still being sought.
What has been done
- July 9, 2020: the classified 2001, 2002, and 2004 DoD surveys and health risk assessments were declassified and publicly released under House Oversight Subcommittee pressure, documenting petroleum contamination, airborne compounds, burn pits, and depleted uranium at the site the troops lived on.
- Fiscal Year 2021 NDAA (enacted at the turn of 2021): the K2 Accountability provisions became law — a mandated DoD study of K2 exposures and K2 access to the Airborne Hazards and Open Burn Pit Registry, Uzbekistan added as an eligible location.
- August 10, 2022 — the PACT Act: Uzbekistan service on or after September 11, 2001 carries a presumption of toxic exposure; the § 1120 presumptive list — eleven cancers and twelve respiratory illnesses — attaches to K2 veterans, alongside the particulate-matter presumption for asthma, rhinitis, and sinusitis, and expanded health-care eligibility.
- August–November 2024: VA recognized K2 service as a toxic exposure risk activity, trained all claims processors and examiners on the K2 contaminant list, and required pre-decisional review of K2 claims.
- January 2 and January 10, 2025: interim final rules made urinary bladder, ureter, and related genitourinary cancers, and then acute and chronic leukemias, multiple myelomas, myelodysplastic syndromes, and myelofibrosis, presumptive for the post-9/11 cohort including K2 — in effect, with claims payable.
- The cohort is substantially inside the system: by VA’s October 2025 accounting, 84 percent of identified K2 veterans are enrolled in VA health care and 68 percent are receiving disability benefits.
What has not been done
- The undiagnosed-illness rule is not final. VA announced the Gulf War illness framework for K2 in August 2024 and proposed it on October 1, 2024 (AR75, 89 Fed. Reg. 79815); as of VA’s October 1, 2025 notice it remained unfinalized, and Uzbekistan is still not in 38 CFR § 3.317. K2 veterans with undiagnosed or multisymptom illness have the department’s processing protections, not the finished presumption.
- The mandated DoD study has no public completion. Required by the FY2021 NDAA, it was still being demanded by Representative Green in letters to the Secretary of Defense and the DoD Inspector General in June 2025.
- The record is not fully released. The SFF/CVLC FOIA suit, filed April 3, 2023, was still being litigated on April 2, 2026, when the court split its decision on DoD’s searches and withholdings and allowed further discovery in part.
- K2-unique conditions remain case-by-case. Anything attributed to K2’s own exposures that is not on the burn-pit list or the 2025 cancer rules — thyroid, bone, autoimmune, reproductive, and other chronic conditions the veterans report — carries no presumption.
- The two January 2025 cancer rules are interim final rules; VA’s post-comment finalization of them is not in the public record.
What is being sought
- A finished undiagnosed-illness/MUCMI presumption for K2 — finalization of the October 2024 proposed rule adding Uzbekistan to the Gulf War illness regulation.
- A full K2-specific presumption list in statute: the K2 Veterans Total Coverage Act of 2025 (H.R. 3441, 119th Congress), introduced May 15, 2025 and still in the House Committee on Veterans’ Affairs — any cancer plus fourteen further disease categories for veterans who served at K2.
- The completed DoD exposure study mandated in the FY2021 NDAA, and complete release of the DoD record on K2 conditions, the object of the still-open FOIA litigation.
- Continued surveillance with published results: VA’s K2 Surveillance Program, committed for at least a decade, as the cohort ages into the years when the diseases in dispute typically appear.
The record, on video
Two films carry this record in the veterans’ own voices: DAV’s account of the base and of Clayton and Natalie White, and the Oversight chairman who ran the investigation making the legislative case in the veterans’ committee. The full 2020 hearings live on the congressional record and C-SPAN; what is embedded here is what could be verified, publisher by publisher, as open for embedding.
The base, and one family. DAV's film on K2: the contaminated former Soviet base, the 2015 Army study, and Air Force veteran Clayton White — who died the day after his 41st birthday, leaving his wife Natalie to carry the claim. (Disabled American Veterans.)
The investigator's case. Subcommittee Chairman Stephen Lynch, whose investigation forced the K2 surveys into the open, testifies to the House Veterans' Affairs Committee for the K2 Veterans Care Act, May 5, 2021. (Oversight Dems.)
Sources
- U.S. House Committee on Oversight, Subcommittee on National Security, press release, July 9, 2020 — the declassified 2001/2002/2004 DoD surveys and health risk assessments, the subcommittee’s findings (petrochemicals and TPH including tent city; 50–75% airborne-compound exposure; PM10 and tetrachloroethylene; the September 2004 burn-pit inspection; Site 1 depleted uranium and the “up to 100%” radiation-contact finding; Widener’s February 27, 2020 testimony; the investigation’s timeline): https://oversightdemocrats.house.gov/news/press-releases/national-security-subcommittee-releases-newly-declassified-documents-revealing
- U.S. Department of Veterans Affairs, Public Health, “Karshi Khanabad (K2) Air Base” — VA’s exposure list (jet fuel from the leaking Soviet-era system, VOCs, particulate matter, depleted uranium from destroyed Soviet missiles, asbestos in roof tiles and dirt, lead-based paint in one building; assessments confirming the absence of chemical warfare agents; VA’s summary of the 2015 study’s melanoma and lymphatic/hematopoietic findings and its few-cases caution): https://www.publichealth.VA.gov/exposures/karshi-khanabad.asp
- McClatchy reporting (Tara Copp, December 2019), as carried by Military Times, February 27, 2020 — the first public reporting on the DoD documents (missile propellant, solvents, fuel, lubricants, trace chemical weapons, depleted uranium), the bright-green “Skittles” runoff ponds and “black goo,” and the February 27, 2020 hearing (Widener, Welsch, Kim Brooks): https://www.militarytimes.com/news/pentagon-congress/2020/02/27/post-911-veterans-attribute-deadly-cancers-to-contaminants-at-us-base-in-uzbekistan/?contentQuery=%7B%22includeSections%22%3A%22%2Fhome%22%2C%22excludeSections%22%3A%22%22%2C%22feedSize%22%3A10%2C%22feedOffset%22%3A45%7D&contentFeatureId=f0fmoahPVC2AbfL-2-1-8
- U.S. House Committee on Oversight, March 4, 2020 letter reporting VA’s response — VA’s position, conveyed to the committee in early 2020, that there was “no indication of increased cancers” among K2 veterans; C-SPAN record of the November 18, 2020 hearing — Dr. Patricia Hastings on the 2015 study (seven K2 cases against five in Korea; “could be a coincidence, but it could also be an early signal”; the 15,777 cohort) via the Internet Archive’s C-SPAN2 transcript: https://archive.org/details/CSPAN2_20201119_022400_Hearing_on_Veterans_Health_After_Exposure_to_Hazardous_Chemicals
- Representative Stephen Lynch, press release, February 27, 2020 — H.R. 5957 and the 2015 study rendered as K2 veterans “more than five times as likely to develop cancer than their counterparts deployed to South Korea”; VA had “not acknowledged a causal relationship”: https://lynch.house.gov/2020/2/reps-lynch-and-green-introduce-bill-holding-dod-and-va-accountable-veterans-toxic
- VA, “The PACT Act and Your VA Benefits” — Uzbekistan listed among the on-or-after-September 11, 2001 presumption-of-exposure locations, and the presumptive cancers and illnesses (eleven cancers; twelve illnesses including asthma diagnosed after service, chronic bronchitis, COPD, chronic rhinitis and sinusitis, constrictive bronchiolitis, emphysema, granulomatous disease, interstitial lung disease, pleuritis, pulmonary fibrosis, sarcoidosis): https://gcc02.safelinks.protection.outlook.com/?url=https%3A//lnks.gd/l/eyJhbGciOiJIUzI1NiJ9.eyJidWxsZXRpbl9saW5rX2lkIjoxMDgsInVyaSI6ImJwMjpjbGljayIsInVybCI6Imh0dHBzOi8vd3d3LnZhLmdvdi9yZXNvdXJjZXMvdGhlLXBhY3QtYWN0LWFuZC15b3VyLXZhLWJlbmVmaXRzLyIsImJ1bGxldGluX2lkIjoiMjAyMzA5MTMuODI1NTQ2MDEifQ.CRiPbMugZO35Rr3c4-fKsOuILBZT5aFNIgt4AE8tjbM/s/662574558/br/225868599073-l&data=05%7C01%7C%7C120a29b1203d46f4df3e08dbb4a740d0%7Ce95f1b23abaf45ee821db7ab251ab3bf%7C0%7C0%7C638302402661930845%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJVTiI6MjAwfQ%3D%3D%7C3000%7C%7C%7C&sdata=kPXFwds%2B9O/MM9xDnqHgLagNCHpuKL2qtqnvLRD8T6A%3D&reserved=0
- Stronghold Freedom Foundation, Executive Director’s notes, fall 2022 newsletter — the Foundation’s verdict on the PACT Act (“does not go nearly far enough”; chronic conditions, spouses, children, survivors, DoD civilians, and contractors unaddressed; Erpelding’s osteoporosis example) and the 15,777 figure as carried by VFW, August 31, 2022: https://us19.campaign-archive.com/?u=6cf0aa8bf4f534a58eff09d4d&id=2061f3e6e1 and https://www.vfw.org/media-and-events/latest-releases/archives/2022/8/troops-likely-exposed-to-toxic-hazards-at-k2-in-uzbekistan
- VA press release, August 9, 2024 (update page, updated January 17, 2025) — the K2 steps (MUCMI plan, TERA recognition with the contaminant list, claims-processor training, pre-decisional review from November 4, 2024) and the AR75 timeline: proposed rule published October 1, 2024, comment period closed December 2, 2024; the separate November 27, 2024 K2 exposure notice: https://www.va.gov/new-mexico-health-care/news-releases/expanded-access-for-benefits-for-k2-veterans-and-survivors/
- VA, proposed rule, “VA Adjudication Regulations for Disability or Death Benefit Claims Based on Toxic Exposure,” 89 Fed. Reg. 79815 (October 1, 2024) — the PACT Act § 405 implementation and the express invitation to comment on adding Uzbekistan (and Somalia, Djibouti, Lebanon, and Yemen) to the undiagnosed-illness/MUCMI regulation: https://regulations.justia.com/regulations/fedreg/2024/10/01/2024-21852.html
- Senate Committee on Veterans’ Affairs, October 2024 — following the Tester, Takano, and Blumenthal push, VA’s announcement that it would begin rulemaking to make bladder, urethra, and other genitourinary cancers presumptive for K2 and burn-pit veterans, with the Stronghold Freedom Foundation’s response: https://www.veterans.senate.gov/2024/10/following-tester-takano-blumenthal-push-va-moves-to-cover-k-2-veterans-sickened-by-uranium-radiation
- VA, interim final rule, “Presumptive Service Connection for Bladder, Ureter, and Related Genitourinary Cancers Due to Exposure to Fine Particulate Matter,” 90 Fed. Reg. 23 (January 2, 2025), RIN 2900-AS21 — the genitourinary presumptions in effect from January 2, 2025, Uzbekistan included, K2 expressly named in VA’s announcement; GAO rule report B-336981, January 17, 2025: https://www.govinfo.gov/content/pkg/FR-2025-01-02/pdf/2024-31220.pdf and https://www.Gao.gov/products/b-336981
- VA press release, January 2025, and Military Times, January 8, 2025 — both January 2025 presumptive packages (genitourinary cancers effective January 2; leukemias, multiple myelomas, myelodysplastic syndromes, and myelofibrosis effective January 10), and the cohort figures (about 13,000 of roughly 16,000 enrolled; at least 11,800 rated disabled): https://news.va.gov/press-room/va-makes-several-cancers-presumptive-for-service-connection-lowering-the-burden-of-proof-for-veterans-to-receive-no-cost-health-care-and-earned-benefits/ and https://www.airforcetimes.com/veterans/2025/01/08/va-eases-benefits-rules-for-cancers-from-post-911-service-k2-tours/
- VA, Notice 2025-19310 (filed October 1, 2025), responses to comments on the November 27, 2024 K2 notice, as summarized by Veterans for Equality Alliance — VA’s position (“to date, there is no evidence supporting an increased risk of disease or mortality associated with service at K2”), DoD’s position that there is no evidence enriched uranium was present, the October 2024 proposed rule “not yet finalized,” and VA’s uptake figures (73% filed, 68% receiving benefits, 13.6 conditions, ~70% rating, 84% enrolled): https://www.vfea.org/news/va-responds-to-public-comments-on-k2-toxic-exposure
- VA K2 Surveillance Program, preliminary morbidity and mortality findings, May 2024 — no increased disease or mortality risk in the initial analyses, with VA’s own preliminary/latency caveats (mean age 52, ~15 years’ follow-up): https://www.publichealth.va.gov/docs/exposures/K2_AMSUS_24.pdf ; and the nested case-control cancer study, Journal of the National Cancer Institute (2026), as summarized by the Institut National du Cancer — 619,403 service members, 15,031 K2 deployers, no association for seven of eight cancers, and the non-Hodgkin lymphoma dose-response (OR 1.78 for deployments over 180 days): https://www.cancer.fr/professionnels-de-sante/veille/nota-bulletin-n-675-du-23-fevrier-2026/deployment-to-karshi-khanabad-air-base-uzbekistan-between-2001-and-2005-and-subsequent-risk-of-specific-cancers-among-us-service-members
- Yale Law School, Veterans Legal Services Clinic, “CVLC et al. v. DOD” — the April 3, 2023 FOIA filing; and Memorandum of Decision, Connecticut Veterans Legal Center and Stronghold Freedom Foundation v. Department of Defense, No. 3:23-cv-408 (D. Conn. April 2, 2026) — DoD’s summary-judgment motion granted in part and denied in part, plaintiffs’ Rule 56(d) cross-motion granted in part: https://law.yale.edu/studying-law-yale/clinical-and-experiential-learning/our-clinics/veterans-legal-services-clinic/cvlc-et-al-v-dod and https://ecf.ctd.uscourts.gov/cgi-bin/show_public_doc?2023cv0408-66
- H.R. 3441, K2 Veterans Total Coverage Act of 2025, 119th Congress — introduced May 15, 2025 by Representative Green (with Representative Lynch), referred to the House Committee on Veterans’ Affairs, the fifteen disease categories it would add to 38 U.S.C. § 1120(b) for K2 veterans, and its status (no action after referral): https://www.govinfo.gov/app/details/BILLS-119hr3441ih and https://www.govtrack.us/congress/bills/119/hr3441 ; RealClear Defense, June 11 and June 25, 2025 — Green’s 2025 letters demanding the NDAA-mandated DoD study, the study’s non-completion “as far as Congress and the general public are aware,” Nicholls’s sampler account, and LaForce’s “Skittles” ponds account: https://www.realcleardefense.com/articles/2025/06/11/exclusive_rep_green_letter_to_dod_ig_demands_answers_on_k2_base_toxins_1116099.html and https://www.realcleardefense.com/articles/2025/06/25/k2_cancer_and_congress_the_full_story_1119039.html
- DAV, “For K2 veterans, the fight for toxic exposure recognition rages” (2023) and “Ending the Wait” reporting with MOAA (2024) — the Clayton and Natalie White account, Mark Jackson’s journal and conditions, the nearly 400 compounds figure as DAV states it, and Liermann’s account of the K2-unique exposures the PACT Act does not reach: https://www.dav.org/learn-more/news/2023/for-k2-veterans-the-fight-for-toxic-exposure-recognition-rages/ and https://www.dav.org/learn-more/news/2024/for-k2-army-veteran-the-fight-for-toxic-exposure-recognition-continues/
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