|Date:||Mon, 22 Jul 1996 11:56:49 -0700 (PDT)|
|Subject:||TX AG RESPONSE TO 346 AMMEND -Reply|
From: Sam Goodhope <Sam.Goodhope@OAG.STATE.TX.US> Subject: Re: TX AG RESPONSE TO 346 AMMEND -Reply Long message... I am uncertain what results will be forthcoming from DoD's and DoE's "hard look" at institutional controls. It is my personal opinion as a member of DERTF that the effort to look meaningfully at such controls has been stymied, if not altogether sandbagged by those working on the issue. Furthermore, I am no longer sanguine about DoD's commitment to cleanup in conformance with state and federal regulator oversight. I think the actions regarding DSMOA cuts and RAB funding cuts, devolvement, the establishment of DoD's self-determined prioritization scheme which may not fit within the desired priorities set by the fifty states and EPA, this year's backdoor attempt to amend CERCLA 120(h)(3), last year's backdoor amendment of 120(h)(3) to allow for long-term leasing, and the unilateral DoD movement during the past few years towards over-reliance on future land use (including the desire to go to a "no future land Use " option (e.g., some portions of Kelly AFB)), risk assessment, and risk management during priority setting are not positive indicators that successful partnering between the regulators and the DoD has adequately developed and/or has been sufficiently institutionalized. Moreover, these indicators evince, if anything, a retreat by DoD to a cleanup program in which the states and state regulators are left outside the fence. (I do not doubt, however, that many of the folks involved with the cleanup programs at the DoD and service level remain committed to cleaning up the mess at some of these bases, so long as it done in accordance with DoD's priorities and under the terms set forth by DoD.) Again, it is my personal belief (i.e., no official view) that we may very well be at the beginning of the end of the truly partnering state/federal relationship in the cleanup program which many have worked together during the past few years to try to establish. This is not an irredeemable situation, but continued efforts to lobby our communities for an amendment that is not needed, or, rather for which no need has yet been shown, will only exacerbate a growing feeling out here in the hinterland that something is amiss inside the Beltway on these very important cleanup issues.
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