2000 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: Thu, 27 Apr 2000 12:27:02 -0700 (PDT)
Reply: cpeo-military
Subject: [CPEO-MEF] IR3M
Last Friday (April 21, 2000), I reported that a version of the Interim
Range Rule Risk Methodology (IR3M) was available for review and comment.
That was my understanding. The Army/Defense Department had long promised
such a version. I had requested and received multiple copies of the

However, I have since been asked to delay circulation of the IR3M "to
allow DoD the first opportunity to release this document outside of the
R3M Partnering Initiative." Unfortunately, this apparently depends upon
the publication of a Federal Register notice, which as far as I can tell
is lost in a bureaucratic no man's land.

I have urged the Defense Department to make the document widely
available as soon as possible because it is long, complex, and - in
places - controversial. The implementation of the Range Rule, once
promulgated, will depend heavily on the availability of a
regulator-accepted risk management framework. The IR3M, intended as such
a framework, still needs work, and it won't be usable until all
stakeholders have had an serious opportunity to influence its


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126

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