2002 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: 3 May 2002 14:22:19 -0000
Reply: cpeo-military
Subject: [CPEO-MEF] States criticize RRPI
On May 1, 2002 the Environmental Council of the States, representing the 
leadership of state and territorial  environmental agencies, sent
letters to Bob Stump (R-Arizona), chair of the House Armed Services
Committee, and Joel Hefley (R-Colorado), chair of that committee's
Readiness Subcommittee, opposing key elements of the Defense
Department's proposed Readiness and Range Preservation Initiative (RRPI) 
legislation. They did not address those portions of the Initiative - 
regarding habitat and species - that are beyond their jurisdiction. Both 
letters are available as PDF files from
http://www.sso.org/ecos/policy/letters.htm. I have keyed in below 
significant excerpts from the letter to Stump.



"ECOS members strongly support military readiness, adequate training,
and preparation for military personnel. Our members recognize that
military readiness requires the Department of Defense (DOD) to train
forces under realistic conditions, including field testing and
evaluating weapons systems and other military equipment. We further
recognize that 'external' factors such as urban and suburban sprawl and 
increasing wildlife habitat pressures have affected DOD's training and 
equipment testing and evaluation activities. In addition, there have 
been isolated cases where environmental regulation requirements have 
affected military operations. However, we also note that there are 
military activities with recognized environmental impacts....

"existing laws provide flexibility to accommodate DOD's current
'short-term' concerns about regulatory impacts to military training and 
readiness activities. In particular, ECOS membership is concerned with 
the earlier version containing proposed changes to the Resource
Conservation and Recovery Act; the Comprehensive Environmental Response, 
Compensation, and Liability Act; and the Clean Air Act....

"In the short time that states have had to evaluate the legislation,
serious questions have been raised about the changes to the Resource
Conservation and Recovery Act and the Comprehensive Environmental
Response, Compensation, and Liability Act, both of which relate to
active and closed DOD facilities. At our [recent ECOS] meeting, DOD
representatives were unable to offer examples of problems with state
regulators that would support the need for the proposed changes. In
fact, the concern appeared to be more directed toward private citizens' 
suits brought under federal law. ECOS is particularly concerned about 
unintended consequences that may occur by changing the definition of 
solid waste and the associated impacts to the authorities states use to 
provide consistent application of federally delegated environmental 
programs and state laws.

"Changes proposed by the Readiness and Range Preservation Initiative to 
the Clean Air Act are also problematic. Congress directed the federal 
government to comply with federal, state, and local requirements for 
control and abatement of air pollution to the same extent that any 
person is subject to such requirements. States have relied upon that 
requirement in crafting the mandated air quality plans for complying 
with national air standards. The proposed changes will force states into 
a difficult position of meeting national air standards with all other 
participants - industry, local  infrastructure, state and federal 
agencies - while temporarily exempting DOD.

"ECOS believes that changes to environmental laws should be carefully
considered, including holding hearings in the committees with
jurisdiction over these regulations. While DOD has stated that this
legislation is narrow in scope and is intended to address issues that
apply only to operational combat ranges necessary for military
readiness, ECOS members' initial analysis is this legislation is overly 
broad and may go beyond its stated intent.... We are also concerned that 
with this federal action encouraging local bases to seek further 
exemptions to state laws through state legislation, the first example of 
which has just been introduced in Alaska.

"ECOS appreciates that the pressures of urban and suburban sprawl and
increasing demands for wildlife habitat are impacting DOD's readiness
ability. ECOS is supportive of establishing buffer zones and other
conservation easement mechanisms to solve this problem. Indeed, ECOS is 
encouraged to see this type of language in the Readiness and Range
Preservation Initiative and supports the Subcommittee's effort to create 
tools for states and DOD to tackle this difficult issue."


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918

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