2002 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: 30 Oct 2002 21:56:37 -0000
Reply: cpeo-military
Subject: Re: Fwd: RE: [CPEO-MEF] RAB questions
I've been reluctant to join in the discussion because my only Internet
access today is from expensive booths at airports. I haven't had time to
read everyone's comments.

The root of the problem is not with the regulatory driver (CERCLA, RCRA,
etc), but the budget mechanism. RABs at active bases and formerly used
defense sites (FUDS) are funded through the Environmental Restoration (ER)
accounts, which are restricted by statute. Under a strict interpretation,
they cannot address issues that are funded under compliance, pollution
prevention, or conservation programs. Activities that look like cleanup to
us mere mortals - such as lead and asbestos abatement - may be compliance

Not all installations make this interpretation. Some accept discussion of
non-environmental restoration issues as a small part of RAB meetings,
since those discussions really don't cost the Defense Department anything

At installations funded through the Base Realignment and Closure (BRAC)
program, I believe there is more flexibility. I don't believe that the
enviromental ceiling within the BRAC appropriation is fenced by statute in
the same fashion, but I would appreciate it if someone with better
knowledge of the law would confirm or correct my conclusion.

Some of us have argued for several years that the Defense Department
should expand RABs to become Community Advisory Boards, which could
address the full slate of environmental issues at a base. This would help
communities and the military alike to resolve issues such as site-specific
encroachment. Vandenberg Air Force Base established a Community Advisory
Board to encompass pollution prevention, and I believe that worked well.
But attenmpts to expand scope elsewhere have run into the statutory,
budgetary roadblock.


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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