2011 CPEO Military List Archive

From: Lenny Siegel <lsiegel@cpeo.org>
Date: Tue, 15 Mar 2011 12:16:22 -0700 (PDT)
Reply: cpeo-military
Subject: [CPEO-MEF] CLEANUP: New Air Force policy
On February 24, 2011 Assistant Air Force Secretary (Installations, Environment, and Logistics) Terry Yonkers issued a new cleanup policy, "Policy for Refocusing the Air Force Environmental Restoration Program." See http://www.cpeo.org/pubs/AF-ASCPolicy.pdf.

The policy directs Air Force personnel to move from an emphasis on site-by-site Remedies in Place (RIP) to fence-to-fence Accelerated Site Completion:

"Cleanup objectives and efforts will focus on the broadest possible (fence-to-fence) accelerated site completion at an installation, as opposed to the previous focus of achieving 'remedies-in-place' and individual site remediation. 'Accelerated site completion' (ASC) is achieved at the point at which Air Force will make essentially no additional appreciable investments of time or money."

Furthermore, Yonkers directs, "The primary contract mechanism to be used to achieve the ASC objectives will be Performance-Based Cleanup (PBC) agreements." He explains, "Performance objectives in contracts must comply with existing agreements and regulations and protect or maintain protection of human health and the environment while encouraging innovation to achieve accelerated site completion."

Finally, the policy memorandum establishes "an objective to reduce management and overhead cost to no more than 10 percent of total program cost as soon as practicable."

I welcome this policy. In my view the Defense-wide goal of putting Installation Restoration remedies in place or achieving response complete by 2014 (except for Formerly Used Defense Sites) has rushed large numbers of sites toward the RIP milestone without regard for long-term potential environmental exposure or the long-term site- management costs associated with incomplete cleanup.

In theory, I also support performance-based contracting. But such contracts must be pursued carefully if they are to succeed. There must be sufficient characterization before contracts are let, to avoid surprises, and the performance objectives must be developed with the concurrence of regulatory agencies and in consultation with the affected public. If this is done, then cleanup success will be evaluated by the actual condition of the soil, groundwater, and surface water, not the achievement of paperwork milestones.



Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918

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