Priority Setting

[Lenny Siegel <lsiegel@igc.org>]

PRIORITY-SETTING CHALLENGE

Faced with the seemingly unsurmountable task of funding cleanup at
Department of Energy (DOE) nuclear weapons production sites, key
elements of the Federal government are once again raising the specter of
priority-setting in environmental restoration. The existing system of
budgeting cleanup includes a process for determining priorities, based upon
common sense, risk assessment, legal obligations, and politics, but officials
see a need to standardize the process.

This is a key focus of the White House-led Federal Facilities Policy Group
(FFPG), led by Alice Rivlin (Director of the White Office of Management
and Budget) and Kathleen McGinty (head of the White House Office of
Environmental Policy). Furthermore, the Senate Appropriations Committee
declared in its recent Defense Appropriations bill report, "A priority-based
process for allocation of budget resources will become increasingly
necessary as DOD seeks to balance calls for immediate restoration of all
sites with continuing declines in defense spending."

When various stakeholders began meeting four years ago in what became
the Federal Facilities Environmental Restoration Dialogue Committee
(FFERDC), their principal charge was devising a method of setting
priorities in Federal facilities environmental restoration. Chapter 4 of the
February, 1993 FFERDC Interim Report makes detailed recommendations
for distributing budget shortfalls, based upon financial plans developed in
consultation with site-specific advisory boards. Though both the DOD and
DOE are implementing the other Interim Report recommendations, including
the formation of advisory boards at contaminated facilities, no agency has
even attempted to start implementing Chapter 4.

Federal advocates of improved priority setting see it as a way to meet legal
obligations within increasingly tight budgets. However, groups
representing facility neighbors and employees fear that low priority sites
will simply be forgotten. Not surprisingly, they are reticent to participate in
such an exercise, even though they generally have their own internal
cleanup priority-setting processes.

It is likely that the White House-led FFPG will develop a new national
scheme for setting or at least describing cleanup priorities. FFERDC, which
represents state and local governments, Indian nations, and non-government
representatives as well as Federal agencies, hopes to influence the FFPG
proposals by developing concepts of its own. The FFERDC Priority-Setting
Work Group will revisit its own recommendations, assess a simple (non-
mathematical), community-based risk evaluation model proposed by the
Defense Environmental Security Office and review options put forward by
the FFPG.

To be effective, the FFERDC Work Group needs to do three things. First, it
must bring more field experience to the table. National models often suffer
from bean-counters' disease. In attempting to measure priorities
numerically, they ignore important factors of common sense, culture, and
historical responsibility. Second, it should devise a priority-setting scheme
that compares activities, not just physical sites. Many individual sites
require a series of activities, some of which are high priority, some of
which are low. And some activities, such as removing pathways - such as
old agricultural wells - are not even associated with contamination sites.
Third, it needs to convince policy-makers that affected communities will
never accept downgraded priorities unless there are iron-clad assurances that
Federal agencies will take remedial action in the long run. Priority-setting
should never be seen as a way for the Federal government to avoid its long-
term obligation to clean up the enormous toxic, radioactive, and explosive
mess its national security establishment created over the last five decades.

This article is reprinted from the September, 1994 edition of the CITIZENS
REPORT ON THE MILITARY AND THE ENVIRONMENT. For more
information, or to be place on the mailing list, contact <lsiegel@igc.org>.