RABs and Reuse

[meuser@cats.ucsc.edu]

Hello,
 I've listed a chronology of documents that talk about RABs addressing
issues of reuse/land use as well as restoration. At Fort Ord the RAB has
been told numerous times that they can only address restoration issues.
Many RAB members have argued that the two, restoration and reuse, are two
parts of the whole - conversion, reuse is dependent upon certain levels
of restoration/cleanup being attained, in other words, reuse "drives"
restoration. We may, in the near future, see restoration "driving" reuse
as the restoration/cleanup pot gets smaller and smaller (congressional
cuts). In either case, I have to agree with the RAB members who say that
you really cannot talk about one without talking about the other. To
artificially separate reuse from restoration, as has been done at Fort
Ord (The RAB does restoration and the Fort Ord Reuse Authority does reuse),
has the potential, at least, to have disasterous ends when it come time
for the community to comment on the final reuse plan, possibly challenge
the EIS, etc. etc.
 I'd really like to know what others on the list think of this and I'm
wondering too if RABs at other closing bases only address restoration
issues or if they also address reuse. Thanks for your time.

Mike Meuser
UCSC

Chronology of reuse and restoration in RAB/SSAB guideline documents
-------------------------------------------------------------------

"Interim Report of the Federal Facilities Environmental Restoration Dialogue 
Committee," February, 1993, pp.23-24, under the subheading "scope" says: 

 "[the boards should provide advice on issues related to] addressing important 
 issues related to clean-up, such as land use, level of clean-up, acceptable 
 risk, and waste management and technology development issues related to 
 environmental restoration; and..." 

Secretary of Defense William Perry, memorandum, "Fast Track Cleanup at Closing 
Installations," September 9, 1993, pp.3-4 of attachment, "DOD Guidance on 
Improving Public Involvement in Environmental Cleanup at Closing Bases," under 
the subheading "The RAB will" says: 

 "h. identify applicable standards and, consistent with Section 121 of the 
 Comprehensive Environmental Response, Compensation, and Liability Act 
 (CERCLA), _propose_ cleanup levels consistent with planned _land use_
 (emphasis added)." 

Deputy Under Secretary of Defense (Environmental Security) Sherri W. Goodman, 
memorandum, "Management Guidance for Execution of the FY94 / 95 and 
Development of the FY96 Defense Environmental Restoration Program," April 14, 
1994, pp.19-20 of attachment, "Fiscal Year 1994 / 1995 / 1996 Defense 
Environmental Restoration Program Management Guidance," under the heading, 
"RAB Responsibilities include" says: 

 "h. identify applicable standards and, consistent with Section 121 of CERCLA, 
 _propose_ cleanup levels consistent with planned _land use_ (emphasis added)." 

US Environmental Protection Agency and Department of Defense, "Restoration 
Advisory Board Implementation Guidelines," Final Draft version 2.4, May 1994, 
pp.13-14 under the heading "RAB Community Members" says" 

 "4. The RAB community members should act as a conduit for the exchange of 
 information between the community, DoD installation, and environmental 
 oversight agencies regarding the installation's restoration and _reuse_
 programs (emphasis added).

 5. The RAB community members should review, evaluate, and comment on documents 
 and other such materials related to installation restoration and _closure_
 where applicable (emphasis added)." 

US Environmental Protection Agency and Department of Defense, "Restoration 
Advisory Board Workshop Guidebook: A Strategy for Implementing the Joint 
Department of Defense and US Environmental Protection Agency Guidelines on 
Restoration Advisory Boards." Summer, 1994, p.7, under the subheading "The 
RAB has two primary purposes" says: 

 "Provide decision makers from the installation and regulatory agencies with 
 input on the cleanup program."

p.31, under subheading, "Responsibilities of the RAB Community Members." 

 "Advise and comment on cleanup issues to government decision makers." 

Note that the introduction to this guidebooks says, "The joint EPA and DoD 
guidelines draw from the recommendations articulated in the February 1993 
Interim Report of the Federal Facilities Environmental Restoration Dialogue 
Committee, known as the Keystone Report." Also note that this is the first 
absence of the terms reuse or land use. 

"Fort Ord Restoration Advisory Board By-Laws," Final Version 1, approximately 
January, 1995, p.3 under subheading "Responsibilities of the Restoration 
Advisory Board" says: 

 Provide advice on environmental restoration issues to the Army installation 
 and regulatory agencies (The Base Realignment and Closure Cleanup Team) made 
 up of ..." 

p.9 under subheading "Responsibilities of all RAB Community members" says: 

 "2. Advise and comment on cleanup issues to government decision makers 
 (BCT)."