Re: Pressure/budgets

[Nick Morgan <nmorgan@igc.org>]

Posting from "Nick Morgan" <nmorgan>

Peter - I think that you bring up a good point about the effect 
budget cuts have on an installation's desire to conduct remedial 
work. I would think, however, that such an attitude is more likely 
to be base-specific, or major command-specific, or possibly 
service-specific, more so than a DOD-wide issue.

In the example you mention, recommending a no-action alternative is 
exactly the response one might expect from a facility trying to avoid 
remedial work in the face of budget cuts - assuming that there is 
some significant contamination present. However, I would be less 
dubious of using a RCRA removal action to address CERCLA 
responsibilities. While it is true that there are far fewer public 
participation responsibilities under RCRA, there are a few reasons 
that doing such work as a RCRA removal might make more sense:

1) It may be easier and faster to secure RCRA funds, 
2) Once some work is started under a removal action, it is far more 
cost effective to complete all necessary work, rather than just go 
after "hot-spots" then come back at some later date and finish the 
cleanup.

But if the work is to happen as a RCRA removal, it is certainly 
vital that the public/RAB be actively involved in the decisions 
leading up to that removal, and that the base openly communicates 
that it desires to complete all neccessary cleanup work using under 
the upcoming removal action. Often removals are conducted with verey 
limited public input, and with much less vigorous review of 
alternative cleanup strategies. Removals then, in general, have some 
real benefits and drawbacks - yet that is another discussion.

In sum, I think that each base/command/service will respond to 
pending budget cuts differently, but you are probably right to recognize that 
those entities which have been tending to avoid cleanup, will 
continue to do so.