Navy Letter on DERA Cuts

[Aimee Houghton <aimeeh@igc.org>]

WARNING: This is a long file

What follows is a letter sent to all EPA Region Administrators by the 
Navy in response to the recent recissions in the DERA budget. THis was 
forwarded to me by The Keystone Center. Please share this with all 
those working on RABs and specifically those that are Navy sites.

Once again, this underscores the severity of the DERA cuts.

Aimee Houghton

----------------------

22 May, 1995

Mr/Ms______
Administrator

U.S. Environmental Protection Agency Region _
Address
Address

Dear Mr/Ms. _______ :

 As you probably know, the Department of Defense (DoD)
environmental restoration program at active bases for Fiscal Year
1995 (FY-95) was cut by $400 million by Congress during the
appropriation process. Most recently, Congress rescinded an
additional $300 million. I wanted to take this opportunity to
explain the impact of this Congressional reduction on the
Department of the Navy (DoN) FY-95 environmental restoration
program and what actions we are taking in response to this
reduction.

 Within DoN, we have sought full funding to meet our
requirements specified in cleanup agreements, including
requirements contained in Federal Facilities Agreements (FFAs).
CERCLA response actions for pre-existing releases, underground
storage tank assessments and remedial actions, and certain RCRA
corrective actions are all funded by the Defense Environmental
Restoration Account (DERA) since these actions all fall within
the "restoration" category. The DERA is a Department of Defense
(DoD) appropriation.

 All military service cleanup requirements are consolidated
by DoD in the DERA and presented to Congress as part of the
annual DoD budget. For FY-95, the DoD requested $2.18 billion
for DERA, including $538 million for the DoN. Congress
appropriated $1.78 billion. The DoN share of this $400 million
DoD reduction was $67.1 million, and the DoN share of the $300
million rescission was $66.9 million, leaving us with a $404
million installation restoration program for FY-95. As a result
of these reductions, we must re-evaluate and adjust the DERA
program on a national basis.

 As you can imagine, the reduction will require us to make
difficult choices between a variety of competing requirements,
all legally mandated, to live within the $404 million in FY-95.
This difficult process has been underway at our Engineering Field
Divisions and Engineering Field Activities (EFDs/EFAs).
Hopefully, the on-going partnering and frequent communications
between our engineering field offices, EPA Regions, and
Restoration Advisory Board members will pay dividends as we make
the necessary adjustments to our program in consultation with
each EPA Region.

 While we work cooperatively with you to adjust our FY-95
program, it is my personal conviction that we have seen the end
of ever increasing DERA budgets for the foreseeable future. For
the last three years, the Congress has cut the DoD DERA budget
request by successively greater amounts, beginning with a $300
million cut in FY-93, a $347 million cut in FY-94, and a $700
million cut in FY-95. The FY-93 and FY-94 cuts reduced program
growth, resulting in appropriated amounts of $1.65 billion and
$1.96 billion respectively. The FY-95 cuts, however, reduced the
FY-95 DoD program to $1.48 billion, which is $480 million below
the FY-94 appropriated level of $1.96 billion.

 Congress has reduced DERA funding in the past due to a
perceived lack of progress on site remediation, i.e., that too
much money was being spent on remediation studies and not enough
on actual site cleanup. More recently, DERA has been cut to
reduce the federal deficit, to make up for shortages in military
readiness accounts, and fund other Congressional priorities. I
expect increasing pressure on Capital Hill during the next term
on all portions of the defense budget that are not directly tied
to enhancing military readiness.

 I believe we must use these fiscal challenges to jointly
revisit all aspect of our remediation efforts. Where possible,
we need to streamline the process, eliminate administrative
bottlenecks, minimize sampling, testing and other study costs,
and refocus our attention to the single goal of the program....to
clean up contaminated sites. We must consider mutually accepting
greater risk in the confidence level of our studies and analysis
if we can save money and begin actual site remediation earlier.

 We must also reconsider how best to allocate our limited
resources. I believe that DoD's new policy for using risk
management in consultation with stakeholders is the single best
tool we have to do so.

 Let me assure you that we are doing our best to defend the
restoration program, both within the Department of Defense, and
with the Congress. Our efforts to budget and execute an
increasing percentage of our program on actual cleanup, even with
Congressional cuts, was a major reason why the DoN received a
relatively small cut in DoD's allocation of the original FY-95
Congressional reduction. I appreciate your help in cutting
process and helping us increase our cleanups to about 60% of our
total program. I can tell you that our execution performance has
helped us considerably during internal deliberations on the FY-96
budget.

 Representatives of our EFDs and EFAs should now be
discussing our FY-96/97 budget requests with you. Obviously, the
FY96/97 requests will require substantial revision due to the
FY95 reductions. In the meantime, we will continue to work
closely with both EPA HQ and the EPA Federal Facilities
Restoration Leadership Council to improve the Navy's restoration
process. In the last year, we have made improvements on
coordination of budget requirements, consultation with Regions
after the DERA appropriation, and streamlining Federal Facilities
Agreements. For the future, I believe that advocating the
concepts of risk management and a stable funding profile for
cleanup will help stem the tide against further cuts.

 Please do not hesitate to call me at (703) 693-4527 should
you have any questions or ideas. The point of contact within the
Office of the Assistant Secretary of the Navy is Mr. Paul
Yaroschak, Director, Environmental Compliance and Restoration
Policy, (703) 614-1282.

 Sincerely,

 (original signed)

 Cheryl Kandaras
 Principal Deputy

22MAY95 LETTERS SENT TO:

Mr. John P. DeVillars
Regional Administrator
U.S. EPA Region I
John F. Kennedy Federal Building
Boston, MA 02203
(617) 565-3420

Ms. Jeanne M. Fox
Regional Administrator
U.S. EPA Region II
209 Broadway
New York, NY 10007-1866
(212) 264-2657

Mr. Peter H. Kostmayer
Regional Administrator
U.S. EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-9800

Mr. John Hankinson, Jr.
Regional Administrator
U.S. EPA Region IV
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727

Mr. Valdas V. Adamkus
Regional Administrator
U.S. EPA Region V
77 West Jackson Blvd.
Chicago, IL 60604-3590
(312) 353-2000

Ms. Jane Saginaw
Regional Administrator

U.S. EPA Region VI
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
(214) 665-6444

Mr. Dennis D. Grams
Regional Administrator
U.S. EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7000

Mr. William P. Yellowtail
Regional Administrator
U.S. EPA Region VIII
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1603

Ms. Felicia Marcus
Regional Administrator
U.S. EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1305

Mr. Charles C. Clarke
U.S. EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-4973

Copy to:
AGC (I&E)
CNO (N45)
HQMC (CMC-LF)
NAVFACENGCOM (40)
EPA HQ (Mr. Breen)
NORTHNAVFACENGCOM
EFA MIDWEST
SOUTHNAVFACENGCOM
LANTNAVFACENGCOM
SWNAVFACENGCOM
EFA WEST
PACNAVFACENGCOM
EFA CHESAPEAKE
EFA NORTHWEST

Blind copy:
DASN(SR)

____________________________________________

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