|From:||Lenny Siegel <firstname.lastname@example.org>|
|Date:||Tue, 26 Sep 1995 09:52:10 -0700 (PDT)|
|Subject:||DOD LETTER ON RAB FUNDING|
In a reply to a September 12, 1995 letter from Congressman Robert Underwood (D-Guam), the Department of Defense (DOD) Environmental Security office has pointed out several practical problems - from my point of view, at least - in the Restoration Advisory Board (RAB) language contained in the Senate version of the FY96 Defense Authorization Act. The letter is signed by Patrick J. Meehan, Acting Deputy Under Secretary of Defense (Environmental Security) 1. The Senate language would preclude the first two options, including the use of regional service providers, described in DOD's May 24, 1995 Federal Register notice. Only small purchase orders - less than $25,000 each - would be permissible under the Senate language. 2. DOD already intends to establish eligibility criteria through the regulatory process. 3. Though the FY95 Defense Authorization Act gave DOD the authority to spend up to $7.5 million on RAB technical assistance, the FY95 Defense Environmental Restoration Account will be fully obligated and thus not available. It is possible, however, that some Base Realignment and Closure funds would be available. 4. The Defense Department prefers giving authority over RAB assistance to a "responsible DOD official," rather than the "installation commander." It says, "This would allow for a DOD executive agent or central Service or regional management approach." Under the Senate language, "communities near Formerly Used Defense Sites could not gain assistance because these sites are not installations with commanders." This would directly conflict with the intent of the Senate Appropriations Committee. 5. DOD prefers to continue providing RAB operating expenses using existing authorities. It says, "We believe it is best to keep administrative support issues (RAB operations) separate from technical support. We are concerned that a cap which applied to both administrative and technical assistance could lead to competition between the two kinds of support. If a shortfall occurs, we advocate supporting ongoing RAB operation before providing technical assistance." 6. DOD believes that the March 1, 1996 deadline for promulgating regulations - or losing funds - is too soon. It wants a year from enactment. It plans to continue administrative support while developing the regulation, but it will withhold technical assistance until the regulation is finalized. UNFORTUNATELY, this means that community groups will have to continue to wait for essential aid. 7. Noting that the Senate Appropriations Committee has proposed language providing for RABs at formerly used Defense sites where the cleanup cost exceeds $1 million, DOD suggests - as do most other stakeholders - that RAB formation be premised of a showing of community interest, not a cost estimate. 8. Finally, DOD feels that the Senate language would require too much reporting - a separate description of the activities for each of more than 200 RABs. It prefers the reporting requirements in the FY95 law.
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