80% CLEANUP GOAL

[Aimee Houghton <aimeeh@igc.org>]

From: Aimee Houghton <aimeeh@igc.org>

Questions For The Record
Senate Armed Services Committee, Readiness Subcommittee
Environmental Security Programs

April 5, 1996
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80% CLEANUP GOAL

 Senator McCain: Section 323 of the National Defense Authorization
Act for Fiscal Year 1996 expressed the sense of Congress that by the 
end of FY 1997 no more than 20% of annual DERA funds should be spent 
for administration, support, studies, and investigations.
 (a) Do the military departments anticipate that this goal will 
facilitate cost effective and efficient cleanup? If not, why not?
 (b) Have the military departments esstablished a cost effective 
and efficient means of ensuring that DERA funds are primarily used for 
actual cleanup activities? Please describe the steps taken to date by 
the military departments?
 (c) How much of the FY 1996 DERA budget is projected to fund 
actual cleanup?

 Ms. Goodman: (a) Establishing a hard and fast number like the 
80% percent goal of DERA funds going to cleanup on an annual basis is 
counter-productive and creates a perverse incentive to spend more money 
for cleanup than might be required. It could lead to inefficiences and 
cost increases in the overall program. A numeric goal could encourage 
selection of expensive remedies for the purpose of meeting the 
financial goal, and discourage investment in studies that could result 
in more cost-effective remedies being selected. The numeric goal 
creates incentives not to identify and implement cost efficiencies in 
proposed remedial actions, such a through the use of natural 
attenuation and phytoremediation. An example of a study that has led 
to a cost effective decision occurred at Tobyhanna Army Depot where the 
groundwater is contaminated with a variety of solvents. Initially, EPA 
and state regulatory agencies argued for a conventional pump and treat 
system to address contamination. Once the source of the contamination 
was removed, continued monitoring of the groundwater provided evidence 
that the concentration of solvents and the extent of the plume was 
decreasing through natural attenuation. An argeement will soon be 
signed in which the regulatory agencies have agreed to accept a natural 
attenuation remedy. This remedy will avoid the spending of more than 
$5 million by not installing a conventional pump and treat system. 
Tobyhanna is not an isolated example. Without appropriate and 
cost-effective investigations the nature and extent of contamination 
cannot be adequately understood. As a result DOD, the regulatory 
agencies, and the affected communities will not have the information 
necessary to determine the best, most effective, and most appropriate 
cleanup actions. Cleanups that take place may exceed what is really 
needed or may result in costly re-work if cleanup objectives are not met.
 (b) DOD has a mature strategy and systematic process in place 
to establish, measure, and continuously refine goals for the 
environmental program. DOD's approach is aimed at maintaining the 
momentum that has been gained over the past several years, and 
establishing consistency and stability of the program in the face of 
destabilizing funding reductions. DOD's goals and investment strategy 
are based on reducing risk and setting priorities for appropriate 
investigation and cleanup work in accordance with those risk reduction 
goals. DOD continues to institute improvements to program and site 
management efforts to reduce the cost and increase the speed of 
investigation work. The program has a bias for action and a natural 
trend of expending increasingly more dollars an actual cleanup. Direct 
expenditures on studies and program management have decreased from 59% 
in FY93 to 36% in FY96 while cleanup has increased from 41% in FY93 to 
64% in FY96. DOD's goals and initiatives are shaping and moving the 
program towards the most appropriate and effective investment in 
reducing risk to human health and the environment. DOD is concerned 
that placing a numeric rather than qualitative goals on expenditures 
for "studies" versus "cleanup" actions may result in false economy and
ultimately limit return on investment
 (c) The FY96 President's budget request was based on 
projections that would have resulted in investing 69% in actual 
cleanup. The $300 million rescission in FY95, after the President's 
budget for FY96 had been submitted, coupled with Congress' reduction of 
$211 million from the President's budget request for FY96, is projected 
to result in 64% of the FY96 DERA budget funding cleanup. For FY97, 
the Department projects investing over 73% in actual cleanup.