ARMY RAB POLICY

[Aimee Houghton <aimeeh@igc.org>]

From: Aimee Houghton <aimeeh@igc.org>

****** WARNING: This is a long file. ******

The following is the Army's newest policy for the role of RABs in 
environmental cleanup at Army installations.

Aimee Houghton

 ******************

DEPARTMENT OF THE ARMY
Office of the Assistant Secretary
Installations Logistics and Environment
110 Army Pentagon
Washington DC 20310-0110

May 7, 1996

MEMORANDUM FOR ASSISTANT CHIEF OF STAFF FOR INSTALLATION 
MANAGEMENT

SUBJECT: Issuance of Army Policy - The Role of Restoration Advisory 
Boards (RAB)s in Environmental Cleanup

 Establishing and fostering an informed community is key to 
successful environmental cleanup at Army installations. In light of 
funding constraints and diminishing resources, it has become paramount 
that Army installation commanders seek and encourage public involvement 
early in the cleanup process by way of RABs.

 Sharing cleanup plans and soliciting stakeholder advice in the 
decision making process will ensure cleanup levels that are consistent 
with a reasonably anticipated future land use.

 Attached, for immediate Army-wide distribution and implementation,
is the Army policy regarding the appropriate role of RABs in relative risk 
evaluation and sequencing of cleanup activities. Request existing Army 
guidance regarding RABs be revised to incorporate the implementation 
and monitoring of this policy.

 My point of contact is Mr. Rick Newsome. (703) 614-9531.

 Robert M. Walker
 Assistant Secretary of the Army
 (Installations, Logistics & Environment)

Attachment

 __________________________________

ARMY POLICY: ROLE OF RESTORATION ADVISORY BOARDS (RABs)
IN ENVIRONMENTAL CLEANUP

 In keeping with Department of Defense (DOD) guidance on 
environmental restoration at Army installations, the Army will provide 
opportunities for regulators and other stakeholders involvement in 
risk-based priority-setting decisions for environmental cleanup at 
Active Sites, Base Realignment and Closure (BRAC) Installations, and 
Formerly Used Defense Sites (FUDS). Because our RABs include regulators 
and representation of diverse community interests, they will play a 
significant role in this process.

 In addition to RABs, BRAC installations also receive advice 
which may affect cleanup priorities from Local Redevelopment Authorities 
(LRAs). Accordingly, BRAC installations will coordinate the results of 
risk-based cleanup evaluations with both RABs and LRAs.

 Installations will consult with their RABs at BRAC installations 
on the sequencing of restoration activities based an available funding.
RABs will be fully involved in this process as follows:

 - Where RABs have been convened, installations will review 
membership and membership selections process in accordance with both 
the April 11, 1994, Army Restoration Advisory Board guidance and the 
September 1994 DOD/EPA RAB Guidelines. The process shall provide for 
diverse community representation, as well as regulator representation.
Where RABs have not been convened, the installations through community 
involvement/outreach techniques, shall educate the public about RABs 
and solicit their feedback. If it is determined that there is not 
sufficient community interest to sustain a RAB, the installation will 
document their efforts and develop a plan to monitor and address sudden
or evolving changes at installations.

 - Installations will provide RAB members instruction on the 
relative risk process, the budgeting process, and how these affect the 
sequencing of restoration actions so that RABs can provide informed 
advice.

 - Prior to submission of cleanup funding needs in the 
programming process, installations will encourage RABs to participate 
in the initial development and/or assessment of relative risk 
evaluations of their sites.

 - Installations will develop their budget requests in 
accordance with the restoration program guidelines, with consideration 
given to RAB advice on sequencing (including relative risk evaluations 
and other factors important to the community and the Army). When a 
RAB's recommended sequencing varies from the Army's original proposal, 
installations will record the differences (and rationale for them) 
and provide this information to their respective MACOMs. In the event 
the installation decision does not coincide with the advice of the RAB 
regarding sequencing , feedback should be provided to the RAB 
explaining the rationale for the installation's determination and what 
requests were provided to higher headquarters.

 - Effective management of restoration activities is a dynamic 
process, often requiring reallocation of restoration funding during 
the fiscal year. Cleanup decisions should take into account both 
program management considerations and RAB advice. As installation 
specific allocations are made, the installations will advise the RAB 
of the funds received, environmental restoration projects funded or 
to be funded, and work remaining. Installations will discuss funding 
and priorities with their RABs and provide the opportunity for the 
RABs to update their recommendations based on the most current 
information. The installations will fully consider the RAB's advice 
along with other management issues in making cleanup decisions.

 - Determination of the appropriate type and level of cleanup, 
of properties being transferred from Army control, is dependent upon 
reasonably anticipated future land use. Future use determinations are 
made by the federal agency, state, tribal, or local authorities that
will have jurisdiction over the land to be transferred. However, 
the communities that are affected by cleanup decisions on properties 
being transferred should be provided a significant advisory role in 
the determination of appropriate cleanup and response actions and in 
how future use determinations will be used in making cleanup decisions.
In order to achieve community acceptance, being one of the nine 
criteria for remedy selection specified in the National Contingency 
Plan, the Army will provide public stakeholders and RAB members with 
all relevant information on cleanup alternatives, including implications 
of land use choices and corresponding cleanup levels and remedies.
Stakeholder and RAB advice and recommendations will be considered in 
the determination of the appropriate remedy to support the selected 
land use.