WA STATE WEIGHS IN ON DEVO

[Aimee Houghton <aimeeh@igc.org>]

From: Aimee Houghton <aimeeh@igc.org>

WASHINGTON STATE WEIGHS IN ON DEVOLVEMENT

The Department of Ecology in Washington has made their concerns about 
the devolvement of DERA known. In a June 13th letter that went to the 
Washington Congressional delegation, among other representatives, 
Department of Ecology Director, Mary Riveland expressed the concern 
that "devolvement could result in the destablization of the DOD 
environmental cleanup program...."

Below are the major issues brought up in the letter:

 "To date, there has been no meaningful involvement or discussion with 
 states or other affected stakeholders on devolvement. Contrary to 
 statements in the Report ("Report to Congress on the Devolvement of the 
 Defense Environmental Restoration Account"), regulators were not 
 involved during DOD's consideration of devolvement and have not 
 accepted the Report's conclusions.

 "There is a potential destabilization of the environmental cleanup 
 program as a result of competition between environmental restoration 
 program obilgations and other service obligations. To date, no one has 
 explained how devolvement will affect cleanup budgets, cleanup 
 agreements, the Defense State Memorandum of Agreement program (an 
 agreement reached between Washington State and DOD in 1994), or 
 Restoration Advisory Boards. Further, each service's funding needs may 
 influence priorities and the level of funding provided to environmental 
 restoration.

 "State participation with the services in relative risk and risk 
 management decisions may be decreased and/or rendered ineffective. 
 DOD's prioritization system may be subject to DOD obligation external 
 to the enviornmental restoration program.

 "Commitments have been made by DOD through Federal Facility 
 Agreements, consent orders, and the Defense State Memorandum of 
 Agreement that they would work with the states to request sufficient 
 funds for cleanup. Devolvement could be viewed as an abrogation of 
 these commitments.

 "The Administration of the Defesne State Memorandum of Agreement will 
 become cumbersome, less flexible, more costly, and could prevent 
 cleanups. Administration of the program will require us to maintain 
 seperate accounts for the service branches, which will result in 
 increased administrative burden (including cost), and may potentially 
 impair the ability of the state to adjust available resources to the 
 needs of the installation.

"Devolution should not be supported until these issues are addressed. 
We propose requiring DOD and the services to work with the states 
during FY97 to resolve these issues. Congress should authorize a 
committee to include DOD, States and other significant interest groups 
to address the above and other issues to stabilize the cleanup program. 
This committee should be funded by DOD, and they should submit 
committee findings back to Congress by April 1, 1997. Devolution 
should occur only if it is demonstrated that replacement of the current 
centralized Defense Environmental Restoration Account can advance the 
environmental restoration of the air, land, and water resources of our 
nation."

Aimee Houghton