From: | Lenny Siegel <lsiegel@igc.org> |
Date: | Wed, 14 Aug 1996 13:52:24 -0700 (PDT) |
Reply: | cpeo-military |
Subject: | DOD RAB RULE PROPOSED |
From: Lenny Siegel <lsiegel@igc.org> DEFENSE DEPARTMENT PROPOSES RAB RULE In the August 6, 1996 Federal Register (pp. 40764-40772) the Department of Defense Environmental Cleanup office proposed "regulations on the characteristics, composition, funding, and establishment of Restoration Advisory Boards (RABs)." Under the Fiscal Year 1996 Defense Authorization Act, the Defense Deparment is required to develop this rule to continue providing funds for RABs after September 15, 1996. Comments on the proposal are due by November 4, 1996. Official contact, in the cleanup office, is Marcia Read, 703/697-9793. The published background on the proposed rule includes a brief official history of the Federal Facilities Environmental Restoration Dialogue Committee (FFERDC), whose February, 1993 Interim Report triggered the formation of more than 200 RABs at over 230 active and closing military facilities. The Defense Department states - and as a member of FFERDC, I agree - "This proposal, developed consistent with the recommendations set forth in the FFERDC's Final Report, is consistent with existing DoD and EPA policy on RABs..." The Register notice adds, "DoD has structured this proposal to maximize flexibility for RAB members and installations nationwide." Essentially, the proposed rule legally anchors, as federal regulations, the general processes of forming and operating restoration advisory boards. It does not attempt to solve some of the problems that have erupted at dysfunctional RABs. It does not promise that DOD will always do what communities neighboring their installations want. But it strengthens the expectation that this generally successful, expanded form of public oversight is around to stay. I have not done a line-by-line comparison with the September, 1994 joint DOD-EPA guidance, but I spotted one clause that I don't recall in the earlier document: "DoD will not limit the ability of community RAB members who have business interests to compete for DoD contracts, if proper and appropriate assurances to avoid any potential conflicts of interest are issued." Given the strong interest, in many base communities, for providing local jobs and contracts through the clean-up program, this is a welcome clarification. Visibly absent from the current proposal is language establishing the TAPP (Technical Assistance for Public Participation) program, which is expected provide funds for providing independent technical support directly to community-based RAB members.. The cleanup office is working on this rule, building upon another key recommendation of FFERDC - and Congressional legislation - but it has had to restart its legal review based upon changes in the FY96 Authorization Act. DOD severed TAPP from the RAB rule in its effort to meet the Congressional deadline. Lenny Siegel | |
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