From: Lenny Siegel <lsiegel@igc.org>
COMPLIANCE ACCOUNTING
For several years, Congress has been trying to get a better grip on
Department of Defense (DOD) spending on environmental compliance
projects. A June, 1996 General Accounting Office (GAO) report provides
useful data on Defense environmental compliance construction projects,
but its critique of existing practices, if acted upon by Congress,
could seriously limit the flexibility of Defense activities to meet
real environmental challenges.
GAO found, "the services and DLA [the Defense Logistics Agency]
continue to vary the manner in which they classify and prioritize the
projects and determine the source of funds for them. The continuing
lack of such guidance and the inconsistencies inhibit congressional
oversight and DOD's program management." GAO is bothered that some
Defense activities fund projects out of construction accounts while
others fund similar projects out of operations and maintenance budgets.
Some bundle small projects as construction; others break up large
projects to fund through operations and maintenance accounts.
It recommended: "The [House Appropriations Subcommittee on Military
Construction] may wish to direct DOD to act now to ensure that projects
are consistently funded and reported for the fiscal year 1998 budget
submission to Congress or to no longer use environmental compliance to
justify higher priority for military construction funding."
GAO reports that the Pentagon disagrees: "DOD officials stated that the
environmental program, like other DOD programs, is integrated into the
appropriation process in accordance with applicable law and guidance,
and that commanders need the flexibility that the current congressional
and DOD guidance provide in determining when it is appropriate to use
operation and maintenance funds versus military construction funds for
smaller projects."
Based upon what I have seen at military bases, flexibility is essential
to spend money smartly on environmental compliance projects. The
successive aggregation of projects means that by the time budget data
gets to Congress it is almost impossible to know how valuable a
proposed project is.
Here is some of the data from the report:
Environmental Construction Compliance Spending, Fiscal Years 1994-1996
Project Category Millions of Dollars
Wastewater collection and treatment $305.5
Underground storage tanks $108.6
Water pollution abatement (including de-icing and fuel facilities) $39.6
Oily waste treatment $35.7
Fire training facilities $29.8
Sanitary facilities $27.4
Jet fuel delivery systems $25.2
Air pollution abatement (including heating plants and paint blasting
facilities) $23.6
Hazardous waste $18.9
Hydrant fuel systems $9.4
Metal preparation facility improvements $7.9
Central wash facility $6.3
Hazardous materials storage $3.5
Other $47.9
Total $689.3
Compliance Construction Estimates for Fiscal Year 1997
Wastewater collection and treatment $19.6
Oily waste collection $17.2
Landfills $15.6
Air pollution abatement $7.6
Basewide compliance $5.7
Underground storage tanks $3.9
Engine test facility upgrade $3.8
Hazardous materials storage $3.2
Boiler conversion $3.1
Tank trail erosion mitigation $2.0
Water pollution abatement $1.2
Drainage system upgrade $0.5
Total $83.5
Single copies of "Environmental Compliance: Continued Need for Guidance
in Programming Defense Construction Projects," GAO/NSIAD-96-134, June,
1996, like other GAO reports, are available for free from GAO at
202/512-6000.
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