[CPEO-MEF] Compliance

[Lenny Siegel <lsiegel@cpeo.org>]

Stella asked:

"Is it possible to get a list of the military installations that
voluntarily comply with or even exceed environmental requirements?"

Each year the Defense Department publishes the "Defense Environmental
Quality Program Annual Report to Congress." It exhaustively documents
Pentagon spending on environmental compliance projects. The 1997 edition
is about 300 pages long, and I have a copy. But I don't know whether it
is available on the Web.

The report is a good list, but it doesn't really answer Stella's
question. It's a judgment call whether any party voluntarily complies
with environmental requirements, or whether it's simply doing its best
to avoid sanctions. The U.S. military, like other U.S.-based
organizations, tends to have a worse environmental record in countries
with weak environmental enforcement programs, so it appears that
environmental regulation and enforcement does make a difference.

And it's hard to measure environmental responsibility "beyond
compliance." In the absence of set standards, what is an environmentally
desirable objective?

Still, there are some cases that stand out. I recall learning, on a
visit to Eglin Air Force Base in Florida, how the installation had
replaced its multi-mile single-walled high-pressure fuel line with a
pipeline with secondary containment. The second wall wasn't required,
but it sure must reduce the chance of leaks.

Ironically, those types of projects are often difficult for
installations to fund, since the Defense Department has historically
given preference to those projects required to avoid enforcement
actions. Still, the base environmental office found a way to justify the
expense legally.



I didn't notice it during the debate over Section 8149 of the FY2000
Defense Appropriations Act, but the Environmental Quality report
summarizes the "Environmental Quality Fines and Penalties Assessed and
Paid Under Environmental Laws." I believe this covers all environmental
programs other than environmental restoration - that is, cleanup.

In fiscal year 1997, the Defense Department was assessed environmental
quality fines totaling $2,473,088. The lion's share of that total
consisted of two fines, levied by the State of Colorado, against the
Army for violations of the Resource Conservation and Recovery Action
(RCRA). Fort Carson was assessed $991,700. The Pueblo Chemical Depot was
assessed $1,048,600.

A separate table shows fines paid, which in fiscal year 1997 included
$702,339 in cash payments and $4,530,916 in supplemental environmental
projects, for a total of $5,233,255. The largest items included the
final Colorado penalties: a $2,950,000 supplemental project at Fort
Carson and $275,000 for a supplemental project at Pueblo combined with a
$235,000 fine. At Fort Wainwright, Alaska, the Army paid U.S. EPA
$200,000 for a RCRA violation and spent $1,002,920 on an associated
supplemental project.


Lenny
-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org
http://www.cpeo.org


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