From: | Lenny Siegel <lsiegel@cpeo.org> |
Date: | 30 Oct 2002 21:56:37 -0000 |
Reply: | cpeo-military |
Subject: | Re: Fwd: RE: [CPEO-MEF] RAB questions |
I've been reluctant to join in the discussion because my only Internet access today is from expensive booths at airports. I haven't had time to read everyone's comments. The root of the problem is not with the regulatory driver (CERCLA, RCRA, etc), but the budget mechanism. RABs at active bases and formerly used defense sites (FUDS) are funded through the Environmental Restoration (ER) accounts, which are restricted by statute. Under a strict interpretation, they cannot address issues that are funded under compliance, pollution prevention, or conservation programs. Activities that look like cleanup to us mere mortals - such as lead and asbestos abatement - may be compliance programs. Not all installations make this interpretation. Some accept discussion of non-environmental restoration issues as a small part of RAB meetings, since those discussions really don't cost the Defense Department anything substantial. At installations funded through the Base Realignment and Closure (BRAC) program, I believe there is more flexibility. I don't believe that the enviromental ceiling within the BRAC appropriation is fenced by statute in the same fashion, but I would appreciate it if someone with better knowledge of the law would confirm or correct my conclusion. Some of us have argued for several years that the Defense Department should expand RABs to become Community Advisory Boards, which could address the full slate of environmental issues at a base. This would help communities and the military alike to resolve issues such as site-specific encroachment. Vandenberg Air Force Base established a Community Advisory Board to encompass pollution prevention, and I believe that worked well. But attenmpts to expand scope elsewhere have run into the statutory, budgetary roadblock. Lenny -- Lenny Siegel Director, Center for Public Environmental Oversight c/o PSC, 278-A Hope St., Mountain View, CA 94041 Voice: 650/961-8918 or 650/969-1545 Fax: 650/961-8918 <lsiegel@cpeo.org> http://www.cpeo.org ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ | |
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