Re:[CPEO-MEF] Regulatory Framework Profile

[CPEO Moderator <cpeo@cpeo.org>]

[POSTED BY Saul Bloom <saulbloom@mindspring.com>]

The lack of a blueprint of the regulatory framework underwhich
individual installation environmental responses take place has been
responsible for deal of the confusion and misinformation community
stakeholders deal with with regarding DoD's cleanup program.  This issue
in combination with the lack of uniformity in Restoration Advisory Board
management (owing largely to the lack of a RAB Rule) and other
outstanding issues with regard to ordnance were concerns raised by the
National Caucus of Restoration Advisory Board Community Members with
DoD, EPA and the Defense Environment Response Task Force between 1997
and 2000. They unfortunately continue to remain true today.  I think
CPEO is offering a very practical response to clarifying the existing
regulatory framework.  DoD and EPA would do well to implement this
recommendation although I have a concern as to how the veracity of the
individual base specific documents would be checked.   It has been Arc
Ecology's experience that individual base commands, as well as the
Department as a whole, can be quite creative with regard to the
interpretation of which and how laws pertain to their programs.  Equally
disturbing is the fact that frequently the EPA and State regulators
remain silent in the face of glaringly inaccurate interpretation of the
regulations.  Nevertheless, CPEO's recommendation is a good start on
this problem.

 Saul Bloom
 Arc Ecology

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