[CPEO-MEF] Better DOD Guidance Needed to Ensure That the Most Important Activiti

[CPEO Moderator <cpeo@cpeo.org>]

The following is an excerpt from the GAO report "ENVIRONMENTAL
COMPLIANCE
Better DOD Guidance Needed to Ensure That the Most Important Activities
Are Funded".

On page 7 of the report (page 10 of the file) GAO provides a simple
explanation of the classification system the Defense Department uses to
prioritize environmental quality activities.
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DOD’s and the services’ policies and processes for the environmental
quality
program do not always ensure that program funds are targeted to the most

important and appropriate environmental activities. Instead, GAO found
that some installations have funded low-priority or other activities
that were
ineligible under their environmental quality funding policies, at the
same
time that higher-priority activities were not funded. For example, at
certain
large installations that GAO visited, low-priority activities, such as
noise
monitoring, or ineligible activities, such as pest management,
landscaping,
and roof replacement, were funded while high-priority activities to
prevent
soil erosion were not.

At the root of the problem is DOD’s broad program policy that does not
provide specific guidance on what activities are eligible for the
program
and the resulting inconsistent interpretation and implementation of this

policy by the military services. DOD’s policy requires that all
high-priority
activities be funded, but gives the services broad discretion in how
this
policy is put into place. As a result, GAO found (1) inconsistencies
across
and within the services about which activities are eligible for
environmental
quality program funding and (2) the funding of some activities through
the
program that more closely relate to military operations or base
maintenance.
For example, some services use program funds for oil and hazardous
material spill response plans, equipment, and cleanup costs, while other

services require the organization responsible for the spill to pay for
the
cleanup portion of those costs. Similarly, service policies can differ
regarding responsibility for funding maintenance of structures such as
water and sewer treatment facilities and historic buildings.

Without a consistently implemented approach, there is no assurance
that DOD’s requirement to fund all high-priority activities is being
met.
Instead, some high-priority projects are being deferred. Generally,
these
deferrals involve projects that, although required by law, do not have
to
be completed by specific dates (e.g., surveys of properties required by
historic preservation law). Deferring such activities, however, can lead

to larger and more costly problems later. Moreover, to fund unbudgeted
emergency environmental activities, the installations may have to defer
other high-priority environmental program activities, obtain funds from
other sources at the installation such as maintenance activities, or
obtain
funds from higher command levels. Some services have recently indicated
that the availability of funds for environmental activities is likely to
get
worse in future years, because of expected reductions in their budgets
for
this program. Such constraints make a well-implemented prioritization
process even more important.

The full report can be viewed as a PDF file at:
http://www.gao.gov/new.items/d03639.pdf

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