[CPEO-MEF] GAO's compliance findings - some comments

[Lenny Siegel <lsiegel@cpeo.org>]

On June 18, we published the summary and a link to a June 2003 report
from the General Accounting Office: "ENVIRONMENTAL COMPLIANCE: Better
DOD Guidance Needed to Ensure That the Most Important Activities Are
Funded." See http://www.cpeo.org/lists/military/2003/msg00685.html.

I've just reviewed that report, and three significant issues emerge.

1) As it often does, GAO is looking for universal, uniform mechanisms
for allocating government money. As an auditing agency, that's its job.
However, as I learned when the Federal Facilities Environmental
Restoration Dialogue Committee (FFERDC) tackled the prioritization of
cleanup activities in the early 1990s, there needs to be flexibility in
the field. It's impossible to respond to local concerns, whether they be
expressed by Restoration Advisory Boards, local governments, or base
employees, if all spending decisions are determined by formula. 

At FFERDC, we came up with the concept of "risk plus other factors" for
setting priorities. Under that approach, other factors could "bump" or
"trump" priorities established because of calculated risk. (I don't
think my "bump-trump" language made it into any of our reports.)

2) Strict interpretation of compliance categories, as suggested by GAO,
discourage prevention activity. The GAO report summarizes an action NOT
taken at Vandenberg Air Force Base, because of spending rules, even
though early action would have protected the environment and saved money:

"Officials at other installations we visited also cited concerns about
the deferral of certain environmental activities, particularly those
that may not have a compliance deadline and are thus considered lower
priorities. For example, a senior environmental official at Vandenberg
Air Force Base described how the rapid spread of Argentinean pampas
grass, an invasive species, had resulted in the U.S. Fish and Wildlife
Service listing the grass as a major threat to four federally endangered
plant species on the installation and requiring that the Air Force
eradicate the grass - at a cost of approximately $1 million. According
to Vandenberg environmental officials, they had requested environmental
funding for the project when the grass was initially found because they
believed the cost to eradicate it at that time would be minimal compared
to the future expense if the grass were left uncontrolled. However, the
installation could not obtain environmental quality funding for the
project because it was a Class III activity and Air Force policy
prohibits funding of lower priorities. The project was not funded until
the U.S. Fish and Wildlife Service listed the grass as a major threat to
the endangered species."

3) GAO is on the mark, however, in warning that environmental funds are
being diverted to plug gaps in other programs:

"Several environmental officials acknowledged that characterizing
certain activities as environmental, or 'painting them green,' rather
than as facility maintenance, restoration, or modernization improves the
chance of their being funded. According to these officials,
installations may seek to fund maintenance and infrastructure projects
through the environmental quality program because of the overall
shortage of funds for facility maintenance, restoration, and
modernization. According to DOD officials, funding for facility
maintenance has been inadequate for many years, resulting in
deteriorated facilities at many installations."


Public stakeholders rarely pay much attention to activities funded
through the Defense Department's compliance budgets, even though they
total about as much as the combined cleanup budgets. Perhaps that's
because there are fewer mechanisms for community involvement. Perhaps
it's because much compliance activity, such as upgrading wastewater
treatment systems, is routine. Still, it's important to ensure that
compliance funding addresses important environmental concerns in a
timely, efficient, transparent manner.

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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