DOD's RRPI Fact Sheet on the Clean Air Act

[Lenny Siegel <lsiegel@cpeo.org>]

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Military Basing, Training and the Clean Air Act
Source: Department of Defense

Legislative clarification is the only practical way to achieve the
necessary balance between military needs and the goals of the Clean Air
Act (CAA).

Background:   The Department of Defense (DoD) regularly relocates forces
among installations throughout the United States and the world in order
to best position them for potential use and to optimize training
opportunities.  The Clean Air Act's "general conformity" requirement,
applicable only to federal agencies, has threatened deployment of new
weapons systems and the movement of forces among installations despite
the relatively minor levels of emissions involved.  Our military forces
must routinely operate out of their home bases and transit to nearby
training ranges to maintain readiness.  Without a reasonable time period
to meet Clean Air Act conformity requirements, the ability to operate in
non-attainment regions is threatened.

* The planned movement of F-14s from Naval Air Station (NAS) Miramar to
NAS Lemoore in California was only possible because of the fortuity that
neighboring Castle Air Force Base in the same air-shed had closed,
creating offsets.  The same coincidence enabled the home basing of new
F/A-18 at NAS Lemoore.
* The movement of F/A-18s from Cecil Field, Florida to NAS Oceana in
Virginia was made possible only by chance, since Virginia was in the
midst of revising its State Implementation Plan and was able to
accommodate the new emissions.  The Hampton Roads area in which Oceana
is located will likely impose more stringent limits on ozone in the
future, reducing the State's flexibility.

Discussion:  The legislation would provide more flexibility under the
Clean Air Act by allowing DoD and the State a three year period to
accommodate or offset emissions from new military readiness activities
in the State Implementation Plan.
* The provision is necessary to facilitate the relocation of forces
critical to military transformation and the efficient use of forces.
* New weapons systems often use higher performance engines, causing them
to emit more NOx than the legacy systems they are replacing (they will
also typically emit lower levels of VOCs and CO).  Without greater
flexibility, the conformity requirement could be a significant obstacle
to the deployment of new weapons systems.
* The provision applies only to the new readiness activity, e.g. the new
weapon system, not to any support activities or relocation-related
construction (such as the construction of new housing or mess halls).
* The provision holds States harmless for emission increases that may
violate air standards.  

Impacts and Facts in Support:  The new legislation would greatly
facilitate the movement of military units among installations in order
to best position them for potential use and to optimize training
opportunities.  The new emissions this proposal would temporarily
authorize are typically less than 0.5% of the total emissions in air
regions-several hundred tons in air sheds with emissions budgets of tens
of thousands of tons.


--


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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