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Introduction No Air Force project, regardless of its importance, can be implemented and completed unless it is funded. Increased budgetary constraints and competition for scarce funds present a challenge to all Air Force environmental program managers. Successfully executing environmental projects depends upon understanding the various funding sources, procedures, and their applicability to a particular project. The purpose of this fact sheet is to familiarize readers with the environmental funding process, as well as associated policies and guidance documents. Governing Documents, Policy, and Guidance Office of Management and Budget (OMB) Circular No. A-106, Reporting Requirements in Connection with the Prevention, Control, and Abatement of Environmental Pollution at Existing Federal Facilities, 31 December 1974. This document requires all federal agencies to develop a Pollution Abatement Plan (commonly referred to as the FEDPLAN or the "A-106 Report") to track the status of all environmental projects, regardless of the source of funding. The FEDPLAN, including annual status report supplements, is used by the Environmental Protection Agency's (EPA) Office of Federal Activities (OFA) as a management tool to justify the environmental portion of the President's annual budget. Office of Management and Budget (OMB) Circular No. A-11 (revised), Preparation and Submission of Budget Estimates, 23 June 1997. This circular provides detailed guidance on the preparation and submission of federal agency budgets. Executive Order (EO) 12088, Federal Compliance with Pollution Control Standards, 13 October 1978. This EO requires federal agencies, in cooperation with the EPA, and State and local agencies, to meet all applicable pollution control requirements. It also requires federal agencies to budget sufficient funds to maintain compliance and correct non-compliance in their environmental programs. EO 12088 delegates responsibility to the head of each federal agency for ensuring that all necessary actions are taken for the prevention, control, and abatement of environmental pollution. On an annual basis, and to meet the requirements of OMB A-106, each agency must submit a plan for the control of environmental pollution (FEDPLAN) to the Director of the OMB through the EPA Administrator. (Note: For overseas facilities where EPA has no jurisdiction, each federal agency is responsible for complying with environmental standards generally applicable in the host country or jurisdiction.) EO 12856, Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements, 3 August 1995. This EO requires, in part, federal agencies to place high priority on obtaining funding and resources needed to implement pollution prevention strategies, plans, assessments, and other activities and projects as required by the order. The federal agency must identify, request, and allocate funds through line-item or direct funding requests as required by the pollution prevention and abatement planning process, and through agency budget requests as set forth in OMB A-106 and OMB A-11, respectively. In addition, EO 12856 requires federal agencies to apply, where practicable, life cycle analyses and total cost accounting principles to environmental projects. Air Force Policy Directive (AFPD) 32-70, Environmental Quality, 20 July 1994. This directive establishes broad policies for the Air Force to carry out its commitment to cleaning up environmental damage resulting from its past activities; meeting all environmental standards applicable to its present operations; planning its future activities to minimize environmental impacts; responsibly managing the irreplaceable natural and cultural resources it holds in public trust; and eliminating pollution from its activities wherever possible. Chapter 4 directs the Air Force to seek sufficient funding to carry out all environmental activities needed to meet its legal obligations. Air Force Instruction (AFI) 32-7001, Environmental Budgeting, 9 May 1994. This AFI, currently under revision, provides guidance on identifying, developing, and processing funding requirements necessary to meet environmental standards at all Air Force installations. Chapters 2, 3, 4, and 5 address budget elements for cleanup, environmental compliance, conservation resources, and pollution prevention programs, respectively (i.e., the four environmental "pillars"). Each chapter presents guidance on a variety of budget-related issues including funding sources, documentation, project prioritization, exclusions, and management. Attachments to the AFI provide examples of projects and services categorized under the environmental program "pillars." Also included are lists of projects specifically excluded from environmental funding. NOTE: HQ USAF/ILEV has issued the following memoranda to supplement AFI 32-7001 until it is revised:
Copies of the above memoranda, including attachments, are available from PRO-ACT. AFI 32-7002, Environmental Information Management System, 31 May 1994. AFI 32-7002 implements Air Force Policy Directive (AFPD) 32-70, Environmental Quality, by providing guidance and procedures to standardize use of the Work Information Management System - Environmental Subsystem (WIMS-ES). WIMS-ES is an information storage and management system designed to help installations manage their environmental programs and to enable efficient reporting of environmental data to Major Commands (MAJCOMs) and Headquarters United States Air Force (HQ USAF). The AFI is used in conjunction with the WIMS-ES User's Manual discussed below. (NOTE: WIMS, after having been converted from a Wang-based platform to a UNIX-platform, is now known as the Interim Work Information Management System [IWIMS] in anticipation of a future transition to a completely new IM system discussed below under "Information Management Systems, Tracking, and Funding Projection.") Pollution Prevention to Achieve Compliance, HQ USAF/ILEV Memorandum, 20 August 1997. This memorandum provides guidance and a philosophy for addressing environmental projects. The stated challenge is to ensure compliance and pollution prevention (P2) functions at all levels work together to identify and fund the best environmental solution with available resources, and to use pollution prevention solutions as the first choice to ensure compliance. The memorandum also states that the environmental management hierarchy (source reduction, recycling/reuse, treatment, and disposal) must be applied when developing solutions for every potential compliance requirement. Pollution Prevention to Achieve Compliance, HQ USAF/ILE Memorandum, 20 November 1997. This memorandum encourages the aggressive pursuit of cost-effective pollution prevention projects and activities to reduce future budget requirements, without deferring current high-priority funding needs. The memorandum challenges MAJCOMs to increase P2 funding by 20 percent by fiscal year (FY) 03 (over FY 1996 levels), along with a corresponding decrease in environmental compliance (EC) funding requirements. Additional clarification on the issue of transferring funds from EC to P2 is provided in the 28 January 1998 HQ USAF/ILE Memorandum: Transferring Funds from Environmental Compliance to Pollution Prevention. User's Guide to the WIMS-ES A-106 Software, Headquarters Air Force Civil Engineer Support Agency (HQ AFCESA), 19 April 1994. This software provides guidance for use of the WIMS-ES system in its original Wang-based platform. Although the system is now in a UNIX platform, and referred to as IWIMS-ES, this guide still provides good background information, as well as guidance that can be applied to the A-106 module in its current form. IWIMS-ES and the A-106 Module - AFMC Guide for Compliance, Conservation, and Pollution Prevention Use of the Module, Headquarters Air Force Materiel Command (HQ AFMC), 20 May 1998. This guide provides detailed instructions applicable Air Force-wide for entering data into the A-106 Module of the IWIMS-ES system. It also includes guidance for updating records, generating reports, and selecting funding sources. A-106 Completion, AF P2 Toolbox, Planning and Programming Process, http://www.afcee.brooks.af.mil/eq/p2toolbox/flowchart/wtprgfun.htm This on-line guidance developed by Headquarters Air Force Center for Environmental Excellence's Environmental Quality Directorate (HQ AFCEE/EQ) offers step-by-step instructions for entering data into the IWIMS-ES A-106 Computer Module. Pollution Prevention Process Flowchart, AF P2 Toolbox, http://www.afcee.brooks.af.mil/EQ/p2toolbox/flowchar.htm. These links provide a visual representation of three processes involved in funding and achieving pollution prevention. These processes-Planning & Programming, Budgeting, and Execution-are all portrayed in flow-chart format on several linked pages. The budgeting process graphically illustrates the steps associated with developing the Financial Plan (next year's budget), Out-of-Cycle (current year) requests, and Program Objective Memorandum (POM - future year) requests. AETC Environmental Planning, Programming, Budgeting and Execution Handbook, January 1998. Though targeted toward the AETC, this guidance provides useful background information about the AF environmental programming and budgeting process, as well as additional program-specific guidance. [NOTE: Air Combat Command (ACC) has also developed guidance published in ACC manual 32-7051, "Environmental Quality Handbook." The point of contact for this guidance is Capt Freeman, HQ ACC/CEVQP, DSN 574-9309. Air Force Materiel Command (AFMC) is in the process of developing similar guidance. They anticipate completion of this guidance summer of 2000.] Federal Facility Pollution Prevention Project Analysis: A Primer for Applying Life Cycle and Total Cost Assessment Concepts, USEPA Federal Facilities Enforcement Office (FFEO), June 1995. The application of Life Cycle Analysis and Total Cost Accounting principles, when practicable, to P2 projects is required under Section 4-404 of EO 12856. This document introduces and describes several analytical tools that can be used to help users identify and quantify the financial and environmental benefits of P2 projects and other opportunities that require funding justification. Federal Agency Pollution Abatement Plan (OMB A-106) - A Handbook for Understanding the OMB A-106 Process, Office of the Deputy Assistant Secretary of Defense (Environment), 1 February 1988. This document presents background on OMB Circular A-106, its requirements, and how the Department of Defense will use the A-106 reporting process to: 1) identify proper funding requirements; 2) manage and transmit information to the OMB and EPA; and 3) achieve compliance with applicable environmental laws. DRAFT Federal Agency Environmental Management Program Planning Guidance, EPA FFEO, June 1996. This guidance is intended for both providers and users of information generated by the FEDPLAN process (formerly the A-106 process), the objective of which is to provide a mechanism for characterizing environmental activities, establishing priorities, and identifying funding requirements. The guide includes an overview of the FEDPLAN process, descriptions of each element, and an instruction kit for completing new program plans and updating existing plans. Additional P2 guidance is also provided, including the reorientation required by new laws and EOs promoting the use of P2 solutions to achieve environmental compliance. EPA Federal Facility Pollution Prevention Planning Guide, EPA Office of Enforcement and Compliance Assurance, EPA 300-B-94-012, November 1994. This document has a narrow focus and is designed to help federal facility environmental coordinators develop pollution prevention plans as required under Section 3-302(d) of EO 12856. Meeting the Challenge: A Summary of Federal Agency Pollution Prevention Strategies, EPA, and Pollution Prevention in the Federal Government: Guide for Developing P2 Strategies for EO 12856 and Beyond, EPA, April 1994. These are general guides designed to assist federal agencies in fulfilling the P2 planning provisions of EO 12856. Management Guidance for the Defense Environmental Restoration Program, Deputy Under Secretary of Defense (Environmental Security) (DUSD[ES]) Memorandum, 17 March 1998. This document provides guidance for the DoD environmental restoration program, including the planning, programming, budgeting, and execution process. Guide to the DoD Environmental Security Budget, DoD/ECOS, October 1998. This joint document developed by the DoD and the Environmental Council of States (ECOS) describes how the military services and defense agencies determine requirements, plan, make decisions, and ultimately budget for their environmental protection programs. The DoD Budget Process The entire DoD budget process is called the Planning, Programming, and Budgeting System (PPBS). The PPBS process typically extends six or seven years into the future and is reassessed each year through the Program Objective Memorandum (POM) process; a process that analyzes the budget and makes adjustments before the next budget is prepared. The yearly POM process involves program managers, military commands, DoD components, and the OSD, and takes approximately eight months to complete. Most major funding decisions in DoD are made during the POM process, not during the actual budget formulation, which occurs afterward and must conform to OMB parameters. Funding Environmental Projects The DoD's annual environmental budget primarily consists of various Cleanup Budgets and Environmental Quality (EQ) Budgets. Each military component has an Environmental Restoration (ER) account for active bases and another cleanup account for closing bases funded under the Base Realignment and Closure (BRAC) law. The Defense EQ budget funds projects for environmental compliance, P2, and natural/cultural resources protection. In recent years, the distinction between compliance projects and P2 projects has become increasingly blurred. Military components, including the Air Force, have initiatives underway to ensure that environmental compliance is achieved by means of pollution prevention. As previously mentioned, the Air Force Civil Engineer recently published two policy memoranda aimed at accomplishing this initiative by establishing a goal for the transfer of 20% of the EC budget to P2 by FY03. Restoration, BRAC, and EQ budgets have their own unique considerations that must be addressed during the budget development process. These considerations are summarized below for restoration and compliance/P2. BRAC funding is a separate process that is not discussed in this fact sheet.
Environmental Restoration Projects
At most installations, partnering efforts between military environmental program managers, environmental agencies, and the community have proven effective in prioritizing restoration projects in a way that is protective of the public, and within budget. The Air Force Installation Restoration Program (IRP) is funded by the Air Force Environmental Restoration Account (AF-ERA) through Congress' Defense Appropriations Act. The IRP focuses on cleaning up contamination from past DoD activities and ensuring the Air Force meets its lawful obligations to eliminate threats to public health and restore natural resources for future use. All AF IRP projects have a Remedial Project Manager (RPM) who manages the project, including budgeting costs, and is usually from the Environmental Management Flight/Section of the installation's Civil Engineer Squadron.
For funding purposes, the Air Force categorizes IRP projects into the following three groups:
Group A - Program Management and Support
A detailed listing of the types of projects eligible for funding in these categories can be found in AFI 32-7001, Environmental Budgeting, Attachments 2 & 3. Additional information about the Air Force's IRP can be found in PRO-ACT's January 1999 fact sheet: Air Force Installation Restoration Program (IRP).
Conservation Resources Projects
Environmental Quality Projects
Level 0 projects are "recurring" and seek to maintain compliance.
The above definitions from the 1 July 1999 EQ Funding Guidance supersede those found in AFI 32-7001. The EQ Funding Guidance does not otherwise supersede the AFI. A detailed matrix of the types of EQ projects eligible for funding can be found in Attachment 4 to AFI 32-7001.
Looking Ahead: Compliance through P2 Projects
With the Air Force's increasing emphasis on achieving compliance goals through pollution prevention, P2 projects are becoming a higher funding priority. As a reflection of the Air Force Civil Engineer's goal to shift compliance dollars to fund P2 initiatives, AFI 32-7080, Pollution Prevention Program, is currently under revision to link compliance projects and P2 projects into "Compliance through Pollution Prevention (CTP2)" projects. The purpose of the CTP2 process is to reduce environmental compliance costs along with environmental, safety, and occupational health (ESOH) risks. Instead of the previous environmental "pillars," the new AFI 32-7080 will categorize CTP2 objectives by program areas to include Air Quality, Water Quality, Hazardous Materials (HAZMATs), Solid Waste, Affirmative Procurement, Conservation, Sustainable Facilities, and Other Program Areas.
To proactively identify and address potential compliance vulnerabilities, the CTP2 process uses the environmental management hierarchy to preferentially apply cost-effective P2 solutions that achieve compliance while reducing total ownership costs (TOC, or Life Cycle Costs [LCC]), reduce risks as determined through the operational risk management (ORM) process, improve environmental and mission performance, and reduce any other compliance requirement. This combination of environmental compliance costs and ESOH risks is referred to as the compliance burden. The Air Force is anticipating that the new AFI 32-7080 will be published early next year.
In May 1996, the Headquarters Air Force Civil Engineer Support Agency's (HQ AFCESA) Civil Engineering Automation Steering Group (ASG) announced its "Automation Vision" of the next generation of computer systems and applications to support base-level Civil Engineer organizations. The new automation system, called the Automated Civil Engineer System (ACES), will replace the existing IWIMS system, including its various subsystems (i.e., IWIMS-ES). ACES will convert existing IWIMS data files to a more versatile and efficient relational database management system. The new ACES system will use the Oracle database engine to store the A-106 data tracked by the Civil Engineer Squadrons. Installation of the final ACES system at all Air Force installations is expected in January 2000. For more information about the Automation Steering Group (ASG) and its activities, contact HQ AFCESA's Operations Support Directorate, Automation Support Division at DSN 523-6455, or visit their Automation Support WWW site at http://www.afcesa.af.mil/Directorate/ceo/Automation/Automation.htm.
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