Planning and Management Failures Cause Clean Water Act Violations
Abstract
In a study of notices of violation (NOVs) issued under the Clean Water Act (CWA), LMI found that recurring systemic problems exist. Many installations must deal with inadequate training, inadequate work forces, delayed funding, and divided responsibilities. The Army must identify the responsible persons, hold them accountable, and provide them with adequate and timely funding and personnel. Most administrative/procedural violations are caused by a lack of knowledge about the regulatory requirements at the installation level. Personnel needing to be aware of CMA provisions include environmental professionals, facility operators, and the soldiers and civilians working on the installations. The Army should ensure that the responsible environmental staff members and facility operators at each installation are trained adequately and institute aggressive compliance-awareness programs. Unlike other regulatory programs, numerous NOVs are issued under the CWA for causing pollution (i.e., exceeding permitted discharge levels). Installations have difficulty implementing corrective actions because of the limited availability of in-house technical experts, and because of limited funding for contract support, for capital projects, and for routine maintenance and upgrades. The Army should establish adequate technical expertise and a forward- looking system to ensure that its treatment systems can meet standards now and in the future.
Document Details
- Document Type
- Technical Report
- Publication Date
- Sep 01, 1993
- Accession Number
- ADA276607
Entities
People
- Douglas M. Brown
- Robert J. Baxter
Organizations
- LMI