Environmental Remediation Contracting: Summary of a Symposium (1994)

David Methot

Air Force Center for Environmental Excellence

• Grafted onto field construction programs

• Lack of experience with cost contracts

• Lack of historical data on costs of environmental tasks

• Difficulty of dedicating sufficient staff

• Contracting challenges

  • Can't identify scope

  • Risk difficult to quantify

  • Each case different

  • Process dictated by law

  • Process time and cost driven

  • Must respond to congressional mandates for base closure

  • Threat of litigation high

  • Criteria controlled by others

  • Threat of civil and/or criminal action

• Different agencies use different contracts and procedures, which reflect agency organizations and experiences

• Types of contracts:

  • Architect-Engineer contracts—provide investigations, studies and/or design capabilities at hazardous waste sites.

  • Rapid response contracts—perform removal actions in a timely manner at hazardous waste sites.

  • Remedial action contracts—provide permanent cleanup actions at hazardous waste sites upon completion of design

  • Total environmental restoration contracts (Army)

• Comprehensive long-term environmental action, Navy (CLEAN) contracts

• Full Service Remedial Action Contracts (Air Force)

• Conclusions:

  • Tailor contracting methods to requirements

  • No one single solution

  • Be innovative

  • Determine unique requirements

  • Consider all contracting methods

  • Combine contracting techniques

  • Use most effective method or combination of methods

  • Major problem—contract administration

• Air Force Center for Environmental Excellence (AFCEE)

• Human systems center (HSC)—contracting agent

• Indefinite delivery/indefinite quantity contracts and delivery orders —centrally selected/issues

• Restoration contracts aligned with clean-up process (studies, designs, clean-up)

• Contracts for pollution prevention, community relations, technology demonstration

• Contract administration delegated to Defense Contract Management Command (DCMC)

• On-site contract administration performed by installation

• Technical oversight by AFCEE

• Cost control by AFCEE and HSC

• Contracting guidance document: U.S. Air Force Environmental Restoration Contracting Strategies Analysis (January 1992), available from: HQUSAF/CEV, 1260 Air Force Pentagon, Washington, DC 20330-1260

• Representatives from EPA, AF, NAVY, COE, NASA, DOE, DOT

• Discuss environmental contracting issues

• Networking and information sharing

• Lessons learned

• What works/what doesn't

• Identify indicators of fraud, waste, or abuse

• Contract administration approaches

• Kickoff meeting, June 1992; second meeting, October 1992; next meeting, October 1993

• Acquisition initiatives

  • Develop federal directory of environmental contractors

  • Conduct joint contractor operation reviews

  • Encourage the Defense Contract Management Command and Defense Contract Audit Agency to give greater support to civilian agencies

  • Develop a common method of cost reporting

  • Encourage a separate Standard Industrial Classification code for environmental work

  • Develop a separate Federal Acquisition Regulation part for environmental work

  • Develop an environmental electronic bulletin board

  • Develop environmental contracting workload model or guidelines

  • Establish federal environmental contractor conflict of interest guidance and interagency controls.