Principles for Reinforcing Federal Facility Agreement Informal and Formal Dispute Timelines
The pace of cleanup at federal facility Superfund sites can be delayed when Federal Facility Agreement (FFA) parties continue disputes beyond the agreed-upon dispute resolution timelines specified in negotiated FFAs. However, because disagreements and disputes are fact-specific, a fluid rather than a one-size-fits-all process may at times be necessary. This September 2018, memorandum sets out principles clarifying and reinforcing the importance of adhering to agreed-upon FFA informal and formal dispute timelines. These principles support Recommendation 18 of the Administrator's Superfund Task Force Recommendations report, released on July 25, 2017.