Final action was deferred until after a meeting is held on October 17 with Department of Justice on resolving the completeness issues. Environmental Liabilities Committee members reviewed draft guidance on environmental liabilities. It was suggested that some of the changes conflicted with the work of the subgroup and warranted careful consideration. Mr. Dacey, after further discussion with Mr. Armstrong, will suggest necessary changes and resubmit the guidance to AAPC for final approval. Intra-Agency Confirmations Mr. Dacey reported that OPM will provide a letter certifying actuarial statements.
Timing is the main issue.
Members discussed whether the confirmation issue should remain on AAPC agenda and agreed to remove it from the agenda. Mr. Dacey will continue to be involved in these matters and will raise issues to AAPC on an as needed basis. Mr. David stated that at the last AAPC meeting there was a question of whether this issue should be addressed by the AAPC, since some members believed that there is sufficient guidance in the literature. Mr. David distributed a summary of the subcommittee's conclusions. The subcommittee recommended a one or more day forum to discuss the issue, followed by a best practices publication.