Re: [CPEO-BIF] EPA's Inspector General reviews All Appropriate Inquiries reports

[Lenny Siegel <lsiegel@cpeo.org>]

From: Markus Niebanck <markus@amicusenv.com>



Why did the Inspector General's report focus only on the issue of 
certification? A supposed evaluation of AAI process that turns only on 
this seems ridiculous. I have many different consultants conducting AAI 
and on reflection I now realize that this is a part of the report that I 
pay less attention to. I look more carefully at the technical elements. 
Did they conduct interviews? Was the breadth of the historic record 
review sufficient? Was the field inspection thorough and properly 
documented? Is this a thorough and well-crafted report?

Note to self, make sure the service providers have used the proper 
certification language at the end of the report. But tell me - why did 
the Inspector not look at these other aspects of the reports?

I don't get in a lather over what they've "discovered" because, taken as 
written, they illuminate a practice that owes to a lack of discipline 
and protocol, not necessarily one that should signify an overall lack of 
AAI quality. In other words, I do not believe a mis-worded certification 
statement or a missing resume is a certain sign that the rest of the 
undertaking was poorly done.

Read the report. Draw your own conclusions.

Markus


----- Original Message -----
From: "Lenny Siegel" <lsiegel@cpeo.org>
To: "Brownfields Internet Forum" <brownfields@lists.cpeo.org>
Sent: Tuesday, February 15, 2011 2:41 PM
Subject: Re: [CPEO-BIF] EPA's Inspector General reviews All Appropriate
Inquiries reports


> This is an important subject. Most of the usual suspects have already 
> chimed in. I invite other members of this list to join the discussion. I 
> would particularly like to hear from government officials. Since many 
> agencies discourage statements that might be misinterpreted as official, I 
> am willing to anonymize submissions.
>
> Personally, I don't think the solution lies in paying environmental 
> professionals more or restricting who might conduct a Phase One. Those 
> might be attractive options in their own right.
>
> But I believe we have to recognize that environmental protection is 
> inherently a government function. It is not inherently protective of 
> public health and the environment to allow private consultants, no matter 
> how qualified and how well paid, to conduct environmental assessments that 
> are questioned only if someone goes to court down the road.
>
> The lesson of the Inspector General's report is that government officials, 
> directly accountable to the public, need to oversee site assessments. It 
> means that assessments should routinely be made available to the public, 
> and that environmental regulators should check all of them against a 
> checklist - as the Inspector General's office did. A percentage should be 
> fully audited. To me, this is the best way to ensure quality.
>
> Lenny
>
> --
>
>
> Lenny Siegel
> Executive Director, Center for Public Environmental Oversight
> a project of the Pacific Studies Center
> 278-A Hope St., Mountain View, CA 94041
> Voice: 650/961-8918 or 650/969-1545
> Fax: 650/961-8918
> <lsiegel@cpeo.org>
> http://www.cpeo.org
>
>
>
> _______________________________________________
> Brownfields mailing list
> Brownfields@lists.cpeo.org
> http://lists.cpeo.org/listinfo.cgi/brownfields-cpeo.org




--


Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org


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