Documents vs. Action

[Lenny Siegel <lsiegel@igc.org>]

LESS DOCUMENTS, MORE ACTION
by Lenny Siegel
December 1, 1994

 Across the country, there is a growing perception that
hazardous waste cleanup programs, such as EPA's Superfund
program or the Federal facilities cleanups carried out under the same
authorities, are bogged down in study. Congress, in fact, has asked
the Defense Department to move more resources into actual remedial
action, as opposed to continued study.

 The problem, however, is not with studies, per se. Sometimes
they are necessary to ensure that remedial action reduces, rather than
spreads, risk, or that premature action does not increase long-term
project costs. Yet from the volumes of documentation generated for
each cleanup, it often seems that consultants or contractors are paid by
the word, not for their contribution to the reduction of human or
environmental risk,

 Unfortunately, the entire process of environmental restoration
is organized around deliverable documents, not real world objectives.
The typical milestones in a Federal Facilities Agreement, for example,
refer to the completion of a remedial investigation or a remedial
design, not the characterization of a plume or the removal of a risk.

 Since it will never be entirely possible or desirable to eliminate
all the legal and regulatory sledgehammers that drive the cleanup
business, it is unrealistic to drop fully the reliance on documentary
deadlines. Still, as Federal agencies divide their Agreements into
permanent, legalistic governing language and flexible site management
plans, there is an opportunity to make project milestones more
concrete and specific.

 I propose, to the extent legal and practical, that project
milestones define activities - such as characterizing contamination at a
specific site or removing tanks - or objectives, achieving the desired
reduction in groundwater contamination. To some degree these
milestones correspond to existing deliverable documents, but those
documents could be simplified - as some agencies are already doing -
by placing support data in active, accessible, computerized files.

 I believe current law allows a great deal of flexibility in the
definition of milestones, so at any site where milestones are already
being adjusted it would not be too difficult to redefine them. I see four
principal advantages:

1) To communities, the press, and other non-specialists, real-world
milestones would make cleanup much more easy to understand. I have
seen many eyes glaze over at the sight of charts summarizing the
completion of documentary cycles.

2) Real-world milestones - including activities and objectives - would
provide better measures of project success. Delivery of a study proves
nothing; but if that study thoroughly maps the spread of a contaminant
of concern, then something has been accomplished. Contractors and
officials could be evaluated not by the amount of paper they push, but
by their contribution to the reduction of risk.

3) The production and review of documents is often a waste of time
and resources. At minor sites or routine sites, contractors generate
documents and regulators go through them with a fine-tooth comb
because it's standard procedure. The Air Force Combat Command's
Project on Streamlined Oversight, coordinated by Versar, Inc., is
looking into ways to reduce unnecessary document flows. Obviously, 
a planning system that calls for documents when necessary, not just
by routine, would be more efficient - assuming, as the Versar project
suggests, that the responsible party, the regulators, and the
community have established a trusting relationship.

4) At facilities where cleanup is expected to contribute to economic
recovery or job training and employment, it's essential to have a
public roadmap on the anticipated cleanup schedule. Building activities
into a site management plan is a good way to give institutions that are
supporting economic development or providing training advanced
notice of work that is expected. Everyone must recognize that such a
plan is predictive - it is not an invitation for bids - but it is the type of
information that must be disseminated early if economic objectives are
to be met.

 The national commitment to cleaning up hazardous waste
contamination is losing its steam, partly because it is so costly, partly
because it is perceived to be inefficient. In many - perhaps most -
cases, however, programs are moving forward in the identification,
investigation, and remediation of toxic environmental releases, but
they have failed in their ability to characterize their own achievements.
Adopting real-world cleanup milestones would improve the picture of
cleanup success while, more importantly, the improved process would
make it easier to focus limited resources on real-world results.