|From:||Lenny Siegel <firstname.lastname@example.org>|
|Date:||Fri, 02 Dec 1994 00:14:27 -0800 (PST)|
|Subject:||Documents vs. Action|
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.
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