Participatory factors regarding RAB relevancy and etc.

[zweifel@nexus.chapman.edu]

Posting from Don Zweifel <zweifel@nexus.chapman.edu>
Subject: Participatory factors regarding RAB relevancy and etc.

To Jeff Green et al (and whomever has an interest in the foregoing):

In reponse to your question as to how much citizen inquiry is welcome 
may we refer you and any others that might be interested to a document 
entitled, "USEPA and DoD RAB Implementation Guidelines," Sept. 1994.

According to Presidential Executive Order 12580 and 10 USC 2705(c), "RABs 
provide an expanded opportunity for ongoing community input and participation 
in all phases of IR (Installation Restoration) activities and decision-making."

"The DoD will consider all advise provided by the RAB whether 
consensus in nature or provided on an individual basis, including advice 
given that represents the minority view of members. Consensus is not a 
prerequisite for RAB recommendations. Each individual should provide 
advice as an individual, not as a group."

"To demonstrate committment to meaningful consideration of comments, the 
DoD installation should prepare formal written responses to all 
substantive comments rcvd from the RAB and the general public. In some 
cases RAB meeting minutes may suffice to document responses to specific 
comments." 

In regards to your query as whether, "Community members will have a role 
in defining risk, impact and clean-up..." May we make the supposition 
that it actually is primarily the regulator's bailiwick or area of 
concern. The EPA determines whether there is an imminent risk to human 
health or potentially so, by setting MCLs or Maximum Contaminant Levels in 
water, for example. 

However, our RAB input is important to the regulators and DoD because 
it is mandated by the above mentioned statutory law provisions.
We believe that no significant inquiry from a RAB may be dismissed as 
irrelevant without a thorough investigation by DoD and/or EPA.

 Don Zweifel