|From:||Lenny Siegel <firstname.lastname@example.org>|
|Date:||Thu, 27 Jul 1995 09:14:35 -0700 (PDT)|
|Subject:||CAREER/PRO COMMENTS ON TAP RULE|
I submitted the following comments to the Defense Environmental Security Office on CAREER/PRO letterhead. Just so misunderstandings don't develop later, I want to make sure that everyone recognizes that we (CAREER/PRO) intend to submit a letter of intent to bid on option B. Our current hope is to build a national consortium with similar institutions in other regions. Lenny July 6, 1995 Office of the Under Secretary of Defense for Environmental Security/Cleanup 3400 Defense The Pentagon Washington, DC 20301-3400 Dear Mmes.: As someone who has worked for several years to increase and improve the role of community stakeholders in the oversight of military installation restoration, I would like to compliment the Defense Department on the proposed rule on "Technical Assistance for Public Participation" (40 CFR Part 52, as published in the Federal Register, May 24, 1995). I continue to hear, from the neighbors and employees of military installations all over the country, the need for the types of services described in the rule. Though I have sought and received feedback from a large number of members of Restoration Advisory Boards, as well as others, my comments only represent my personal opinions and CAREER/PRO, the San Francisco State University project that I direct. Before addressing the specific proposals, I want to highlight three themes: 1) The provider(s) of technical assistance must be independent, and be perceived of as independent, not only from the Department of Defense, but from state and Federal regulatory agencies. 2) Since needs vary significantly from facility to facility, the program must be flexible - offering a range of services. 3) To serve public stakeholders and win the respect of government agencies, service providers must be technically and administratively competent. I favor a combination of the options for providing assistance that are described in the proposed rule. To the extent that its is possible to allocate resources in advance, up to two thirds of the funds available to support this program should support Option C. With the exception of locations where EPA Technical Assistance Grants are already in place, the remainder of the money should support Option B. Foremost, community RAB members seek the assistance of technical consultants that they can selected and direct. OPTION C appears best designed to meet this need, but it has two shortcomings. First, the $25,000 purchase order may not be large enough to acquire the services of a competent technical assistance team - that is, a group of cooperating specialists. I assume the $25,000 limit has been proposed to limit administrative work, but it might also hamper the assistance as well. Second, most RABs lack the capacity to institute such a program. That is, they don't have the organization, experience, or time to properly advertise for and evaluate technical consultants, particularly because they must comply with complex, unfamiliar Federal procurement regulations. These are precisely the types of obstacles that make it difficult for many otherwise qualifying groups to obtain EPA TAGs. While the RABs' agency sponsors could provide such assistance, many RABs would feel that it would undermine their independence, and given the installations' reliance on engineering service contractors, it would probably not be cost-effective. Consequently, I believe that OPTION C would work best in conjunction with OPTION B. The Technical Assistance Provider(s) would lead each RAB through the administrative thicket of seeking, hiring, and overseeing the local Technical Consultant. This would not only strengthen program accountability and uniformity of procedures, it would free the RAB members and the host installation to focus on substantive issues of cleanup. The proposed qualifications for the OPTION B technical assistance provider are good, but they could be improved. 1) I would add the term "independent" to "neutral and credible." Community representatives need someone to turn to when they aren't sure if they should believe the military or regulators. 2) I would de-emphasize the role of facilitation and mediation. These services appear to be available locally. 3) Ideally, the services would be provided by a national consortium of regional institutions. There is a need for national coverage and networking, but regional institutions are better placed to understand local needs. It also saves on travel money when key personnel and/or RAB members travel shorter distances for training. 4) Some of the organizations that have been offering this type of service are publicly owned universities, such as San Francisco State University. Please clarify that "not-for-profit" includes state academic institutions. OPTION B can complement OPTION A by providing a number of national or regional services, such as: 1) On-call technical assistance for RABs a) in the early stages of development; b) needing quick answers, or c) preferring not to hire a consultant. 2) Administrative support for RABs that wish to hire technical consultants directly. 3) Training workshops for RAB members. 4) Services, such an Internet link and a national clearinghouse of RAB documents - such as sample mission statements or by-laws - to promote the sharing of experiences and ideas among the various RABs. 5) For RABs that are just forming, organizational assistance. Please note that the legislation says that funds may be made available to "assist such members and affected citizens to participate more effectively..." Many new RABs waste valuable time and energy re- inventing procedures. While it would be inappropriate for the agencies to establish detailed procedural rules on a national scale, a technical assistance provider could help new RABs draw upon the successes of existing ones. In providing these services, the technical assistance providers could increase public confidence in the process and relieve base environmental officials and contractors of what are, in some cases, unwanted tasks. Translation of technical documents into foreign languages, as well as into non-technical English, could be done either by OPTION B technical providers or OPTION C purchase order recipients. Finally, although OPTION A is least desirable, I don't think existing EPA TAG recipients should lose their support. Unless there is cause, OPTION A should be used to provide continuation funding for existing TAG recipients. Given the administrative difficulties that both EPA and TAG recipients have with the program, I don't believe OPTION A would provide new grantees faster service than the other options. I don't know of any TOSC centers that have established working relationships with RABs or other community oversight boards at defense facilities. sincerely, Lenny Siegel Director
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