RAB RULE COMMENTS

[Lenny Siegel <lsiegel@igc.org>]

From: Lenny Siegel <lsiegel@igc.org>

Today I am submitting the follow comments on the Proposed RAB Rule. 
Comments are due by November 4, 1996
Lenny Siegel
 
 
October 14, 1996
Marcia Read
Office of the Assistant Deputy Undersecretary of Defense (Environmental 
Cleanup)
3400 Defense, The Pentagon
Washington, DC 20301-3400
Dear Ms. Read:
These are my formal comments on the Proposed Rule on Restoration 
Advisory Boards (32 CFR Part 202), as published in the August 6, 1996 
Federal Register. 
First and foremost, I support the proposed rule. I find that it is 
consistent with the joint EPA-DOD "Restoration Advisory Board 
Implementation Guidelines" and the two reports of the Federal 
Facilities Environmental Restoration Dialogue Committee.
I do however, have three suggestions:
1. Nothing in the rule should be construed to forbid the 
broadening of a Restoration Advisory Board's scope to the oversight of 
other site-specific environmental activities, such as pollution 
prevention or natural resource management. At Vandenberg Air Force 
Base, the Air Force, regulators, and community members of the RAB 
agreed that it would be mutually beneficial to use the RAB as a major 
source of community input on the pilot implementation of the ENVVEST 
program. Such a widening of scope makes sense where there is a clear 
community interest in base environmental compliance or management, not 
only to build upon the experiences of the RAB, but to limit the 
proliferation of facility advisory committees.
2. The rule contains no guidance for dealing with situations where 
relations between installation military officials and at least some 
members of the community have broken down, as at Fort Ord. I suggest 
the establishment of a clearly defined appeals process or, at the very 
least, a national point of contact, so dissatisfied members of the 
community can raise issues before communications break down entirely.
3. Though RAB members do not generally require travel assistance, 
there may be some rare instances - such as remote Alaskan sites - where 
such assistance is the best way to ensure participation by 
representatives of the affected population. Therefore, I believe travel 
should be listed as an acceptable administrative expense in rare 
instances, subject to approval of the appropriate military command.
Sincerely,
Lenny Siegel
Director (SFSU CAREER/PRO)