From: | Lenny Siegel <lsiegel@igc.org> |
Date: | Mon, 14 Oct 1996 14:27:48 -0700 (PDT) |
Reply: | cpeo-military |
Subject: | RAB RULE COMMENTS |
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) | |
Prev by Date: CNN LAUNCH STORY Next by Date: BEYOND PARTNERING | |
Prev by Thread: CNN LAUNCH STORY Next by Thread: BEYOND PARTNERING |