TAPP Ruling

[megry@juno.com (Lisa A. Chelf)]

Below please find my response to the TAPP Rule. As stated in the
following letter, I am a member of the RAB at NAS Cecil Field
Jacksonville, Florida. Our RAB participation in the Fast Track Cleanup
Program was a contributing factor in NAS Cecil Field being presented the
"Secretary of Defense Environmental Cleanup Award for Installation
Restoration".

Office of the Deputy Under Secretary for 
Environmental Security / Cleanup
3400 Defense Pentagon
Washington, DC 20301-3400

Subject: Federal Register Publication of Technical
 Assistance for Public Participation Proposed Rule 
 and Department of Defense Request for Comments

Dear Ms. Rivers:

In my perusal of the above named document I became aware of issues which
need to be addressed prior to final ruling. I am a stakeholder and a
member of the RAB for NAS Cecil Field. As you may be aware the RAB I am
involved in has received awards for the outstanding work which has been
achieved thus far. The RAB for NAS Cecil Field has worked long and 
hard to build a trusting relationship with the government agencies 
responsible for overseeing environmental restoration. All 3 "Options" 
would destroy the trusting relationships we now have. Currently 
funding is provided to the RAB of NAS Cecil Field through Southern 
Division. The BRAC Cleanup team has been providing technical training 
for us which we RAB members are perfectly happy with. We have, to 
date, never asked for any funding from the EPA.

The request for comments in the Federal Register on May 24, 1995 (60 FR
27460-27463) was responded to by only 43 people which is hardly a good
cross section of stakeholders considering there are over 200 RABs across
the country. More responses are needed especially from the RABs which have
been very successful such as ours. Possibly the stakeholders were not
aware of the impact of the proposed rules.

The concept of "Just in Time Training" providebackground material
documentation and other support materials to community members as topics
are discussed. Notably these documents would mean little without
additional training. The work of any advisory board technical 
consultant should occur concurrently with the on-going efforts of 
regulated and regulating agencies so as not to slow down or impede the 
process. All "Options" would slow thprocess considerably.

The NAS Cecil Field RAB participated in a consensus building workshop
March 21, 1995 which has proven invaluable in working as a team to
function as effectively as possible not to purely exchange information. 

In the Final Report of he Dialogue Committee, Chapter 4 Box 11 Citizen
groups can apply for Technical Assistance Grants (TAG) through the EPA. 
In addition, the National Defense authorization Act for Fiscal Year 1995 
provided new authority for DOD to provide up to 7.5 million in technical
assistance funding to members of RABs. Am I to understand that ruling 
is no longer in effect?

The Dialogue Committee states the need to create advisory committees that
are balanced and subject to an open process to the end of ensuring that
the needs of the community are consistently a primary consideration in
the decision making process. Furthermore the Committee wished to avoid
unnecessary burden that may hamper the creation of such boards. Finally,
chartering agencies should also seek to reduce the bureaucratic burden of
the law on board members to the greatest extent. None of the "Options"
are consistent with these three elements.

The Dialogue Committee provided for the continuing education program
tailored to the needs of both citizen and agency participants can
considerably aid in the formation and growth of advisory boards. The
preparation and continuing education of all advisory board members (not
just community members) is vital to the quality and substance of their
advisory role. The committee supports providing advisory boards with
technical assistance funding. In many cases, advisory boards offer
regulated and regulating agencies a good opportunity for focused and
meaningful input into the negotiations because of their background
knowledge of issues at the facility, and their ability to respond quickly
to concerns and questions. None of the "Options" provide this. A great
injustice will be done to the entire RAB if only community members
receive required technical training. Our agency participants are just as
important in all decision making as our community members. This is a
very important part of consensus building.

The work of any advisory board technical consultant should occur
concurrently with the on-going efforts of the regulated and regulating
agencies so as not to slow down or impede the process. All "Options"
would slow the process considerably.

The Fast Track Cleanup process will be considerably slowed down with all
"Options".Steering Committee meetings are needed more now than ever.

I agree it is necessary to limit funding however, funding should be
concurrent with each facilities circumstances. (i.e.: proposed closure
date, reuse interest by civilian corporations). It would be impossible
to make a determination based on the total number of RABs expected to
make requests versus the available resources.

Serious questions arise with proposed Option C such as:

What is involved in demonstrating that the technical expertise necessary
for the proposed TAPP project is not available through the Federal,
State, or local agencies responsible for overseeing environmental
restoration?

How long will the review process of purchase orders take?

What is the turn around time from a purchase order being issued and
receiving the requested technical support?

In conclusion regulations should be based on a proven track record. 
Visit our RAB. We will be pleased to show anyone how we have been
successful. Administrative requirements are much more cumbersome in all
"Options" than in what we at NAS Cecil Field have in place now. 
Bureaucratic red tape as in all "Options" will only serve to impede our
process. Meaningful assistance will be impeded more by all "Options". 
Increased trust will not be fostered with any of the "Options". I see
no increased flexibility and responsiveness to community needs with any
of the "Options". Having Southern Division provide funding and the BRAC
team provide technical training is on going and functioning quite well at
NAS Cecil Field. If it isn't broken, please don't try to fix i
Problems and confusion and lack of trust in the government will be the
outcome if the rules for RABs change from year to year. 

Sincerely,

Lisa A. Chelf