TAPP RULE COMMENTS

[Aimee Houghton <aimeeh@igc.org>]

I submitted this to ODUSD(ES) today.
LS

TO: Office of the Deputy 
Undersecretary of Defense for Environmental Security/Cleanup
FROM: Lenny Siegel, SFSU CAREER/PRO
SUBJECT: Proposed Rule on Technical Assistance for Public Participation
DATE: February 20, 1997

 I am pleased to have the opportunity to comment on the Proposed 
TAPP Rule. Once implemented, this rule will significantly enhance the 
oversight of Department of Defense cleanup and ensure effective 
participation by community stakeholders. In general, I think the 
proposed rule does a good job of meeting the goals of the Congressional 
authorization. My greatest concern is that public stakeholders have 
access to independent technical advice as soon as possible.

 I do have a few minor suggestions however:

1) It should be clear that academic institutions and other non-profit 
organizations that are not small businesses qualify as assistance providers.

2) The list of qualifications for providers should be flexible to 
encourage the formation of teams that include both technical experts 
and experienced communicators.

3) Purchase orders smaller than $25,000 - such as $5,000 - should be 
available to support workshops and other training activity. The 
qualifications for trainers should be broad enough to include 
non-technical "process experts."

4) Some vehicle is necessary to help community RAB members define their 
technical assistance requirements, evaluate potential assistance 
providers, and supervise selected providers. In my experience, many 
communities lack the knowhow to get started. This vehicle could be the 
support - through other means - of intermediary organizations who could 
facilitate the acquisition of independent technical services. Or if 
could be the availability of mini-grants - again in the $5,000 range - 
for the direct acquisition of intermediary services.

5) Similarly, I believe it is important for DOD to encourage and even 
support the creation of a directory of potential service providers. 
This directory would include references from past clients, so community 
participants would have some help as they evaluate potential providers.

6) Finally, technical assistance funding should not encourage a "use it 
or lose it" approach. Provider hours not used in the year of contract 
award should clearly be available in the following year. I believe that 
most community participants are likely, under such conditions, to 
carefully conserve the resources made available to them under this program.

I may be contacted at SFSU CAREER/PRO, 425 Market Street, San 
Francisco, CA 94105. The phone number at that office is 415/904-7750. 
Fax is 415/904-7765.

Thank you.