Nat'l Advisory Board On Environmental Restoration (NABER)

[Aimee Houghton <aimeeh@cpeo.org>]

We are seeking input on the following proposal. Please send
suggestions or comments to this newsgroup directly at:

<cpeo@cpeo.org>

Aimee Houghton and Lenny Siegel
CAREER/PRO
*******************************

CAREER/PRO suggests that the both DERTF and the National RAB
Caucus discuss the possible formation of a National Advisory
Board on Environmental Restoration (NABER). The Board would
advise both U.S. EPA and the Department of Defense on policy
issues regarding military base cleanup.

Currently, both DOD and EPA develop national policies and
proposals on cleanup with no direct consultation with public
stakeholders, despite the existence of a visible, organized
community of RAB members throughout the country. The Federal
Register and comment periods do not substitute for the type of
dialogue that the Federal Facilities Environmental Restoration
Dialogue Committee (FFERDC) and other groups have established.

Among the recent issues that could have been discussed at NABER:

* Procedures for implementing the Early Transfer law.

* EPA's new regs on NPL deferral

* The presumptive remedy for landfills on large properties with
multiple landfills

* Lead paint removal and remediation

* Sunsetting RABs

While community members of NABER could bring up local problems,
resolving them locally would not be the job of the Board.

NABER meetings should include ex officio representation from the
Environmental Security Office, the Armed Services, and DLA, as
well as U.S. EPA. Other federal agencies, such as Interior,
should be invited when issues pertain to them. There should be
state and tribal representation as well.

Most important, community members should serve as
representatives of the RABs. We propose a system of election in
which RABs nationally are lumped into groups of 25 to 30 RABs.
This can be done by geography, active vs. closing bases, or
military component. By mail ballot, RAB co-chairs or designated
committees from each RAB would vote for two representatives from
nominees within their grouping. In addition, EPA's Environmental
Justice office could make additional appointments if the
election process does not ensure adequate representation of
people of color.

Lenny Siegel
Aimee Houghton
CAREER/PRO
425 Market Street, 2nd Floor
San Francisco, CA 94105
tel: 415-904-7750; fax: 415-904-7765
email: <aimeeh@cpeo.org> or <lsiegel@cpeo.org>