Re: Nat'l Advisory Board On Environmental Restoration (NABER)

[worldworks1@dnvrpop1.dnvr.uswest.net]

The NABER suggestion addresses the need for an effective
national RAB/SSAB voice. Clearly this is an urgent and important
need. Yet the suggestion poses the following concerns:

A. A concern that a good many voices on the advisory boards will
be left-out due to suggested limited representation and that the
demands of personal life will infringe on many RAB/SSAB members'
ability to participate at a national level, further diluting
representation. Also, that larger sites will tend to dominate
the membership.

B. In our region ( Region VIII) the EPA doesn't have much of a
record in the Environmental Justice arena. They have a
demonstrated preference for citizens whose main qualifications
are; a certain malleability towards the EPA point of view; and a
predilection for main stream thought. I for one would have no
confidence in their participation to "ensure adequate
representation." This was one of the reasons that several
members of the Rocky Mountain Arsenal RAB and SSAB (yes we have
both) requested the national EPA OSWER ombudsman be assigned to
investigate Region VIII EPA (a preliminary investigation is now
underway).

C. Additional institutional layers, specifically group
representatives and NABER, will further allow the DoD, EPA, DLA,
and other federal agencies to disregard and marginalize the
diverse voices on local RABs/SSABs. Many RABs/SSABs (certainly
at Rocky Mountain Arsenal) are pretty much disempowered now and
have very little or no voice at all. Instead of more meetings we
need better, more effective local meetings with the additional
ability for consistent and continuous communication between
community advisory boards and national policy makers. The intent
of the NABER suggestion seeks to address better participation on
a national level, which I applaud, yet the worry here is that
local RABs/SSABs may become more disenfranchised when their
views deviate from the national cookie cutter mentality that
prevails in federal agencies / or the views expressed in the
suggested NABER.

D. As with the establishment of any new group, considerable time
may be lost to months or years of discussions about who
constitutes NABER, how it operates, who gets to vote, FACA or
not, what it gets to consider, who sets the agenda, how
decisions are made, whether decisions are made, where the money
will come from, public relations, who controls the money, where
to meet, and on and on . . . In the meantime many RABs/SSABs
will continue to struggle while the federal agencies continue to
steam roll policy after policy. Additionally the interim
establishment interval may serve as a further excuse to postpone
RAB/SSAB involvement on national policy issues.

I'm not saying that these concerns should stand in the way of
pursuing a NABER concept, but because of these concerns it
should not be the only avenue pursued. Some possible alternative
or additional avenues may be:

1. There is an immediate need for better and effective two-way
communication between RABs/SSABs and national policy makers.
 To maybe more quickly address this need, the DoD and EPA could
establish a national RAB/SSAB service bureau to;
 a. establish better communication;
 b. encourage and coordinate more complete, consistent, inclusive
and forthright communication;
 c. orchestrate means for that communication which is mindful of
the very diverse and limited resources available to the volunteer
 citizens that make up these boards;
 d. follow-up with two-way outreach so that communication is
occurring;
 e. routinely evaluate for effectiveness then modify and amend as
needed.

2. Pursue immediate annual regional or State RAB/SSAB gatherings
that are mindful of COMMUNITY members needs and strive to
include ALL community members of RABs/SSABs. The aforementioned
service bureau could provide staff and logistical support for
these across the nation. Organization and convening of these
regional gatherings could be done by grass roots organizations
who have experience and go through a bidding process. The
results and out comes would be shared with regional and national
federal agencies, state and local governments, and RABs/SSABs
through out the world.

3. I believe the difficulties for community members in the
RAB/SSAB environment are directly related to the bedrock
regulations/guidelines that the DoD/EPA have used to establish
RABs. Particularly:

 a. the role of the services as co-chairs;
 b. the limitations on the RABs for allowibg only individual
 advice rather than giving advoce from the RAB as a body;
 c. the limited and ineffective participation of community members
 in money matters (budget, who gets hired, control of
 expenses, final authority, etc.); b. the lack of
 full/open/forthright disclosure of the facts by the agencies;
 d. on-again / off-again public outreach and involvement;
 e. the lack of independent technical advice to community members
 (at community members' discretion) ;
 f. the continuing fight at many RABs over the lack of consistent,
 truthful and complete meeting minutes;
 g. the often high-handed role of Public affairs organizations in
 the determination of meeting sites, agendas, meeting materials
 (handouts), published product if any, meeting notifications,
 etc.

In light of the above, consider forming a national RAB/SSAB
Improvement (limited duration) Task Force. Initially it should
be composed exclusively of RAB/SSAB community members (with
staff and organizing support from DoD/EPA) to conduct a RAB/SSAB
needs assessment. Once the assessment is complete, then Federal,
State, and local participants would join in a discussion with
the task force community members about improving the RAB
process. Recommendations would then be made along with
implementation schedules, and next steps planning.

Congratulations to Pacific Studies Center, ARC Ecology, and
CAREER/PRO for pushing, encouraging and organizing to make the
advisory boards and public involvment effective. Your efforts
are invaluable and important. I will not be at he meetings in
Phoenix next week but I appreciate this opportunity to share
these thoughts for your discussion and consideration.

Rick Warner
member of: WorldWorksI & The Rocky Mountain Arsenal SSAB
Broomfield Colorado
303-466-9868