reformated comments on NABER

[Aimee Houghton <aimeeh@cpeo.org>]

[THE FOLLOWING IS A REFORMATTED VERSION OF THIS MESSAGE FROM 1/24/98.
HOPEFULLY IT WILL BE EASIER TO READ.]

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 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 grassroots organizations who have experience and go through a
bidding process. The results and outcomes would be shared with
regional and national federal agencies, state and local governments, and
RABs/SSABs throughout 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 allowing only individual advice
rather than advice from the RAB body;
c. the limited and ineffective participation of community members in
money matters (budget, who gets hired, control of expenses, final
authority, etc.);
d. the lack of full/open/forthright disclosure of the facts by the
agencies;
e. on-again / off-again public outreach and involvement;
f. the lack of independent technical advice to community members (at
community members' discretion) ;
g. the continuing fight at many RABs over the lack of consistent,
truthful and complete meeting minutes;
h. 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 (limited duration) national
RAB/SSAB Improvement 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 involvement 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