Making Use of TAPP

[Lenny Siegel <lsiegel@cpeo.org>]

Making Use of TAPP

For many RABs at military bases that are not on the "Superfund" National
Priorities List, the TAPP program should make available resources
essential to the effective, constructive, independent oversight of the
Department of Defense cleanup program. The history of U.S. EPA Technical
Assistance Grants (TAGs), at federal and non-federal facilities as well,
is that community-hired technical consultants not only empower and
inform public stakeholders, but they make possible a smoother
decision-making process.

The conditions for TAPP help written into the 1996 Defense Authorization
Act look difficult to meet, but the two-part second condition* is
remarkably consistent with the goals of most community RAB members.
Contributing to the effectiveness of activities, for example, may mean
that the TAPP assistance facilitates more complete cleanup. In fact,
condition 2(a) is not all that different than the call for faster,
cheaper, safer, more complete cleanup. Contributing to community
acceptance doesn't just mean winning support for pre-established cleanup
goals and remedies. It also means coming up with cleanup strategies that
are more likely to earn public support.

The TAPP program, like EPA's TAG program, is not designed to provide
another level of regulatory oversight. It would be futile, even with ten
times the money, for the TAPP consultant to check and comment on every
aspect of the multitude of documents associated with a typical hazardous
waste cleanup. Rather, the purpose of independent technical assistance
is to help members of the affected community identify and influence key
cleanup decisions.

The first task, therefore, of a RAB considering a TAPP application is to
look at the cleanup calendar for the next year. What decisions about
characterization, removal or other source controls, and remedial action
are likely to be made? Will the RAB be asked to comment on risk
assessments or the prioritization of sites and activities at the
facility?

With that calendar in mind, it's usually necessary to figure out which
of those impending decisions are significant, complex, or controversial.
Those are the decisions around which to build a TAPP project. Figure out
what questions you want answered, and specify criteria for a service
provider that can help answer those particular questions.

In my experience, the best TAG-type consultants are those who not only
understand the technical aspects of cleanup, but who understand the
cleanup process as well: What does the community really need to know,
and when, if it's going to make a difference? For that reason, I think
it's important to emphasize, as a criterion for hiring a provider, the
consultant's experience in working with community groups. (To make it
easier to find such consultants, CAREER/PRO is compiling a reference
list of environmental consultants who primarily work with
community-based groups.)

Working with an independent consultant is usually helpful, but it's also
normally a lot of work. You have to meet regularly with the consultant
throughout the process. In fact, it may be necessary to structure a RAB
committee both to direct and hear from the consultant.

Remember, the consultant does not take the place of community activists.
He or she focuses on issues and problems identified by activists and
helps them develop recommendations. The consultant may also function as
an interpreter or go-between, particularly at locations where
differences in education and culture - as well as the jargon and use of
acronyms by government agencies and their contractors - make
communications between the public and government agencies difficult.

The publication of the TAPP rule is a giant step forward, but it doesn't
mean your installation is ready to implement the program locally. Base
officials probably don't yet have instructions, and the program, at
least in the short run, requires extra work of them while draining a
small amount of money.

Furthermore, particularly at facilities with low-trust programs, where
independent consulting is needed most, officials may be reluctant to
launch TAPP. (If the community already has a TAG grant or other
technical support, then the installation may decide that TAPP support is
not necessary.)

I suggest, therefore, that RAB members who think they might need
technical assistance develop and file applications soon, to get the ball
rolling as soon as possible. Those project managers and environmental
coordinators who don't know what to do will have to ask their
organizations for guidance and/or support.

In developing projects, think not only of what you want to get out of
TAPP. Try to come up with ways to show the military and the regulators
how an independently informed RAB will help the process, even from their
point of view.

And remember, there are people on Capitol Hill and in the Pentagon who
still don't want this program to succeed. They will be looking for
examples of waste and abuse. Follow the rules carefully. Avoid conflicts
of interest. And make sure, if your TAPP project proceeds well, that
your elected officials know that the program is working as designed.

*"TRCs and RABs may request this assistance only if:
(2) The technical assistance--
 (a) Is likely to contribute to the efficiency, effectiveness, or
timeliness of environmental restoration activities at the installation;
and
 (b) Is likely to contribute to community acceptance of environmental
restoration activities at the installation."

Lenny Siegel
Director, SFSU CAREER/PRO (and Pacific Studies Center)
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org