Re: [CPEO-MEF] RAB Crisis - HELP!

[isisGU@hampshire.edu]

[from Laura Olah <olah@speagle.com>

QUESTION: Do you have information on voting by the military and
regulatory RAB members including what is happening at other bases in
this regard? Something as simple as a list of several dozen RAB's where
the military and regulators do not vote would do the trick.]


Dear Laura,

The following is excerpted from 'Final Report of the Federal Facilities
Environmental Restoration Dialogue Committee Consensus Principles And
Recommendations For Improving Federal Facilities Cleanup [Federal
Register: April 16, 1996 (Volume 61, Number 74).' The full document can be
found online at: http://www.epa.gov/swerffrr/ferdcrpt/toc.htm

"[CHAPTER 4 - ADVISORY BOARDS
III. Existing Advisory Boards
Where advisory boards already exist, the Committee intends for its
recommendations to build upon existing groups and not to supplant them,
particularly where they have proven successful....

VII. Role of Regulated and Regulating Agencies
...The advisory board is intended to be a forum through which advice can
be given to both regulated and regulating agencies on cleanup and waste
management and technology development related to cleanup. The regulated
agency should serve as the host of the advisory board and should provide
administrative assistance, meeting facilities, and other logistical
support as necessary. The Interim Report recommended that senior
representatives of both regulated and regulating agencies should serve as
"ex-officio" participants of the advisory board. The term ex-officio was
used to imply that representatives of these agencies should attend
advisory board meetings and participate actively in advisory board
discussions by making their views known. However, because the advice from
the advisory boards will be directed at their agencies, the Interim Report
recommended that agency representatives should not take part
in final decisions about what recommendations are made.

Since the publication of the Interim Report, DOE and DoD have established
advisory boards that involve regulated and regulating agencies in
different ways. DOE's SSABs essentially follow the model outlined in the
Interim Report. DoD has directed RABs to include regulated and regulating
agency representatives as regular board members and for the installation
commander or his or her designee to serve as co-chair along with a
community representative. [For copies of DoD and DOE guidance documents on
this issue see the points of contact in Appendix D of the above referenced
document)].

Because both models seem to be working, the Committee remains silent in
this report regarding whether regulated and regulating agencies should
serve as ex-officio or full members. Nonetheless, experience from RABs,
SSABs, and advisory boards in the private sector proves that community
members may stop participating actively in boards because senior managers
do not come and actively participate in board meetings, or senior managers
ignore the advice of board members without providing an explanation.
Regardless of their title, the Committee strongly recommends that
regulated and regulating agencies' role be defined in three ways. First,
the most senior level person available with site-specific cleanup
responsibility from the regulated and regulating agency should participate
in board meetings. Second, the participants from the regulated and
regulating agencies should be responsive to the concerns and advice of the
advisory board or provide a reasonable explanation for not adhering to the
advice. Third, representatives from regulating and regulated agencies
should serve as information sources for the board, providing updates and
background as needed.

XI. Role of Local Government Officials
...In practice, local government involvement in federal facility decision
making varies from facility to facility. Local government officials should
have the opportunity to decide, taking into account local laws and
community preference, if and how they will participate in a federal
agency-sponsored advisory board. Local government options for
participation may include: 1) full member; 2) ex-officio participant; or
3) advisory board convener. In addition, the local government may decide
not to participate in the advisory board."]


Hopefully, you will find this to be helpful.  Good luck to you.


Best Regards,

Jeanne Stevens

Coordinator, Military Waste Cleanup Project
Institute for Science and Interdisciplinary Studies
Prescott D-1
893 West Street
Amherst, MA 01002
Phone (413)559-5582
Fax (413)559-5611
jstevens@hampshire.edu

http://isis.hampshire.edu







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