Re: [CPEO-MEF] RAB questions

["A. Richard Miller" <TheMillers@millermicro.com>]

I think Ted Henry states it well.  A RAB functions to provide important
community inputs concerning that base's environmental impacts.  Jim Oyer
undoubtedly has been told about the limits of that, and even may be held
to those limits by an uncooperative base administration, but that's not
the way it has to work.

A case study?  I just happen to have one in mind.  At the outset of the
SSCOM RAB (Soldier Systems Command, a.k.a. U.S. Army Natick Labs, and
several other names over the years) on which I serve, NLabs helpfully
provided community members with four pages of draft contract wording
which would have limited us (a) to specific issues (b) on the base
property.  We rejected both limitations, pointing out that other
contamination issues might arise, and that we were meeting because it
already was affecting our town drinking wells - OFF the base property. 
We proposed an alternate one-paragraph contract to describe our purpose
in more appropriate terms.  That produced months where we met without
any contract, while SSCOM told us we must have a contract and that it
"was not allowed to accept that broad one."

Instead of giving in, we asked the US EPA for its opinion.  After the
RAB's Massachusetts Dept. of Environmental Protection and US EPA
members reported back that THEY found our paragraph quite acceptable,
NLabs regrouped; it finally said that we were so darned good that NO
contract would be required.  And so it has been, for these many years. 
I think all parties would agree that our RAB has worked quite well, and
to the further benefit of the community.

I suspect that ALL the RABs were sold this spurious bill of goods, and
most of them signed on for unreasonable constraints.  That doesn't make
it right.  IF you signed on to a bad deal, ask how to renegotiate for
adequate community representation.  Of, if necessary, don another hat to
do what's right.

A final, related thought: Start thinking about how to convert your RAB
to an equally-effective CAB (Community Advisory Board) for that base,
once the initial RAB goals are met.

Cheers from
--Dick Miller <TheMillers@millermicro.com>
  Citizen Member, SSCOM RAB (U.S. Army Natick Laboratories)


ted@theodorejhenry.com wrote (Wed, 30 Oct 2002 11:33:14 -0500):
> 
> Jim
> 
> I do not think DOD made RABs just to make them fail, although I
> certainly think they could have supported them better. DOD has always
> said that such guidance was not made too detailed so site personnel
> would have the flexibility needed to fit their situations.
> 
> Unfortunately, some sites do not want it to work or simply have had no
> training in the same room with community members to learn how to make it
> work.
> 
> At sites where this closed approach is taking place, and I am associated
> with one right now, the military entity is shooting itself in the foot
> and in the end, making their projects harder, more costly, and more
> prone to serious political scrutiny.
> 
> So, I believe RABs can work, but the tools available to community
> members and military personnel alike to make them work are very, very
> limited. Throw in a great number of defense contractors who do not truly
> understand community participation and sites can certainly head down the
> wrong path. I guess my point is - this is not the only path available,
> just like only discussing defined SWMUs is not only path available.
> 
> Peace
> 
> Ted
> 
> 
> -----Original Message-----
> From: UTOSI-Hdqrs@kc.rr.com [mailto:UTOSI-Hdqrs@kc.rr.com]
> Sent: Wednesday, October 30, 2002 11:07 AM
> To: cpeo-military
> Subject: Re: [CPEO-MEF] RAB questions
> 
> At 07:08 AM 10/30/02 -0600, info@cswab.com wrote:
> 
> >I've been told that Restoration Advisory Boards can only "legally"
> >discuss sites listed on the base's Installation Action Plan.
> >
> >Are RABs in other communities commenting on things like cleanup of
> >contaminated buildings, pipelines, spills not covered under RCRA or
> >CERCLA, PCB cleanups, asbestos removal, etc. (ie, cleanup projects that
> >are not necessarily listed as an IRP cleanup)?
> >
> >Does anyone know if there is specific language that either prohibits or
> >provides for the discussion of specific cleanup topics by a RAB?
> >
> >Please post your reply.
> >Thank you!
> >Laura
> 
> Laura this is very true.  Only items listed in the IAP known as SWMU's,
> Solid Waste Managements Units.
> 
> And in fact the RAB cannot vote as a group on IAP work that is being
> done,
> only vote and send letters as individuals.
> 
> The RAB members do not have any say in the cleanup of contaminated
> buildings, pipelines, sewer lines, spills not covered under RCRA or
> CERCLA,
> PCB cleanups, asbestos removal, etc.
> 
> What a "SHAM".  This is called covering your XXXXXXXXXXXX.
> 
> Jim Oyler, RAB Member
> Sunflower Army Ammunition Plant.
> De Soto, KS


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