RE: [CPEO-MEF] RE: [CPEO-MEF] Administrative Record example sought

[walshw@pepperlaw.com]

You are generally correct, there is no formal need to prepare a formal
administrative record until the decision is about to be made.  Some more
farsighted remedial program managers put documents in an informal
administrative record as they go along.  Of course, any data, reports or
other public information (particularly if it is submitted on the record)
should end up in the site-specific public file.  You can send a Freedom of
Information request (or as a RAB member perhaps just ask for it) to obtain
such documents.

What may not be in this public file is internal memoranda, memoranda from or
to the government consultant/contractor studying the site, and any internal
notes.  Pure fact should be available pursuant to FOIA.  Deliberative and
draft documents typically are not. 



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