It’s my understanding that you may be the only Advisor who has served community groups pursuant to both an EPA TAG (e.g., LLNL, MEW, Moffett) and to a PRP arrangement in a settlement provision (= the Casmalia site). Accordingly, given your unique position, I am interested in whether you might be willing to share your perspective as to the pro’s and con’s of these two different mechanisms (e.g., the different levels of paperwork facing the community group recipients).

First, and this may be obvious to many, technical assistance is most valuable at the beginning of the process: that is, during the investigation and feasibility study leading up to development of the proposed plan. This affords communities to be fully informed when they have a chance to make a significant difference in the remediation plan. Often this does not occur because a qualified non-profit is not available or does not come forward. EPA should consider granting technical assistance on a more limited basis (than the TAG) to community groups, or in lieu of that, organizing Community Advisory Groups (CAGs) and granting them some independent technical assistance. This may be similar to the TAPP program whereby the Dept. of Defense provided technical assistance to Restoration Advisory Boards.

Having said that, it is also essential to create meaningful opportunities for community involvement during and after remediation. My experience has been that this is vitally important, but requires less money than the remedial planning phase.

Second, no matter what size the group with the grant, it is their obligation to communicate the TA’s finding, analysis and comments to a broader community. In one case where I am the TA, the organization has a monthly newsletter and issues that I bring up are discussed there. In another case, the relatively small organization has put together a Community Advisory Board, which is briefed on issues that I think are important, and the CAB gives me feedback on what they believe is important to the community. In both of these cases, I am asked to present my findings at public meetings. In still another case, where the scope of the TAG was very focused, I gave public presentations in five communities around the state and established a dialogue with those who did not agree with my conclusions.

Because the community’s interests are often not focused at the beginning of the TAG, and the Technical Assistance Grant has limited funding relative to the amount of money that PRPs and the regulatory agencies have at there disposal, I have on many occasions written “Community Guides” that provide an overview of the site and the issues as I see them. These are then discussed with the community, and the community decides on what issues it would like to focus on.

Peter Strauss

But EPA can encourage such small groups to both represent and provide information to the larger community. Some of the tools already exist: EPA requires that interested parties work together to apply for technical assistance grants. It asks technical assistance recipients to report how they communicate with the public at large. And it seeks broad representation when it creates or helps establish community advisory groups.

But the key element in encouraging small activist groups to represent the interests of their entire communities is for activists to realize that they will not be effective unless they have broad local support. That support can be manifested through turnout at public meetings, petitions, newspaper editorials, resolutions by local governments, etc.

In my experience, neither regulatory agencies nor responsible parties listen to small activist groups simply because they have access to hired-gun experts. Such groups influence decisions when they offer sensible recommendations that help them demonstrate that they speak for the community as a whole, or at least a broad segment of those paying attention. Technical assistance can help small groups speak for their communities, but only when they listen to their communities.

As to a specific suggestion: the EPA website for any particualr site should have an easy to use index of documents on record and link to those documents. There is an enormous amount of information. The documents should be indexed by date issued/submitted. A list of documents without some sort of index, at least by date, is not as useful to the public.

I’d also like to see measures taken to support the local volunteers more, with the ability to spend grant money on things that could increase our visibility and make our meetings something to look forward to. Like FOOD! It is a known fact that good food & coffee brings adults to evening or Sat. morning meetings ~ allow us to use a small portion of the grant funds to offer FOOD or bring in other FUN speakers to promote the organization I volunteer for, and then we can get folks to make larger and more serious committments!