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If you read the report, OIG was supposed to evaluate the adequacy of the "continuing obligations" but this effort was not completed due to time constraints.
I suspect the documentation issues were raised because that was probably the only kind of issue OIG could effectively review. I dont think OIG could have evaluated the quality of the work itself. That being said, there was sloppy documentation in ALL 35 reports. My experience has been that such sloppiness is usually not limited to documentation but is probably inherent in the work product itself
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-----Original Message-----
From: Lenny Siegel [mailto:lsiegel@cpeo.org]
Sent: Wednesday, February 16, 2011 02:50 PM
To: 'Brownfields Internet Forum'
Subject: Re: [CPEO-BIF] EPA's Inspector General reviews All Appropriate Inquiries reports
From: Markus Niebanck Why did the Inspector General's report focus only on the issue of certification? A supposed evaluation of AAI process that turns only on this seems ridiculous. I have many different consultants conducting AAI and on reflection I now realize that this is a part of the report that I pay less attention to. I look more carefully at the technical elements. Did they conduct interviews? Was the breadth of the historic record review sufficient? Was the field inspection thorough and properly documented? Is this a thorough and well-crafted report? Note to self, make sure the service providers have used the proper certification language at the end of the report. But tell me - why did the Inspector not look at these other aspects of the reports? I don't get in a lather over what they've "discovered" because, taken as written, they illuminate a practice that owes to a lack of discipline and protocol, not necessarily one that should signify an overall lack of AAI quality. In other words, I do not believe a mis-worded certification statement or a missing resume is a certain sign that the rest of the undertaking was poorly done. Read the report. Draw your own conclusions. Markus ----- Original Message ----- From: "Lenny Siegel" To: "Brownfields Internet Forum" Sent: Tuesday, February 15, 2011 2:41 PM Subject: Re: [CPEO-BIF] EPA's Inspector General reviews All Appropriate Inquiries reports > This is an important subject. Most of the usual suspects have already > chimed in. I invite other members of this list to join the discussion. I > would particularly like to hear from government officials. Since many > agencies discourage statements that might be misinterpreted as official, I > am willing to anonymize submissions. > > Personally, I don't think the solution lies in paying environmental > professionals more or restricting who might conduct a Phase One. Those > might be attractive options in their own right. > > But I believe we have to recognize that environmental protection is > inherently a government function. It is not inherently protective of > public health and the environment to allow private consultants, no matter > how qualified and how well paid, to conduct environmental assessments that > are questioned only if someone goes to court down the road. > > The lesson of the Inspector General's report is that government officials, > directly accountable to the public, need to oversee site assessments. It > means that assessments should routinely be made available to the public, > and that environmental regulators should check all of them against a > checklist - as the Inspector General's office did. A percentage should be > fully audited. To me, this is the best way to ensure quality. > > Lenny > > -- > > > Lenny Siegel > Executive Director, Center for Public Environmental Oversight > a project of the Pacific Studies Center > 278-A Hope St., Mountain View, CA 94041 > Voice: 650/961-8918 or 650/969-1545 > Fax: 650/961-8918 > > http://www.cpeo.org > > > > _______________________________________________ > Brownfields mailing list > Brownfields@lists.cpeo.org > http://lists.cpeo.org/listinfo.cgi/brownfields-cpeo.org > -- Lenny Siegel Executive Director, Center for Public Environmental Oversight a project of the Pacific Studies Center 278-A Hope St., Mountain View, CA 94041 Voice: 650/961-8918 or 650/969-1545 Fax: 650/961-8918 http://www.cpeo.org _______________________________________________ Brownfields mailing list Brownfields@lists.cpeo.org http://lists.cpeo.org/listinfo.cgi/brownfields-cpeo.org
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