|From:||Aimee Houghton <firstname.lastname@example.org>|
|Date:||Sun, 23 Feb 1997 16:18:55 -0800 (PST)|
|Subject:||TAPP RULE COMMENTS|
I submitted this to ODUSD(ES) today. LS TO: Office of the Deputy Undersecretary of Defense for Environmental Security/Cleanup FROM: Lenny Siegel, SFSU CAREER/PRO SUBJECT: Proposed Rule on Technical Assistance for Public Participation DATE: February 20, 1997 I am pleased to have the opportunity to comment on the Proposed TAPP Rule. Once implemented, this rule will significantly enhance the oversight of Department of Defense cleanup and ensure effective participation by community stakeholders. In general, I think the proposed rule does a good job of meeting the goals of the Congressional authorization. My greatest concern is that public stakeholders have access to independent technical advice as soon as possible. I do have a few minor suggestions however: 1) It should be clear that academic institutions and other non-profit organizations that are not small businesses qualify as assistance providers. 2) The list of qualifications for providers should be flexible to encourage the formation of teams that include both technical experts and experienced communicators. 3) Purchase orders smaller than $25,000 - such as $5,000 - should be available to support workshops and other training activity. The qualifications for trainers should be broad enough to include non-technical "process experts." 4) Some vehicle is necessary to help community RAB members define their technical assistance requirements, evaluate potential assistance providers, and supervise selected providers. In my experience, many communities lack the knowhow to get started. This vehicle could be the support - through other means - of intermediary organizations who could facilitate the acquisition of independent technical services. Or if could be the availability of mini-grants - again in the $5,000 range - for the direct acquisition of intermediary services. 5) Similarly, I believe it is important for DOD to encourage and even support the creation of a directory of potential service providers. This directory would include references from past clients, so community participants would have some help as they evaluate potential providers. 6) Finally, technical assistance funding should not encourage a "use it or lose it" approach. Provider hours not used in the year of contract award should clearly be available in the following year. I believe that most community participants are likely, under such conditions, to carefully conserve the resources made available to them under this program. I may be contacted at SFSU CAREER/PRO, 425 Market Street, San Francisco, CA 94105. The phone number at that office is 415/904-7750. Fax is 415/904-7765. Thank you.
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