|From:||Seth Kirshenberg <firstname.lastname@example.org>|
|Date:||Thu, 23 Apr 1998 10:19:52 -0700|
|Subject:||FFERDC MEMO: A BROADER VIEW OF LOCAL GOVERNMENT INVOLVEMENT|
The following memorandum was sent to FFERDC members on April 10, 1998. Energy Communities Alliance (ECA) is an organization which represents local governments impacted by DOE facilities. For more information on ECA please visit our web site at http://www.energyca.org MEMORANDUM TO FFERDC MEMBERS, FROM SETH KIRSHENBERG, EXECUTIVE DIRECTOR, ENERGY COMMUNITIES ALLIANCE, DATE APRIL 10, 1998, SUBJECT BEYOND ADVISORY BOARDS: PARTICIPATION IN ENVIRONMENTAL DECISION MAKING Federal agencies need to review their advisory board policies for the involvement of local and Tribal governments. Many local and tribal governments actively participate in advisory boards, others participate on an ad hoc basis and others choose not to participate. Federal agencies must remember, as it states in the FFERDC Final Report, advisory boards should only be one mechanism of public involvement in environmental cleanup. In some communities the Federal agencies believe that Restoration Advisory Board ("RABs") or Site Specific Advisory Boards ("SSABs") are "the" conduit of environmental decision making input by the local community. For example, the Department of Energy ("DOE") headquarters staff, holds a regular conference call with its field managers. On the call, headquarters staff asks the DOE field offices if they are communicating with the SSABs. Each call the field manager answers affirmatively and headquarters and field staff believe they have the input on environmental issues from the "community." The FFERDC committee clearly stated numerous times that a RAB, SSAB or other similar group should not be the only form of public involvement for environmental decision making. Each Federal agency should ensure it communicates directly with others because the boards are only advisory in nature. Some Federal agencies seem to have missed this section in implementing advisory boards. This in turn, has caused a backlash against RABs and SSABs at some sites by local governments and others because their RABs or SSABs do not represent their local community, yet they have more input then locally elected officials into environmental cleanup decisions which impact the long-term health, safety, and welfare of the community. In one recent case, a federal agency and EPA worked through some environmental cleanup issues, and developed a solution with the input of the RAB/SSAB and thought the issue was resolved. But when the local government brought up the issue (at a later date), the issue in the mind of EPA and the federal agency had been resolved, but the elected local officials did not agree with the outcome. The federal agency people say it is the fault of the local government for not actively participating in the RAB/SSAB. However, the FFERDC recommendations for implementing advisory boards clearly suggest that the Federal agencies should not only use the RABs/SSABs for input on environmental issues, and that in the case of local governments, the Federal agencies should consult directly with local governments. In another example, federal agencies use either an advisory board or reuse organization (which does not always have sufficient local government representation) to make future land use decisions at a site. The FFERDC principles state "For properties being transferred from federal ownership, future use determinations should be made by the state, tribal, or local authorities that will have jurisdiction over the land to be transferred, with appropriate forms of stakeholder involvement." Although, I do not expect every FFERDC principle and idea to be followed explicitly, Federal agencies should ensure that basic issues such as future land use decision making are addressed by the officials elected to represent a local community and have land use jurisdiction over the property. I ask that each Federal agency review its policies and the FFERDC principles to ensure the advisory boards are implemented as intended by the FFERDC participants. Advisory Boards work well in many communities. However, the Federal agencies need to look closely at each board and ensure that they are not the only conduit for providing input into environmental cleanup decision making at a site. Where a local or Tribal government requests separate interaction on environmental issues, the Federal agency should work with the governmental entities to develop a communications mechanism to obtain input on environmental cleanup issues. Seth Kirshenberg email@example.com 1101 Connecticut Avenue, N.W. Washington, D.C. 20036
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