RE: Distance may be measured many ways

[Marty Walters <marty_walters@terrasano.com>]

One example is Makua Valley, which I'm involved with only 
peripherally -- I help individual citizens from a 
technical/regulatory perspective from time to time when they 
are reviewing documents or attending meetings.

What has been in the press is the push for the Army to 
complete a full environmental impact statement for Makua 
Valley, which has been a live fire training range since WWII.  
An EIS seems like a good solution for most folks, because it  
is broad based and seems like a go or no-go decision.  At 
another level, the EIS effort can be a legal strategy to prevent 
the Army from starting up training again in the valley.

But the request for an EIS also has roots in people's 
attempts to understand the RCRA closure process for the 
open burn/open detonation unit, the RCRA corrective action 
investigation, and the Army's CERCLA investigation.  

Once we went back and reconstructed the order of events 
(and especially the order of investigations and 
environmental sampling), we realized that EPA had not 
evaluated all the sites identified later by the Army, and had 
not evaluated groundwater data that was collected by the 
Army.  Once we figured out who looked at what information, 
it was easier to understand the basis of those "no further 
action" decisions that were made by EPA and the Army 
under their respective cleanup programs.  We developed a 
list of specific issues and questions to raise with each 
regulatory program lead from EPA and the Army, which was 
a lot more effective than throwing a lot of concerns out to the 
whole universe.  When we phrased our questions in the 
right context, the bureaucrat felt more comfortable 
responding and there was less frustration all around.  We 
also started asking about current compliance issues, like 
the requirement to have an NPDES stormwater permit for a 
hazardous waste unit.  When issues come up, I try to work 
with people to identify all the regulatory programs that might 
affect that issue, then develop a list of questions that need 
to be answered, then identify what kinds of decisions are 
made, and how citizens can affect those decisions.  It's 
really hard work.

Thanks for listening!
Marty Walters

One area that draws the most concern from people in 
Hawaii is the protection of cultural and historical resources, 
but this aspect is not a key to decision making in most 
environmental programs.  I try to focus people's attention on 
the environmental element, like a stormwater NPDES 
permit, that might force an agency to also acknowledge 
cultural, historical, or archaeological concerns.