Goals for Economic development, while important to community revitalization, can never supersede public health. 1. To identify a plan to influence the decision around San Luis Obispo Counties EPA Superfund sites. 2. Advocate that the public participation program remains intact and community families have a right to information, technical assistance grants and a voice/vote on actions taken at all Superfund sites, in San Luis Obispo County. ( I can name several, the Pismo police department, ambulance services and school on bello street, is a Superfund/brownfield site) I can make a safe bet that the people that work/ live there don't know it. 3. Human health and environmental protection is a priority for actions at Superfund Sites not exclusively redevelopment potential. 4. Support the Polluter Pays Tax to provide the necessary funds for orphan sites and a robust enforcement/research capacity in San Luis Obispo County. 5. Request a meeting in Washington, DC (of local Superfund Sites leaders) with EPA Albert Kelly (Superfund) and Scott Pruitt (EPA Administrator) to discuss concerns, needs and priorities in San Luis Obispo County Superfund sites. 6. Request Kelly/Pruitt visit communities leaders/activist (not just agency and elected representatives) across the country to understand the needs, problems and solutions for specific sites. 7. Work with/coordinate support for Senator Cory Booker (NJ) who has introduced the "Environmental Cleanup Infrastructure Act". 8. In order to determine the state of human exposure, thorough “health studies” are necessary. The health studies performed at Superfund sites are inadequate, often resulting in findings that are inconclusive and short-sighted. Exposure to environmental pollution must receive the same type of government response as infectious diseases or mass cases of food contamination, including a timely response. Objective, independent, thorough, long-term studies of residents' health conditions are crucial to determining appropriate cleanup strategies and monitoring response efficacy. 9 . While site reuse may be desirable, reuse potential should not be a primary tool in gaining funding and accelerating cleanups. Third party investment is not a stable source of funds for Superfund and Brownfield sites. 10. Site-specific information needs to be published in a timely manner for all sites, not merely those with reuse potential. Communities whose welfare is at stake have the right to understand the conditions they are exposed to and participate in the cleanup decision making process. Transparency and community involvement/engagement should not merely be a method to facilitate redevelopment - it must be "central" in all stages of the cleanup process, from evaluation, to remedy selection, to execution and ongoing monitoring of success. 11. However, third party investment and brownfield redevelopment often bring about future issues in liability. ( the Pismo police department, ambulance services and school) 12. End-users purchase sites without taking on future liability and when Responsible Party cleanup is deemed complete they are often released from liability as well. However, in the cases where containment fails or cleanup later proves ineffective, such properties are left without a liable party, and become orphaned sites which must be remediated with taxpayer money. (when the community deemed all superfund/brownfield sites that people should never live on, will become the financial responsibility of the taxpayers, does not seem fair at all) 13. When sites are redeveloped, institutional controls are often put in place to restrict the type of activity which can take place on the property (ranging from light industry to residential use), however, over time these controls almost "always fail and are ignored". In order to ensure properties are used in a safe manner, either "institutional controls must be strengthened", so that if land use is altered in future, the property must be further cleaned accordingly, or we will have to simply remediate all reusable sites according to residential guidelines. 14. I'm concerned over industry representatives calling for the development of exit strategies, usually including the removal of a site from the National Priority List (NPL). This may not sound initially worrying, however, they simultaneously push for cleanup strategies that merely manage or contain toxic hazards, as opposed to complete removal or other permanent remedies (which are required by law to be considered under the Superfund Amendments and Re-authorization Act of 1986). 15. When ‘band-aid’ methods are employed at NPL sites, or in situations where permanent treatment technologies do not exist, exit strategies will not be possible, as the sites require continual maintenance and monitoring. This is evident through the history of the Superfund sites only 30% of the sites where construction is completed have been removed from the NPL, as the rest require long-term management. Thus, these two goals for which industry advocates are incompatible. If Responsible Parties want their sites to be delisted from the NPL, they must either pursue complete cleanup or accept the necessary continual oversight to ensure that toxic hazards are under control. 16. This section advises that the EPA “revise NPL deletion policy to maximize statutory flexibility”, which yet another example of how the Task Force cators to private interests and not public health. Instead of devoting time to bending the cleanup standards to allow responsible parties to hastily conclude remedial action, the EPA should be focusing on ensuring that toxic sites are thoroughly cleaned to safe levels. 17. The NPL sites in the assessment and investigation stages will be expedited by applying new technologies an approaches. The report suggests modifying how groundwater designation is determined for aquifers which are not reasonably anticipated for drinking water - this could allow such sites go untreated. However, consumption is not the only pathway of toxic exposure - even when a contaminated aquifer is not a source of drinking water, the groundwater plume may migrate miles, contaminating soil and releasing vapor which can pose a major health hazard. 18. Monitored Natural Attenuation, which in essence is doing nothing - watching and waiting for the contaminants to take care of themselves. Many may claim that the chemicals in the aquifer degrade over time, however there is no scientific data to support that this indeed occurs, as opposed to the dilution of contaminants that occurs when the groundwater plume expands. 19. Without proper oversight and public accountability, the Superfund would lose much of its remaining efficacy. Placing faith in responsible parties' remediation ignores that they have a vested interest in finishing as quickly and cheaply as possible, threatening the health of local communities in San Luis Obispo County. 20. I ask you must reinstate the Polluter’s Pay Tax if we are truly committed, as Administrator Scott Pruitt claims, to restoring Superfund cleanups “to their rightful place at the center of the agency’s core mission.” Private investment and “alternative funding mechanisms” can’t come close to compensating for the Superfund budget cuts and the high volume of abandoned sites. 21. Develop a Community Involvement Plan (CIP) it must be drafted, finalized, and implemented. The Community Advisory Committees (CAC) must include real community members who live and work around Superfund sites, not just local government representatives. Local knowledge offers indispensable on-the-ground insight and perspective, and we strongly support all stakeholders at the discussion table early in the process. 22. Finally, The use of third-party monitoring to oversee Superfund cleanup is not a new idea - it has been proposed multiple times over the history of Superfund and protested each time for the same concerns which apply to this day. Third party monitoring threatens the public’s ability to access information relevant to their health, because the monitoring official is not a government body, thus "The Freedom of Information Act does not apply". (behind closed doors deals happen at an alarming rate) 23. The public has always been the primary watchdog over local toxic hazards, as they are the only stakeholder that is fundamentally driven by protecting public health, as opposed to financial motivations, however, if third party monitoring is implemented, they could be cut out of the process entirely.