Comment submitted by B. Koontz

As a program funded through the general appropriations to the EPA by Congress, Superfund sites will most likely continue to be addressed at a slow rate. It is unfortunate that in a time of elevated unemployment rates that additional funding mechanisms such as the previous user tax are not available to support additional assessment and remediation activities of the program. The previous user tax placed a burden on chemical users and created a link between the major chemical users and the funding of clean up activities. Future funding via a tax might be better received if the funding targeted violators of environmental standards rather than broad industries. Southern and central California are experiencing extreme challenges to the existing water supply due to environmental protection of species in the Sacramento delta and an extended drought. As this trend continues the value of clean water will increase dramatically. Future selection of sites should give additional attention to areas of the country where water resources are at a premium. It appears as if a significant return on investment is more likely in situations where the value of clean water is high or likely to increase at an accelerated rate. None of the selected sites for this rule are located in California. The time required to complete Superfund projects and the names given to them have resulted in negative perceptions of the program. Additional favorable consideration of future projects should be directed to states, counties, contractors and work groups that demonstrate the greatest ability to implement projects in an efficient and effective manner. Rewarding innovation and success in the program may stimulate growth through efficient use of funds. Furthermore, it is common for the name of a site to be derived from the town, former business or current property owner. Although this process is practical, it has the potential to add a stigma that may not be entirely accurate at sites with multiple, potential, responsible parties. An alternative naming convention for sites, after initial listing, that signifies growth and renewal might be warranted in order to reflect the goals for a cleaner and healthier environment. A site naming convention integrating the common names of plants, trees or other biological organisms reflective of the area ecology may foster improved public perception. Additionally, it may symbolize the potential for growth and renewal that is anticipated at the location. The use of such names at community meetings and on project documents could support this concept. Although Superfund is a federal program, the local agencies are informally tasked with keeping community members informed throughout the process. Federal agencies may work with regional contractors and may appear for occasional public meetings, but the need to share information and build relationships with local agency representatives should not be overlooked. Local administrators should be integrated into these types of projects and utilized for their area expertise and ability to interface with constituents. Open dialogue with local officials can facilitate communication channels that are critical when addressing topics such as community exposures, environmental contamination and relative risk.