Keith Shadden - Comments

To the PHMSA: I am a Board member for our local/county LEPC. I am sending this in accordance and in agreement of our board with their foreknowledge and approval. The pending legislation for the HMEP grant would prove an undue and unnecessary hardship for the LEPC's that benefit from this grant. Our County LEPC currently receives a $2000.00 grant from the Oklahoma Emergency Management Agency (OEM) for planning. This grant is made available to us as part of the HMEP grant to the state of Oklahoma. We recieve this funding only by completing and maintaining the organizational requirements and exercises that are currently in-place and these are recorded and monitored by sending in quarterly reports with verifications and additional dpcumentation and standard forms. This includes but is not limited to 24 hour access, community outreach, annual drills, Tier II:collection; storage; reference; 24 access and other elements associated with HazMat information and safety. The grant funding is only released in parts after completion and the meeting of the state's requirements. I would like to remind this body these are the grant requirements, not what has to be done in an actual event. In that case, we can immediately add hours and or days for responding, the required activities, monitoring, cleaning-up and after-action events, safety issues and reports. Our LEPC is indicative of all LEPC's. It is a volunteer program which also incorporates unpaid professionals, who volunteer their time, effort and resources in order to have an LEPC in our communities and jurisdictions. The money allotted is needed and utilized for this objective but doesn't cover the cost in human resources, personnel and needed additional resources, time and costs. Our LEPC group is possibly more unique in that it covers a large area but has limited resources to draw upon due to limited population and distance from outside assistance. We are dependent upon each other and our closest neighbors with or without any funding or additional support from outside sources. Your funding provides for us to have access to training and or resources that might not be readily available or affordable. It also helps sustain and maintain our organization but it doesn't necessarily "keep it alive". We do follow the existing format in our meetings, trainings and requirements. The majority of our members have taken the required NIMS training and continue to take additional courses, either on-line or as instructors become available. Once again this is on the individual's time, with their effort and at their cost for the most part. To try and break down every minute should be considered an undue hardship and frankly unworthy of the participants and their efforts for the LEPC organization to exist and possibly survive. I must re-emphasize everything is appreciated but to add more to an already burdened and strained membership load-additional duties, in a purely volunteer organization is without merit and detracts rather than adds to its efficiency. We had a full scale activation this past summer in a missing person event. People who were trained in the Nims/ICS structure advised that it was one of the best run examples of this structure that they had seen and confirmed its effectiveness in action, not only theory. It was due to the previous training already in place that we, as an organization were able to implement and efficate this in a live action. Another example I would like to express is that we had a tabletop exercise less than a month ago. It was well attended and actively participated in. Those that couldn't attend weren't there, because they couldn't take off from their jobs. This was largely due to having fought a grass fire a few days prior and because so many people in smaller communities have so many other volunteer duties that one is constantly having to "catch up" with their salaried positions when there is an actual event. I hope that this is a case in point. We have people who are using their vacation time to try to attend trainings. This is at the expense and with the compliance of their work, affecting their income/resources and maybe, most importantly, their time with their families. They are giving enough- don't be part of the process that places the "straw that breaks the camels back". We are out "there" or "here" doing this-on call 24/7 maintaining standards that we are utilizing and implementing for the good of our families and communities effectively. We are in compliance with state and national standards. What more do we have to do.... what more do we have to prove. Thank you for giving us a format in which to speak and hopefully contribute to this process from the other end of the spectrum. Sincerely, Keith Shadden Board Member Beaver County LEPC