Citizens Against Remediation Extremes
100 Wiltshire Drive; Oak Ridge, TN 37830
c/o Alfred A. Brooks - (615) 482-1559

An Environmental Policy Petition

The petitioners believe that the reduction and prevention of 
environmental contamination is one of the many important problems facing 
our society and affecting the quality of life but that current Federal 
policy may lead in some instances to unnecessary extremes of 
remediation. We specifically believe that:

1) The current CERCLA objective of reducing an environmental contaminant 
to its pristine, pre-industrial level independent of any significant 
risk reduction accomplished is often wasteful of funds which are badly 
needed for other purposes and thus is not in the public's best interest.

2) To be effective, environmental remediation must be carried out within 
a comprehensive Federal policy which correctly reflects all of the 
risks, environmental and otherwise, to which the general public is or 
may be subjected and are candidates for Federal actions. The Federal 
strategy for risk management must be to enable, in so far as possible, 
an optimal use of available resources.

3) Priority for public expenditures should be based on the objective of 
reducing the most serious public risks to an acceptable level relative 
to the unavoidable background risk levels.

4) Conservatively biased risk assessments in the resource-constrained, 
real world are not conducive to good risk management and, in fact, may 
preclude good risk management by obscuring the real risks being incurred 
and creating public fears which hamper objective decisions. Likewise 
initial conservative risk assessment inhibits normal uses of land until 
such time as realistic risks can be determined.

5) To be meaningful, risk assessment must be based on unbiased, site-
specific, central values of risk parameters and an associated risk 
distribution function which clearly states what fraction of the 
population may be at risk as a result of a current contaminant level or 
a proposed remediation expenditure.

6) The appropriate Federal agencies should be charged with and funded 
for the completion of an accepted data base of unbiased information by 
which the foregoing can be accomplished and that this data base be 
upgraded for site-specific circumstances as the occasion demands.

7) Only in the presence of an immediate demonstrated risk should 
substantive remediation be allowed to proceed in the absence of an 
unbiased, risk assessment.

The petitioners respectfully request that Congress consider the above in 
the current review and re-justification of the CERCLA legislation, House 
Resolution #3800 and the corresponding Senate bill.

July 27, 1994

Copies of this petition the original of which was signed by over 
350 residents have been submitted to Rep. Zack Wamp and Sen. Fred 
Thompson.