Regulatory Participation in the Systematic Planning Process
The Triad requires significant changes in the way regulatory agencies participate in project planning and data collection activities.
The Triad requires significant changes in the way regulatory agencies participate in project planning and data collection activities of environmental projects. For the Triad, the regulatory effort is "front-end loaded." This means that full regulatory participation is required in the planning and data collection stages of the project. This is very different from traditional projects where regulatory comment is typically the heaviest subsequent to characterization activities.
As part of the systematic planning process, regulatory personnel must participate in the initial development of project goals and the conceptual site model (CSM) and identify issues of regulatory importance early in the planning process. The Triad's focus is on managing decision-making uncertainty. Decision-making uncertainty is embodied in the CSM. The CSM is also the foundation for designing cost-effective approaches for managing uncertainty. If regulators do not concur with the CSM or with the assessment of the uncertainty it contains, there will not be agreement about uncertainty management strategies, data collection programs addressing uncertainty, or ultimately the decisions developed from the resulting data sets.
Contrast this model for regulatory participation with the traditional model where remedial investigations are performed with little regulatory input. Inevitably, remedial investigation reports receive numerous comments from the regulatory agencies, many of which could have been resolved prior to developing a remedial investigation work plan.
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