3. MANAGEMENT AND RESPONSIBILITIES
3.1 Program Organization
The organization of the monitoring team for implementation of the MMCRP for the Pacific Pipeline Project is presented in Figure 1. The major organizational aspects of this monitoring effort are as follows:
Program Management: Dr. Hamid Rastegar serves as Program Manager, and will supervise all program activities. Dr. Rastegar will directly manage the critically important Community Relations and Data Management and Reporting efforts, and he will coordinate and supervise the field monitoring and technical review functions. He will be assisted by two
Deputy Program Managers. Kirstine (Kris) Thorne will serve as Deputy Program Manager, Field Monitoring (Lead Environmental Monitor [LEM]). Susan Lee will serve as Deputy Program Manager, Expert Technical Review.
A pool of Field Monitors will serve as construction and mitigation monitors
A pool of Expert Technical Reviewers will review submitted plans; participate in the identification of performance/success criteria; participate in training as appropriate; and resolve specific technical problems in the field.
The Data Management and Reporting function will allow development and operation of a computerized database system that will allow field entry of daily reports and result in generation of reports to appropriate agency personnel.
The Community Relations function will monitor the Community Outreach and Community Partnership Programs and develop and implement the Public Access Program.
The Organization Chart shown in Exhibit 1 also displays lines of communication with PPSI under the full direction and guidance of CPUC and ANF. While this communication in the field and in the review of submitted plans is necessary, the Aspen team is very sensitive to the need to maintain the monitoring team as an objective third party contractor under the control and guidance of the CEQA and NEPA Lead Agencies, and not subject to any potential influence by PPSI's team.
3.2 Monitoring, Enforcement, and Compliance Responsibilities
Field monitoring and enforcement activities are addressed in detail in Section 6, the Field Monitoring Manual. Aspen's team will perform continuous compliance inspection during the preconstruction and construction phases of the project to ensure compliance with all applicable plans, permits, and conditions of the approval of the Commission and the ANF. Environmental Monitors (EMs) will be on-site at all times during construction, under the supervision of the Lead Environmental Monitor (LEM), Kris Thorne. The LEM and EMs will monitor all active construction areas. They will contact personnel on-site, and access Expert Technical Reviewers as needed during construction progress.
Assignment of individual EMs will be based on compliance and scientific expertise appropriate to the specific construction activity (e.g., stream or fault crossings, sensitive habitats, traffic issues). With regard to compliance and enforcement activities, if necessary the LEM and EMs will prepare and issue Non-Compliance Reports (with levels of severity ranging from a warning to an immediate stop-work order) as appropriate, depending on severity of the incident and the potential impact.
3.3 Aspen's Responsibilities and Organization
As the Prime Contractor for this MMCRP, Aspen will be the primary point of contact with the CPUC and ANF, and will manage and direct all work under the contract. Aspen will also take on full responsibility for data management, work planning and scheduling, progress reporting, accounting, and invoicing. Aspen staff will direct the two major components of this program: field monitoring and expert technical support.
Aspen will perform this work under the guidance of the lead agencies, the CPUC and ANF. Aspen is under contract to the CPUC, which has a Memorandum of Understanding with the ANF regarding program implementation. Aspen will provide progress reports to both agencies, and will provide monthly invoices to the CPUC.
Specific responsibilities of Program personnel are described in the following sections.
3.3.1 Program Manager: Dr. Hamid Rastegar
Dr. Rastegar will have full responsibility and authority to commit Aspen Team resources and ensure successful performance for the duration of the contract. He will be Aspen's primary point of contact with CPUC and ANF and will have full responsibility for all contractual matters. He will use Aspen's established management systems and procedures to ensure completion of all program activities in accordance with plans, schedules, and budgets, and he will ensure that field personnel and subcontractors are properly tasked, controlled, and integrated into project activities.
In addition to his direct supervision of MMCRP activities, Dr. Rastegar will serve as Quality Assurance/Quality Control manager for the MMCRP. This will include development of a specific quality assurance plan for contract performance, quality audits, and performance monitoring and review of project deliverables.
3.3.2 Deputy Program Manager - Field Monitoring (Lead Environmental Monitor): Kris Thorne
Ms. Thorne will manage the field monitoring effort. In addition, she will prepare the Field Monitoring Manual, and present much of the three-day monitor training course to Aspen's Environmental Monitors. She will also participate in training of PPSI and contractor personnel to ensure that these training programs comply with agency requirements. As the LEM, Ms. Thorne will interface with representatives of PPSI as well as with a variety of Federal, state, and local agencies in the field. She will supervise compliance reporting, issuance of Non-Compliance Reports, and development and implementation of variance procedures.
3.3.3 Deputy Program Manager - Expert Technical Review: Susan Lee
Ms. Lee will coordinate the services of the Expert Technical Reviewers in the plan review effort. This role includes review of subcontractors' reports and comments, and coordination with PPSI and its team to ensure timely review and responsiveness to issues of concern. She is responsible for the development of this Implementation Plan, and she will assist Dr. Rastegar with various Program Management responsibilities, including preparation of Progress Reports, and she will serve as acting Program Manager, on occasion, in Dr. Rastegar's absence.
3.3.4 Environmental Monitors
Supervised by Kris Thorne as LEM, Aspen's EMs will be in the field at all times while construction is in progress. The EMs will monitor pipeline construction at the five proposed construction spreads, as well as construction of the two pump stations at Emidio and Grapevine, and the Whitaker Pressure Relief Station. The roles and responsibilities of the EMs are described in detail in Section 6 of this Plan, the Field Monitoring Manual.
3.3.5 Expert Technical Reviewers
Aspen's team of Expert Technical Reviewers will serve several roles in the MMCRP. First, they will review and comment on PPSI's plans submitted to demonstrate compliance with various mitigation measures. In this review, they will ensure that plans demonstrate full performance of the measures and that the plans appear to provide effective environmental protection, as appropriate. The second role of the Technical Experts is to prepare detailed and specific performance and success criteria for each mitigation measure to be monitored under this program. Experts might also be asked to participate in portions of the training program to discuss some of the technical parameters that might be specifically monitored. And lastly, the experts will be available for consultation on construction issues and problems, or to monitor construction at critical locations for their resource areas. The field role is described in more detail in Section 6.3.
3.3.6 Community Outreach Team
The community involvement and public access program will be coordinated by Aspen, utilizing the in-house expertise and project familiarity of Negar Vahidi, in combination with the outreach expertise and community familiarity of Arellano Associates, under the direction of the Program Manager and Deputy Program Managers. They will be responsible for monitoring the proper implementation of the Environmental Justice mitigation measures, and for developing and implementing the Public Access Program. These programs are described in Sections 3.5 (Public Access Program) and 6.12.3 (Approach to Monitoring Environmental Justice Mitigation Measures).
3.3.7 Data Tracking System Staff
Aspen's MMCRP will utilize a computerized database program to record daily activity on each spread, record variance and non-compliance events, and generate reports. Aspen will coordinate the overall data management effort in-house with the assistance of Kris Thorne, Vida Strong, and Craig Hattori, who will coordinate report design, development, and system maintenance. Development of the integrated data management program itself will be provided by Dr. Howard Wolff of Butte Canyon Research Associates (BCRA).
3.4 Data Management System
The data management software developed for use in the MMCRP will be simple and interactive. It will be implemented with minor training and through use of a network of portable computers connected via modem to a central server at Aspen's headquarters office. The software will record the daily results of the environmental inspection and monitoring program, including ranking the severity of any non-compliance condition activities and the degree of attention required by the agencies. The system will include generation of daily reports faxed to Lead Agencies as well as responsible agencies and parties as determined appropriate by Aspen and the Lead Agencies. The system will be accessible via modem and passwords to the lead agencies at all times. The reporting system will generate reports in a variety of formats, summarizing inspections codes and incidents. The system also provides the monitors with the ability to determine the number and description of each mitigation measure to be implemented at any specific location.
Appendix D [attached for Environmental Monitors only] includes a manual describing the function and use of the software to be used in the MMCRP, including showing several of the computer screens developed by Dr. Wolff and utilized on these other projects; these screens demonstrate the system's accessibility and ease of use. Similar screens will be utilized on this project.
Report Generation and Distribution. One of the useful features of the software system will be its ability to generate a variety of reports that will serve to keep the Lead Agencies and other parties, as determined necessary, informed regarding the status of construction and compliance activities. Reports include: Daily Inspection Record, Weekly Summary Report, and Monthly Compliance Report.
One of the key activities for this program is proper documentation and reporting of many diverse activities and the status of hundreds of impact reducing measures. We have identified the reporting requirements necessary for an effective environmental inspection program, including the preparation and submittal of regular activity reports documenting the implementation of mitigation measures to agency staff and PPSI's project managers. Aspen's computerized reporting system will be based on existing systems approved by the CPUC, California Department of Fish and Game (CDFG), and Bureau of Land Management (BLM), and modified for this project. Reports will be automatically faxed to all parties each night, summarizing the day's activities and documenting the implementation of each mitigation measure.
Section 7.2 includes a complete list of agencies with jurisdiction over aspects of this project, including contact names and telephone numbers. We propose to send Daily, Weekly, and Monthly reports to the following agencies:
- CPUC and ANF
- California State Fire Marshal
- California Department of Fish and Game
We propose to send Weekly and Monthly Summary Reports to all other agencies listed in Section 7.2. In addition, all agencies will be included on the project mailing list and provided with information through the Public Access Program.
3.5 Public Access Program
The Pacific Pipeline Project has been controversial, and attracted significant amount of interest and scrutiny during the environmental review process. This level of interest and scrutiny is expected to continue during the construction and operation phases of the project. It is the intention of the Lead Agencies to provide easy public access to project and construction progress information so they can follow the progress of the construction and the MMCRP.
The public access program will provide current information to the public about the status of Pacific Pipeline construction and mitigation activities. The goals of the public access program are:
- Focus on an interactive dialogue of information which will result in the exchange of constructive ideas
- Inform as much of the affected public as possible, especially non-English speaking and low-income communities of the progress of work and implementation of the mitigation measures.
Aspen will provide public access to monitoring records and reports, and will produce and maintain public information on the status and results of mitigation monitoring on an ongoing basis. The implementation strategy for accomplishing the goals of the Public Access Program is described below.
3.5.1 Public Information
Mailing List. The MMCRP Mailing List could grow to as large as 2,500 names (although it will be expanded as demand requires), and will include the local Community Based Organizations (CBOs, described below). This list will be maintained and expanded throughout the project based on requests for addition of names and any other new information. This list will be maintained on Microsoft Access Version 7.0 database software. A user-friendly screen will be developed to facilitate quick data entry and query.
The initial mailing list will be developed by sending an inquiry to parties whose names and addresses are received from the sources listed below. If they indicate that they would like to be included on the mailing list, their names will be included on the database (we are estimating that approximately 2,500 people or organizations will respond).
- EIS/SEIR mailing list (3,700), which includes a Community Leader's List (Environmental Justice)
- Property owner list (14,000 names; PPSI will have to notify via Landowner Notification Plan per Mitigation Measure L-1)
- Community Database developed by PPSI in conjunction with implementation of Environmental Justice mitigation measures.
The following types of information will be included in the database: first name, last name, organization, department, address, city, state, ZIP Code, phone, fax, e-mail, source (where the entry was obtained from), code (type of organization), information (type of information sent), memo (comments/notes on entry). We will include e-mail addresses for as many of the government agencies and organizations as possible so that project notices can be simply sent quickly to everyone at once.
Information Repositories. Project information repositories (i.e., libraries) most accessible to construction locations will be used to house the 1993 FEIR, the FEIS/SEIR, the CPUC's certification decision and decision on re-hearing, the ANF's ROD, a copy of this Implementation Plan, and all MMCRP mail outs, so that the public can access these documents on a regular basis. Many of these libraries now have access to the Internet, where the public can use computers to search for information.
Following is a list of potential repository locations and libraries with online access to the Internet (described below). All libraries on this list were repositories for the EIS/SEIR information, but many of the repositories have been deleted from that list so we now have a more focused list that relates directly to the construction route. These libraries will be contacted individually to determine whether they are willing to be a repository site and the availability of Internet access. (Numbers in parentheses indicate Thomas Bros. Guide Page number and grid.)
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Newsletters. Aspen will design, produce and print a quarterly newsletter (including one at Project initiation) to the mailing list to acquaint the public with construction progress, implemented mitigation measures, problems identified, future plan and schedule, and methods of additional public access. The text of the newsletter document will be written with the average concerned citizen in mind; the public would not need to have technical background in order to understand the issues. The design of the newsletter will be appealing to the eye, formatted in a clean, easy-to-read layout with appropriate maps and graphics (possibly photographic images) and variations in typefaces, paragraph, box and bullet formats in order to increase interest and understandability. The design will include provision for a self-mailer in order to prevent the need for envelopes. Depending on demand and response to our initial mailing list survey, we may have to translate newsletters into one or more other languages (e.g., Spanish). An option would be to have newsletters translated into other languages but not distributed; in the English newsletter we could place a one-liner guiding people to our hotline for requesting the newsletter in other languages and the translated versions could then be distributed upon request.
Potential Newsletter Components. Following are general contents proposed for the project newsletters.
Project Web Site
An on-line service will be set-up to provide project information on a 24-hour basis. We will implement a service that can be reached by a large audience, and at little or no cost. This service will make project information accessible via the Internet and a project Web site linked to CPUC's existing Web site (gopher.cpuc.ca.gov) where the previous FEIR and FEIS/SEIR are currently located. In order to make online access more readily available beyond the Project Walk-In Site (described below), we can partner with local CBOs, libraries, and schools to allow online access for individuals wanting to search the MMCRP Web site.
The Web site will include a unique Uniform Resource Locator (URL), including a home page with buttons that link to the CPUC's site and PPSI's site. The site will have the following components to provide information and can be expanded and changed on an as-needed basis:
- A home page with description of the Pacific Pipeline Project and MMCRP including purpose of program, Lead Agency and Applicant roles, etc.
- Representative graphics, to the extent possible, that can show the regional map or project progress
- Generalized regional map showing locations of construction spreads
- Buttons leading to all other pages on the site (e.g., Table of Contents, Spanish-language page, etc.); an e-mail button, so that people can leave messages and contact us
- Possibly a survey or form to assess the general public's awareness, participation in, and contact with the project.
Back issues and current issues of the quarterly newsletters can be placed on the site. Key words on pages within the web site will be highlighted using hypertext, so that the viewer can find out about the topic by simply clicking on the word. In other words, highlighted text will take the viewer to other locations on the site that are relevant.
Community Involvement
Walk-In Information Site. A walk-in site for the public to view records or ask questions regarding the project or construction activities will be set-up (potential sites include Aspen's field office, a few selected library or city centers, PPSI's Burbank office, or CPUC/ANF office locations). Ideally, the site should be located at a mid-way point of the Los Angeles County portion of the route. Based on demographic data, this portion of the route has the most densely populated communities along the route (i.e., from San Fernando to Wilmington). Currently, three locations are being considered: Santa Clarita, Burbank, and the Taylor Yard area (Atwater, Glassell Park).
Originally, Aspen had intended to set-up a project walk-in site to be staffed by Aspen personnel. However we are very concerned about the potential security issues associated with an open-to-the-public site related to such a highly controversial project. Throughout the environmental review process, the public has tended to identify the Lead Agencies and their representatives with a certain degree of animosity despite our efforts to delineate our roles as separate from those of PPSI. Therefore, we recommend as an alternative to set up our walk-in site at the office of an existing Community Based Organization (CBO, discussed further below) or other highly visible and respected non-profit organization within one of the Los Angeles County communities traversed by the pipeline. Negotiations will be made with the organization for set-up of the site with regard to rent and staffing. We would place a desk with the components described below and provide a schedule of staff availability in newsletters and on the project Web site. Our staff would be at the site a minimum of two days and on an as-needed basis. We would ultimately donate the computer, desk, and phone line of the site to the CBO, if it meets with their approval. This site will maintain the following kinds of information:
- A sign-in log, listing of those who walk in, date, and time
- A description of issues raised and person or organization who raised the issue
- Listing and discussion of any follow up questions or issues that need to be addressed as a result of issues raised
The Walk-In Site will include the following components:
- A computer for access to the user-friendly Project Web Site
- All documents available at project repository sites (described above)
- Hard copies of questionnaires and surveys so that public can fill in and deposit
- A telephone.
It should be noted that a walk-in site would be beneficial for minority and low-income communities along the Los Angeles County portion of the route, since it is unlikely that many of the members of these communities have access to computers at home. Aspen staff will most likely join student interns to staff the site and to talk with concerned members of the public. Selected student interns would supplement Aspen's staff at the public location of the walk-in site (internship program described below). Because the interns would have to be educated about the basics of the project and would be involved with the CBOs they would serve as ideal people to staff the Walk-In Site and address the communities' questions.
CBO Surveys. On a monthly basis, Aspen will randomly survey five to ten Community Based Organizations (CBOs) that are on the project mailing list to assess their awareness, participation in, and contact with the project. This will most probably be done via a survey on the project Web site for organizations that have indicated an interest; copies will also be sent to key organizations in the community. The purpose of the survey will be to gain feedback from the community on the understanding, awareness and effectiveness of the Public Access Program. As an organization identified to receive project information, the CBO can provide critical input as to how project information is received by community and offer ongoing suggestions for improved communication.
The survey inquire regarding the following:
- Name of CBO
- Name of contact completing survey (optional)
- Level of knowledge regarding Pacific Pipeline project
- Frequency of receipt of project information via mail
- Description of how CBO disseminates/shares project information with its own constituency received via mail
- Degree to which online services are utilized by CBO
- Open opportunity to offer recommendations for improved communication.
Student Interns. College student interns from the neighborhoods through which the construction passes will be selected to serve as evaluators of the effectiveness of project information and access. They would receive all project notices and information. We will meet with the interns on a periodic basis to solicit their opinion and input on how well they thought the information was presented, their experience at community meetings, success on the Internet site, etc. This "test group" would also be exposed to a major public project and public process, and they would learn from the process as well.
A team of 10 to 15 student interns would be selected for this effort via two methods. First, identified CBOs on the existing mailing list will be requested to provide student candidates. Individuals from the community frequently work with local CBOs, and vice versa, thereby, providing a very grass-roots representation of young individuals dedicated and working in their community. Second, all local universities, community colleges and vocational institutions will also be identified for receipt of the student intern solicitation notice. The campus' career placement office will be contacted and the lead job counselor will be identified as the representative of the school for the project. The counselor would be encouraged to promote this internship opportunity as a Areal world experience affecting a student's local community. The intern solicitation notice would encourage bi-lingual/multi-lingual individuals to apply as well as students living within the project area sphere of influence.
Depending upon the number of student responses, interns may be selected through the review of his/her resume, a phone interview and/or an in-person interview, as possible. Each student will be asked to participate for a minimum of a one-year period. Additional search efforts will be conducted on a annual basis to ensure a regular test group of 10 to 15 students.
