Activities related to planning and targeting of training should be allowable. Some areas may have far more equipment on hand to deal with these kinds of potential accidents than others. This is confusing. Without adequate exercises and drills, the jurisdictions and first responders are not adequately prepared. To exclude exercises from a training program for emergency response is to do incomplete training.
Exercises are also essential for identifying training needs.
The formula proposed by DOE appears to shift the financial burden for preparedness and training to individual states, thereby creating potentially major unfunded mandates for local governments and states. The NWPA requires that waste generators pay for the costs of waste disposal, including states, tribes', and local governments emergency response and safe routine transportation-related costs. Costs for individual jurisdictions' programs must be based on needs assessments undertaken as part of the grant application, not as proposed. The jurisdiction should determine training needs and develop the budget and program to meet the needs. The Notice should address a minimal standard of need.