2. Section 4 Requirements, b(4): This section requires 'prevention, control, mitigation, and /or remedial measures where adverse impacts are identified.'EMSs require the organization to have strong preventative measures in place. The words 'control, mitigation and remedial measures' leaves the possibility open that environmental insults will be tolerated. Strengthen this section to stress the importance of the prevention-based system that does not pre-suppose that environmental damage is a part of doing business but, conversely, pre-supposes that it is NOT a part of doing business.

3. Section 4 Requirements, c.: Require and define sustainability as it pertains to purchases, buildings, and projects. Sustainability considers the entire life-cycle of a project, building or operation. It considers energy use, water use, and resource use over the life of the project or building. It considers these issues up-front in early design stages. For instance, designing an HVAC system after energy-saving measures have been designed such as daylighting and windows with improved R-values can reduce the size requirements for the HVAC system, as well as long-term energy costs.

4. Section 4 Requirements, c(2): Most EMSs require a strong stance on public involvement. This section does not encompass opportunities for DOE to involve itself in open public dialog. Examples of public involvement could be: DOE-funded mentorship programs for local businesses involving technology transfer of pollution prevention, sustainability and/or other environmentally related sciences or requiring involvement in local environmental issues, such as groundwater, energy conservation, etc. A dialogue such as this could greatly enhance DOE's stance with the public on issues near and dear to DOE such as nuclear waste transport and disposal. ]]>