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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
OSWER 92.30.0-99
Signed October 12, 2001
MEMORANDUM
SUBJECT: Early and Meaningful Community Involvement
FROM: Elaine F. Davies, Acting Director s/Elaine F. Davies
Office of Emergency and Remedial Response
TO: Superfund National Policy Managers, Regions 1-10
PURPOSE
To improve early and meaningful community involvement in
Superfund site decision-making.
BACKGROUND
In an April 10, 2001, memo on EPA's Regulatory Decision
Process, Administrator Whitman endorsed "vigorous public outreach
and involvement" in working toward environmental goals. Her
support for effective public participation is consistent with the
Agency's draft Public Involvement Policy (65 Fed. Reg. 82335,
December 12, 2000). Among other things, the draft Policy
emphasizes that Agency programs, when implementing their
responsibilities, should:
1. Plan and budget for public involvement.
2. Identify interested parties.
3. Consider technical or financial assistance.
4. Provide timely and useful information and outreach.
5. Conduct meaningful involvement activities.
6. Assimilate public input and provide good feedback.
Superfund has a long-standing commitment to community
involvement (also known as public participation) that
incorporates these functions. In a 1991 memo(OSWER Directive
9230.0-18), one of my predecessors, Henry Longest, encouraged
site responders to "demonstrate to citizens that they are
involved in the decision-making process." That memo identified
four key practices:
- Listen carefully to what community members are saying.
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- Take the time needed to deal with community concerns.
- Change planned actions where community input has merit.
- Explain to the community what EPA has done and why.
This memo builds on the 1991 memo and encourages more
substantive involvement of communities from the very outset of a
cleanup. The involvement should begin prior to any on-site work
and continue throughout the cleanup process, including during any
5-year reviews. This memo focuses on six practices that you
should be implementing during Superfund responses.
PRACTICES FOR EARLY AND MEANINGFUL INVOLVEMENT
1) Energize the community involvement plan (CIP). The CIP
should be a living vision that is focused, current and helpful.
Ideally, a draft of the CIP should be reviewed by the community
to ensure that the CIP is on target and meaningful. Making the
involvement plan an actual partnership plan, endorsed by the
community, is a best practice. All site team members should
contribute to early development and implementation of the CIP.
2) Provide early, proactive community support. You should
do more to promote and give assistance to communities from the
very outset of the work at a site. Superfund has a variety of
community assistance mechanisms: Technical Assistance Grants,
Community Advisory Groups, Technical Outreach Services to
Communities, and the Superfund Job Training Initiative. You
should make sure community groups know about these opportunities
by the end of the site investigation and you should encourage
them throughout the cleanup process to take advantage of what is
available. You should also be creative in identifying site-
specific ways to enhance the ability of a community to
participate (e.g., arranging for educational activities or
facilitation services).
3) Get the community more involved in the risk assessment.
You should assume the community will be able to understand risk
assessments and provide useful input. If the right questions are
posed, the community can make important contributions from the
outset. In particular, you should ask community members about
patterns and practices of chemical usage, exposure pathways, and
health concerns. At big or controversial sites, you should share
a draft of the scope of work with the community and answer
questions that are raised about it. You should also provide
regular and clear feedback on the progress of the risk assessment
and its results. For more ideas, see OSWER Directive 9285.7-01E-
P, Community Involvement in Superfund Risk Assessments.
4) Seek early community input on the scope of the remedial
investigation/feasibility study (RI/FS). Soliciting input before
the start of the RI/FS on its scope and approach is a concrete
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demonstration that you take early involvement seriously. In
particular, you need to ask the community what cleanup
alternatives should be evaluated during the FS and then consider
thoughtfully the input you get. This does not mean you have to
do or include exactly what the community wants. It does mean you
should listen carefully to identify and understand significant
concerns that have merit and should be addressed.
5) Encourage community involvement in identification of
future land use. The Superfund Redevelopment Initiative focuses
on helping communities participate in identifying future land use
at Superfund sites. Early during removal and remedial site
planning, you should work with the community to develop a process
for exploring future use. This should include providing the
information and tools to make this exploration a success. The
community should have the lead in assessing its social, economic
and recreational needs and in giving us its perspective of the
most likely future use. You should encourage this effort, while
not advocating particular views or options.
6) Do more to involve communities during removals. Early and
meaningful community involvement at removals is important.
Whether it is an emergency response or a non-time critical
action, community involvement should not be neglected or
postponed. While initial calls should be to state and local
authorities, soon thereafter you should reach out to the entire
community, which may have a high level of anxiety and concern
about health and safety. You need to demonstrate our sincere
concern and credibility in order to set the stage for the
community cooperation that may be critical during the response
(e.g., during an evacuation or relocation). You should not wait
to share important information. If you proceed in a spirit of
"early, humble coordination," as one On-Scene-Coordinator once
put it, you will be surprised at how much good input and help you
get.
IMPLEMENTATION
The practices described above are good ways to help achieve
early and meaningful community involvement(see attachment for a
handy checklist). They are by no means the only effective
approaches. Indeed, they may not even be appropriate in certain
circumstances. Each community is different and deserves its own,
well-thought-out involvement plan. As you conduct removal and
remedial actions, you should be creative and proactive in looking
for opportunities that meet the needs and interests of the
community, while making sound cleanup decisions. You should
always be clear about the respective roles of the participants to
avoid creating unrealistic expectations about how decisions will
be made.
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The responsibility for community involvement is a team
effort. You achieve the best results when all the key players —
the remedial project manager, the on-scene coordinator, the risk
assessor, the legal advisor, the site assessment manager and the
community involvement coordinator -- cooperate to effectively
involve the community. Also, all program managers should look for
ways to encourage community involvement and to recognize staff
members who successfully practice it.
CONCLUSION
Public involvement is an integral part of both removal and
remedial actions. Involvement should occur early and be sustained
in a meaningful way throughout all stages of our work. This is
strongly encouraged by EPA's Public Involvement Policy and should
lead to better cleanups and more satisfied communities.
Copies of this document are available on our web site at
http://www.epa.gov/superfund/pubs.htm. General questions about •
this topic should be referred to the Call Center at 1-800-424-
9346.
Attachment
cc: Jeff Josephson, Lead Region Coordinator, USEPA Region 2
NARPM Co-Chairs
On-Scene Coordinators
Community Involvement Managers
OERR Records Manager, IMC 5202G
OERR Documents Coordinator, HOSC 5202G
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Key Practices for Early and Meaningful
Community Involvement at Superfund Sites
From OSWER Directive 9230.0-18
Listen carefully to what community members are saying.
Take the time needed to deal with community concerns.
Change plans where community suggestions have merit.
Explain to the community what EPA has done and why.
From OSWER Directive 9230.0-99
Energize the community involvement plan.
Provide early, proactive community support.
Get the community more involved in the risk assessment.
Seek early community input on the scope of the remedial
investigation/feasibility study.
Encourage community involvement in identification of
future land use.
Do more to involve communities during removals.
Useful Resources
EPA Draft Policy on Public Involvement:
http://www.epa.gov/stakeholders/policy.htm
Model Plan for Public Participation:
http://es.epa.qov/oeca/oej/nejac/pdf/modelbk.pdf
Lessons Learned About Superfund Community Involvement:
http://intranet.epa.gov/oerrinet/topics/cioc/lessons/index.htm
Community Involvement in Superfund Risk Assessments:
www.epa.gov/oerrpage/superfund/programs/risk/raqsa/ci-ra.htm
Superfund Community Involvement Website:
http://www.epa.gov/superfund/action/community/index.htm
Superfund Redevelopment Initiative Website:
http://www.epa.gov/superfund/programs/recycle/recycle.htm
EPA Stakeholder Website:
http://www.epa.gov/stakeholders/intro.htm
International Assoc. of Public Participation Practitioner Tools:
http://www.iap2.org/practitionertools/index.html
Community Partnering for Environmental Results: A computerized
learning program for developing community involvement skills
(see Regional Training Officer or Community Involvement
Manager for access)
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