&EPA United States Environmental Protection Agency Office of Solid Waste and Emergency Response DIRECTIVE NUMBER: TITLE: 9230.0-08 Planning for Sufficient Community Relations: Superfund Mgmt Review Rec #43A APPROVAL DATE: 3/7/90 EFFECTIVE DATE: 3/7/90 ORIGINATING OFFICE: OSWER/OERR/HSCD Q FINAL D DRAFT STATUS. REFERENCE (other documents): OS WER OS WER OS WER 'E DIRECTIVE DIRECTIVE Dl ------- REPORT DOCUMENTATION PAGE Form Approved OMB No. 0704-0188 1. Acrency Use Only: PB90-249533 2. Report Date: 03/07/90 3. Report Type And Dates Covered: DIRECTIVE 4. Title And Subtitle: Planning for Sufficient Community Relations (Superfund Management Review: /43A) 6. Author(s) : 5. Funding Numbers: 7. Performing Organization Names And Addresses: Environmental Protection Agency Office of Solid Waste and Emergency Response 401 M Street, SW Washington, DC 20460 8. Performing Organization Report Number: EPA/9230.0-08 9. Sponsoring/Monitoring Agency Name(s) And Address(es): Environmental Protection Agency Office of Emergency and Remedial Response 401 M Street, SW Washington, DC 20460 10. Sponsoring/Monitoring Agency Report Number: 11. Supplementary Notes: 12a. Distribution/Availability Statement: 12b. Distribution Code: 13. Abstract: Provides guidance to Regional staff on planning for sufficient community relations at all stages of the Superfund process. This document identifies specific planning activities that have been used successfully in the Regions. 14. Subject Terms: SUPERFUND DOCUMENT: Remedial 15. Number Of Pages: 10 16. Price Code: A02 17. Report Security Classication: 18. Page Security Classication: 19. Abstract Security Classication: 20. Media: ------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 MAR OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE MEMORANDUM OSWER DIRECTIVE 9230.0-08 SUBJECT: FROM: TO: Planning for Sufficient Community Relati (Superfund Management Review: #4 Henry L. Longest II, Director Office of Emergency and Remedial Response Director, Waste Management Division Regions I, IV, V, VII, VIII Director, Emergency and Remedial Response Division Region II Director, Hazardous Waste Management Division Regions III, VI Director, Toxic and Waste Management Division Region IX Director, Hazardous Waste Division Region X PURPOSE The purpose of this short sheet is to provide guidance to Regional staff on planning for sufficient community relations activities. BACKGROUND The Superfund Management Review (SMR) found that "limited time and resources for Regional staff keep them from doing the communication they think necessary and essential. Site managers and community relations staff are concerned that EPA may be letting some potentially serious conflicts develop with communities because they cannot get out to the sites early enough or frequently enough." This document has been prepared to help Superfund managers promote earlier and more freguent citizen involvement at Superfund site communities. Printed on Recycled Paper ------- - 2 - OSWER DIRECTIVE 9230.0-08 GUIDANCE This guidance identifies specific planning activities that have been used successfully in the Regions. These activities encourage Superfund managers to take the following steps: o integrate community relations into all technical phases, o ensure responsive community relations activities, o dedicate adequate resources to support community relations needs, and o establish realistic schedules to meet Superfund site community needs. I. Integrate Community Relations Into All Technical Phases Integrating community relations into the remedial process at sites is a team effort that takes the commitment of both the Community Relations Coordinator (CRC) and the Remedial Project Manager (RPM). To integrate community relations into the remedial process, Regions should do the following: o Train all technical staff in community relations. Because technical staff are site managers, it is important for them to understand community relations concepts and requirements. RPMs have found the two-day Community Relations Skills Training Course, sponsored by headquarters, to be extremely useful. This free course is offered periodically in each Region. Many Regions have also developed their own Regional training programs that are very successful. o Encourage RPMs to be active in community relations. Community relations works best when the CRC and RPM are a team in which the RPM is an active player. While CRCs can provide expert advice and guidance, RPMs should not divorce themselves entirely from all community relations activities. To do so alienates community relations from the overall remedial process. Involvement by the RPM furthers public participation and ensures integration of community relations in the remedial process. One way for RPMs to be involved is for them to participate in the community interviews conducted as part of the Community Relations Plan (CRP). Frequently, these interviews can be scheduled to coincide with the RPM's trip to the site on other matters. Even though the RPM may not be active in the interviews or assist in the preparation of the CRP, the RPM's presence has several positive effects. Citizens see that there is real interest in what they have ------- OSWER DIRECTIVE 9230.0-08 to say, the RPM begins to know individuals in the community (which is a start to establishing trust), and the RPM gets first-hand understanding of community interests and sentiments. It is also effective for RPMs to participate in other community relations activities. They can coordinate with the CRC to attend community meetings, make periodic telephone calls to key people in the community, or informally visit with community members when they make site visits. Although they will not be able to participate in all community relations activities, they should request briefings after key activities and keep a steady dialogue with the CRC. Make CRCs integral members of the site team. CRCs have expertise in planning and implementing community relations, but they can only contribute if they are made members of the site team. RPMs must recognize however, that just as their own workloads preclude them from participating in all community relations activities, CRCs have tremendous workload requirements that result in their inability to attend all site meetings. Therefore, the RPM and CRC need to coordinate at critical points and keep each other up to date at all times. II. Ensure Responsive CommunityRelations Activities The SMR found that about one-quarter to one-third of Superfund sites were controversial enough to warrant extensive community involvement. To respond to this critical finding, the study recommended that "...EPA should inform citizens early at all sites, and should then work most intensively at those sites where there appear to be substantial citizen concerns and incipient controversies." To ensure that community needs are identified and appropriate community relations activities are performed, EPA should do the following: o Prepare community relations plans (CRPs) and keep them current. The CRP is the main tool that identifies community relations needs and CRC activities for a given site. Because the CRP is developed prior to the beginning of Remedial Investigation field work, it is an early opportunity for EPA to assess the level and nature of citizen concerns. It can be the basis of an initial assessment to determine whether the site will require extensive community involvement. ------- - 4 - OSWER DIRECTIVE 9230.0-08 Although EPA is required to revise the CRP after the Record of Decision (ROD) is signed, several Regions do not wait until this technical milestone is reached. Instead, if changes at the site occur, the RPM and CRC should update the CRP so the document is accurate and timely. Periodic updates also bring Regional staff into the community, provide EPA additional opportunities to talk with the public and continue fostering good relationships between the Agency and the site community. o Maintain regular communications with the community. Communities want to know they are being heard. This can be accomplished by making monthly telephone calls to key local officials or citizen leaders. These telephone calls help the RPM and CRC follow community interest in the site and let the community know that EPA wants the community's input. The RPM and CRC can also use this communication technique to update the community on site progress and other site-related activities. Regions have also set up toll-free numbers that are advertised to residents in a site community. This technique provides citizens with easy access to EPA and can let EPA know if there are unresolved issues or problems in the community. Another way to maintain contact with the community is through fact sheets. Some Regions have implemented a policy of preparing bi-monthly fact sheets for all sites. A fact sheet can include information that encourages public participation by encouraging citizens with questions and/or comments to write or call the RPM and CRC. It may also include a blank mailing label where citizens who are not already part of the mailing list are encouraged to add their names. The letters or telephone calls that RPMs and CRCs receive assist EPA in measuring the level and type of interest that exists. This understanding is critical to planning and scheduling responsive community relations activities. In order to perform these planning and communication activities, as well as respond to specific community needs, adequate resources must be available. Ill,.Dedicate Adequate Resources to Support Community Relations Needs The allocation of adequate resources is a vital step in planning for sufficient community relations and requires cooperation and coordination between EPA technical and community ------- - 5 - OSWER DIRECTIVE 9230.0-08 relations staff. The following resource planning guidelines are currently in use in many Regions to assist in allocating adequate funds toward community relations activities. o The more complex a site is, the greater the community relations needs will be. The CRP identifies the community relations activities required by a given site and serves as a useful planning tool for preparing the community relations budget. RPMs, in consultation with CRCs, should prepare a budget with sufficient funds for staffing and financing planned community relations activities. In addition, Regions should do the following: o Establish "...a discretionary fund that [can be used] to fund additional work necessary to respond to citizen concerns," as recommended by the SMR. Responding to the public's request for more sampling activities is a possible way to make use of the discretionary fund. The discretionary fund may also be used to finance additional community relations activities at a site where the level and nature of community interest warrants additional activities not included in the original budget. As described in the SMR, the discretionary fund can enable RPMs and CRCs to respond to the site community's needs, thereby enabling the citizens to become "partners in the (decision-making) process, rather than angry adversaries." o Determine appropriate staffing. EPA Managers need to consider the site's community relations needs in making technical staff decisions. Whenever possible, EPA managers need to staff the most controversial sites with more senior personnel who are experienced in dealing with the public. In the event that one team member must be replaced, an EPA manager may be able to preserve some level of continuity by keeping the second team member at the site. For example, whenever possible, if the RPM is new, the CRC should not be switched. As quickly as possible, new staff need to be educated about the site's history and the community's involvement and concerns. IV. Establish Realistic Schedules To Meet Superfund Site Community Needs Community relations activities are part of the Superfund process and need to be built into every remedial schedule. If adequate time is not factored into the schedule to meet community relations needs, delays imposed by citizens are more likely. ------- - 6 - OSWER DIRECTIVE 9230.0-08 ROD deadlines should be based on remedial schedules that reflect both technical and community relations milestones. By working closely with CRCs, RPMs can become familiar with the public involvement needs of a community and plan accordingly. Many Regions use the following techniques to meet Superfund site community needs: o Anticipate public involvement needs throughout the remedial process. For scheduling purposes, it is best to determine well in advance which communities will request standard 30-day public comment periods and which will need extensions, based on the level of community interest, involvement, and other site-related activity. If a site community shows little interest in a site, a 30-day public comment period is generally required. If, however, there is substantial interest in the site, the RPM should factor adequate time (generally 60 days) for public comment and response into the remedial schedule. Anticipating the amount of time a community will need for a public comment period is critical to scheduling realistic ROD deadlines. o Plan for a public meeting to initiate each public comment period. At least one month of planning is required. The CRCs assist the RPM in coordinating a public meeting by contacting the local community leaders, providing notice of the meeting in local newspapers, preparing a fact sheet, preparing graphics for the presentation, and providing overall meeting logistics support. It is best to reserve the meeting space at least four weeks ahead of time. The RPM, CRC, and other guest speakers at the meeting should organize a planning meeting at least three weeks ahead of the public meeting. The public notice should be placed in the local newspapers two weeks in advance of the meeting. The "dry run," or rehearsal, should take place one week before the meeting. Advance planning and practice is key to preparing an effective public meeting. o Track upcoming technical milestones with community relations needs. Some Regions have established computer-based tracking systems to assist RPMs and CRCs in closely coordinating technical and community relations activities. Other Regions use manual tracking systems or hold bi-weekly or monthly coordination meetings between RPMs and CRCs. Whether the Regions use computer-based manual tracking systems to track both technical and community relations milestones at each Superfund site is not important. What is critical, however, is that regular tracking and coordination of efforts is taking place between RPMs and CRCs. ------- - 7 - OSWER DIRECTIVE 9230.0-08 By considering the community relations needs at all stages of the Superfund process, RPMs can work with CRCs to prepare remedial schedules that reflect realistic remedial goals and deadlines, and provide sufficient lead time for planning community relations activities. ------- |