&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
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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:
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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
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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
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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.
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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
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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.
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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.
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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.
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