UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C 20460
SEP 2 8 1990
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SOLID WASTE AND EMERGENCY RESPONSE
OSWER Directive #9230.0-17
MEMORANDUM
SUBJECT: Using State and Local Officials to Assist in Community
Relations (Superfund Management Review: .Recommendation
#43.K,L)
FROM: Henry L. Longest II, Director
Office of Emergency and Remedial
TO: Director, Waste Management Division
Regions I, IV, V, VII, VIII
Director, Emergency and Remedial Response Division
Region II
Director, Hazardous Waste Management Division
Region III, VI, IX
Director, Hazardous Waste Division
Region X
Community Relations Coordinators, Regions I - X
Purpose: To increase communication with the public by
involving State and local officials.
Background: The Superfund Management Review (SMR) found
that EPA's communication with citizens near Superfund sites is
not as frequent as site managers and community relations staff
believe necessary due to limited resources and the difficulties
encountered in accessing remote sites. The SMR suggested that,
as a "way of coping with resource and distance problems,11 EPA use
State and local officials to augment our own efforts in community
relations. The SMR also pointed out, however, that it may not be
appropriate to use State and local officials where we and they
disagree about the course of action. According to the SMR, "such
disagreements make it both difficult and inappropriate for a
State or local official to represent EPA." fSuperfund Management
Review, p. 5-10)
Our experience tells us that, under certain circumstances,
State and local officials can be effective contributors to
community relations activities. Citizens often feel more
frinud ON Kteyeltd Paptr
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OSWER Directive #9230.0-17
comfortable Communicating with an official who is a member of
their community, and who may have first-hand knowledge about a
site. Many Regions already use State and local officials, and,
in some Regions, the State actually has the lead for community
relations.
Obj.ctiv.: To discuss specific methods for using State and
local officials to increase Superfund’s communication with the
public.
Implementation: The following recommendations describe the
use of State and local officials to serve as liaisons, to provide
and maintain information, and to assist in public meetings.
1) Use State and local officials as a liaison between the
public and EPA . Because State and local officials often are very
well-informed about a site, its history, and the affected
community, they can serve as effective liaisons between the
public and EPA, channeling information and communications between
the interested parties quickly and aptly. For example, Regions
can designate an official as a point of contact. The official
could then field inquiries from the public and relay them to the
appropriate person in the Region or link a Regional staff member
with concerned citizens or community leaders. Furthermore, as
the local officials become familiar with both the Superfund
process in general and cleanup activities at the site, they will
be able to handle more of the routine questions themselves,
thereby helping EPA, as well as the public.
Using local officials as a liaison also helps increase the
frequency of communication with the community, particularly when
a site is far away from the Regional office. In some cases, this
may be the best or only way to ensure adequate communication.
Because local officials will ordinarily live nearer the site than
do Regional staff, the community has easier and more frequent
access to them than to EPA staff. However, Regional staff must
also visit the site and meet with the community on a regular
basis.
While using State or local officials as a liaison, there are
several points to consider before making that decision. First,
local officials frequently are not well-versed in Superfund
community relations. Local officials can be effective in this
role only where Regions educate them about the Superfund process
and, of course, keep them fully informed about site progress.
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Also, State and local officials assisting with community
relations must still perform the role to which they were
appointed or elected. That role may require them to be involved
at the site in an official capacity in which they might have to
“wear two hats.” This makes it especially important to define
the officials’ roles when the community relations plan is being
drafted, or in the case of State officials, when the Community
Relations Coordinator first assesses the State’s capability for
taking the lead for community relations.
Finally, even where State and local officials are assisting
EPA, the Region needs to retain control over the release of site
information. Our experience indicates that it is appropriate to
give State and local officials a significant but clearly
supporting role in community relations activities. This
assistance may not be appropriate in every Region, and should be
considered on a case—by-case basis. Thus, Regions should
evaluate not only the relationship between EPA and such
officials, but also the relationship between the officials and
the community, before seeking their assistance. Furthermore,
although the involvement of State and local officials can
increase communication with the public, it cannot and should not
be a substitute for EPA’S direct involvement with the community.
2) Use State and local officials to maintain and provide
information . As noted earlier, Regional offices are often
located far away from a site. Some Regions find it helpful to
use State, and more often local officials, to help establish and
maintain information repositories near the site. Because local
officials frequently have first-hand knowledge of the site, they
can help determine convenient places for the repository. Where
State or local officials are helping in this way, it is
especially important that Regions provide the officials with
documents for the repository as soon as they are available.
Some States have developed what have proven to be effective
communications tools and systems of their own for providing
information to the public. Regions often copy or borrow these
aids, such as mailing lists, and save time by not duplicating the
effort that went into creating them. Regions should learn what
communications tools and systems are available through their
States as early in the community relations process as possible.
State and local officials’ knowledge of and experience with
a site and its history, and especially their understanding of the
community, provide a wealth of information for the Regions. EPA
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can utilize State and local officials’ knowledge and experience
to identify people to interview for the community relations plan,
to gather background information for fact sheets, and to review
press releases and other documents. Capitalizing on this first-
hand source of information allows Regions to begin the community
relations process faster and helps target the effort for the
particular community. Because of their ties to a community and
their history with a particular site, State and local officials
can be an extremely valuable group of effective communicators of
site information. These officials represent a resource whose
potential to contribute should not be underestimated.
3) Use State and local officials to assist in public
meetings . Having State or local officials introduce EPA Regional
staff or otherwise participate in a public meeting helps visibly
demonstrate a mutually supportive working relationship among the
Region, State and local officials, and the community. Both
the appearance of cooperation and the underlying relationship
require, of course, that Regions maintain frequent contact with
State and local officials to keep them informed of site progress
and the schedule for public meetings.
Regions also should include State and local officials in dry
runs of the meeting to confirm their role at the meeting. If the
officials’ role includes speaking, the dry run will provide a
final opportunity to understand their view before it is aired to
the public. These dry runs may also help to resolve issues prior
to a public meeting where there are known differences of opinion
between the State or local official and EPA.
Some Regions also use community organizations, such as the
League of Women Voters, to assist in public meetings. Members of
the organization can provide introductions and even moderate the
meeting. Although not State or local “officials,” organizations
like these are viewed as impartial parties, and consequently make
excellent third-party moderators. Using such organizations also
demonstrates to the community the Region’s willingness to include
as many members of the community as possible in the community
relations process.
Conclusion: Using State and local officials to assist
Regions in community relations activities can be an effective way
to increase the frequency and consistency of community relations
at Superfund sites. In order for it to be effective, Regions
must solicit assistance from the officials early in the community
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relations effort; ensure that the officials are educated about
how superfund works; and maintain an avenue of communications
with the officials to keep all parties well-informed. State and
local officials will often have great credibility with citizens
and their cooperation and participation can help greatly to build
public confidence around Superfund cleanup activities.
For further information regarding the involvement of State
and local officials in community relations, please contact
Melissa Shapiro of my staff at FTS 398—8340 / (703) 308—8340 or
Jeff Langholz at FTS 398—8341 / (703) 308—8341.
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