United States       1980
        Environmental Protection   SWB36
        Agency
        Solid Waste       	
&EPA   Public
        Understanding
        and
        Involvement-
        The Key to
        Environmental
        Protection

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PUBLIC UNDERSTANDING
AND INVOLVEMENT—
THE KEY TO
ENVIRONMENTAL PROTECTION

Thomas F. Williams*
   L
    In the middle 1960s, when the
original solid waste and resource recov-
ery legislation was passed, the public's
rising anxiety about environmental
problems that our society had overlooked
during two centuries of economic growth
was accompanied by two illusions that
it has not been easy to dispel. The
first of these was that science could
magically produce a quick solution
to almost any problem; and the second,
that government alone could readily
work out the means of applying the
solution.  Under these principles, newly
discerned environmental problems
could be solved while everyone went
on pursuing business as  usual.  As we
have painfully learned since that time,
progress depends upon the abandonment
of such illusions and acceptance of
the fact that solving environmental
problems necessarily interferes with
business as usual. Congress has acknowl-
edged the fading of these illusions
by placing specific provisions for public
participation in the major environmental
and consumer laws which have been
created or amended in the last 10 years.
*Deputy Director, Office of Public
Awareness, U.S. Environmental Protec-
tion Agency.  Presented September
12, 1979, at a conference sponsored
by the Arkansas Department of Pollution
Control and Ecology, Solid Waste Manage-
ment Division, Little Rock, September
1979.

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    Built on the firm base of the Nation-
al Environmental Policy Act, created
at the dawn of this decade, these laws
and amendments have made for revolu-
tionary changes in the way our society
operates. We can no longer randomly
build airports, highways, or power
plants, dam rivers, market or dispose
of any chemical concoction anyway
we please while a quiet, trusting, and
docile public sits on the sidelines and
leaves it all to the experts.
    The trend toward making our institu-
tions  more responsive to the public
will has placed special communications
responsibilities on government agencies.
Unless these responsibilities are taken
seriously, meaningful public participa-
tion will be difficult, if  not impossible,
to achieve.
    This extremely serious matter
has not received enough attention
at any level of government or in any
branch of government.  It is the responsi-
bility of agency managers to ensure
that the  public has access to the scientif-
ic and economic information on which
agency decisions and actions are based.
Since agencies cannot expect the public
to read every pertinent  and voluminous
technical report published, agencies
have an obligation to communicate
the essence of complex  issues in such
a way that the voting public will under-
stand them as well as the experts do.
    To carry out this objective, agencies
must  communicate in a  variety of
ways.  Computer printouts may be
precisely what the nuclear scientist
needs, but  the worker in the generating
plant and the citizen who lives nearby
need to be informed also.  In an open
process of  assessing technology, each
has one vote.
    For  the process to work, those
who are employed in government agen-
cies must regard the public with the

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same respect that the authors of the
Constitution had in  mind.  We must
all be aware that our audience consists
of environmental, industrial,  health,
trade, civic, and service groups; ethnic
minorities; rural and urban people;
young and old people, whose priorities
and values vary greatly. We must
strive to communicate what we know
openly and consistently, in such a way
that everyone receives in essence the
same message.  To do so, we  must
all understand that  what we communi-
cate, to whom we communicate it,
and how we communicate  it are inextri-
cably linked—and that accurate informa-
tion poorly communicated can be just
as misleading as inaccurate information
effectively communicated.
     Those within agencies who are
responsible for conducting research
and carrying out technical assistance,
enforcement, or other traditional "line"
responsibilities must learn that inform-
ing and involving the public is one
of the agency's major responsibilities,
and hence one of theirs. The alternative
is to play into the hands of those who
view the public as a vague, primitive
force, susceptible to infinite  manipula-
tion and deception—those who distort
issues, conceal facts, and  smooth over
all difficulties with superficial public
relations double talk.
     The  communications responsibilities
which face government agencies are
extremely challenging.  We cannot,
or should not, employ the  techniques
often used in commercial advertising
where very compelling psychological
legerdemain is placed at the service
of those who want the  consuming public
to see a particular thing in a  particular
preconceived manner.  On the other
hand, it does no good to conduct research
and carry out the many other activities

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which result in the development of
vital information and then wrap it
up in some dreary package which will
defeat the most  public-spirited citizens'
efforts to understand what the govern-
ment has done for them with their
tax monies.
    While government agencies must
avoid the  temptations of institutional
salesmanship, they must, nevertheless,
process the staggering amounts of
raw data which current research and
monitoring efforts and technical informa-
tion-gathering technology make accessi-
ble.  Moreover, they must make it
available through various media so
that as broad a spectrum of  the public
as possible can think, act, and vote
with the fullest possible awareness
of the issues confronting our society.
    Environmental agencies at all
levels of government have not succeeded
in fully meeting this challenge during
this critical decade of  environmental
improvement. Environmental program
managers, for a  variety of reasons,
are not yet convinced that seeking
public understanding and participation
is as important as anything else they
have to do.
    Fortunately, the Solid Waste Office
of the U.S. Environmental Protection
Agency has traditionally taken its
public information and participation
responsibilities more seriously than
most. It has, within  the limitations
of resources and an  uncertain climate,
operated in accordance with the princi-
ple that the general public has a right
to information and to a voice in the
program's affairs. This view was reflec-
ted in the development of the original
public participation guidelines, published
in January 1978, under the Resource
Conservation and Recovery Act of
1976 (RCRA), Public Law 94-580.

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    The Solid Waste Office was very
much aware of the fact that the public
participation provisions of environmental
laws have often amounted to little,
that they were almost never properly
combined  with public information activi-
ties, and that they seldom touched
the mainstream of agency research,
technical assistance, and regulatory
activities.
    The guidelines underscored the
need for developing public information
materials on the solid base of technical
information, so that public participation
could be meaningful. The original
guidelines lost something of their impact
and clarity as they became integrated
with the public participation regulations
under the  Clean Water and Water Quali-
ty Laws (Part 25 of Chapter 40 in the
Code of Federal Regulations), published
in February 1979.  Nevertheless, Part
25 does require that information and
education activities be an integral
part of other elements of public partici-
pation—meetings, conferences, workshops,
consultations with interested parties,
proper notification to the public, and
so forth.
     What these regulations actually
mean to programs being conducted
under RCRA  is that every agency that
receives EPA financial assistance will
be required to submit, as part  of its
grant application, a public participation
work plan which reflects how public
participation will be provided  for,
encouraged, and assisted.  All reasonable
costs of public participation identified
in an approved work plan will be eligible
for funding.  The public participation
requirements contained in Part 25
will be carried out in the individual
RCRA program regulations. These
are:

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    •   the State solid waste manage-
        ment plan guidelines under
        section 4002(b)
    •   the permit regulations for
        hazardous waste facilities
        under section 3005
    •   the State hazardous waste
        program/regulations under
        section 3006.

    There is, lam happy to say, substan-
tial evidence that the entire staff
of the Solid Waste Program of EPA
has itself taken public participation
seriously.  Since December 1976 over
150 workshops, public meetings, and
public hearings have been held through-
out the country on every major aspect
of the waste problem.  Literally thou-
sands of drafts have been distributed
to a wide spectrum of interested persons.
The information and views received
as a result of this effort have added
greatly to the quality of the regulations
and to the understanding of staff mem-
bers.
    Even though t;he U.S. EPA has
found it very challenging, indeed, to
get on with its role in implementing
RCRA, the Federal effort is likely
to be the easier part of the formidable
job mandated by the law.
    The more difficult, long-term
challenge faces State and local  govern-
ments. Moreover, the job is even more
urgent, more critical, and more difficult
than anyone was aware of when RCRA
was being developed and enacted.
Not until this year—when Love Canal
and similar disasters hit the headlines
and the public's demand for hazardous
waste control and, ironically, the con-
comitant public resistance to having
treatment and disposal sites established
anywhere near them became clear—
did we realize the full dimensions and
the intense pressures of the waste

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issue.  All of this, of course, has made
the necessity for meaningful public
awareness and participation even more
critical than we originally thought.
     Douglas Costle, Administrator
of the  U.S. EPA, commented on the
difficulties facing States last February
when he spoke before the National
Governors' Conference in Washington,
D.C. He said "Every State, I suggest,
needs to establish a process—consistent
with its own Constitution and laws--
for making decisions on the siting of
hazardous waste facilities. That process
must be one that the public will judge
environmentally sound and politically
fair. Above all, that process must
go beyond debate and produce  decisions."
This process, of course, will not work
without genuine public understanding
and participation.
     In light of all this, what is one
to say  when a State, in good faith,
holds a public meeting on an aspect
of hazardous waste management under
RCRA and almost nobody shows up
to participate?   Under such circum-
stances, what generally follows is that
many of those who work for the agency
involved complain to one another that
the public does  not really care, that
the public does  not know what it wants,
that the public  gets what it deserves,
and so  on.
     A  primary  purpose of public partici-
pation  regulations is to make it difficult
for public participation  efforts to elicit
this unfortunate and all too familiar
response.  Hence, the regulations require
that proper and timely efforts be made
to ensure that the public does  show
up for  the meetings and that they have
a reasonable opportunity to learn about
the issues to be discussed beforehand.
Indeed, proper regulations are  intended
to enable citizens to express themselves

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before, during, and after meetings
for the development and implementation
of important decisions and regulations
affecting their welfare.  But as we
are so  often reminded today—and there
is some truth in almost every cliche—
you cannot accomplish everything
through regulations. Proper attitudes
are also essential.  We must admit
that those of us who work for govern-
ment agencies, at all levels, operate
within  a historical tradition which
does not  yet include the proper attitude
toward public  involvement. This tradi-
tion does not yet encompass the full
scope of  our activities as they have
been redefined in recent environmental
and consumer  laws.
     Our  embryonic efforts to accommo-
date ourselves to the "new" public
participation requirements are often
made more difficult by widespread
distrust and cynicism. In actuality,
the resources available to agencies
are much lower than is widely under-
stood—particularly  in the environmental
area where there are so many long-
neglected, difficult problems in search
of quick and easy solutions.  Resources
needed to do the job usually trail  several
months, or years, behind newly minted
authorities and responsibilities.
     In this decade, environmental
managers have often found themselves
in the  same position David  would  have
been in if he had lost his sling before
confronting Goliath. In light  of the
constant need for more  reliable scientif-
ic information, more engineering  and
legal talent, and more days in each
week,  the relatively recent require-
ment for public participation gets
lost in  the shuffle, and if any effort
is made at all, it is usually little and
late.

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          The solid waste management prob-
     lem is perhaps even more illustrative
     of the need for sustained and successful
     efforts to involve the public than other
     environmental issues, which have en-
     joyed much earlier  national attention.
     The public has demanded air and water
     pollution control efforts.  And the
     public has paid,  directly or indirectly,
     for the controls placed on industries
     and municipalities.  Even though few
     people have been personally involved
     in these  issues, almost all segments
     of the public have been represented
     by a variety of public interest groups,
     which have influenced the development
     and implementation of legislation.
     But air and water pollution problems
     have not presented  anything quite
     comparable to the dilemmas faced
     by government officials charged with
     hazardous waste control responsibilities.
     These public servants must somehow
     meet the public expectations for protec-
     tion against a neglected and insidious
     problem  at the same time that the
     public seems to feel that these wastes
     must be  treated and disposed of on
     another  planet.  Without a high degree
     of public understanding and participation
     at the grassroots level, the solution
     will be elusive.
          We  must keep  in mind that the
     public is not accustomed to being asked
     for their views and  assistance in manag-
     ing solid wastes. If people fail to re-
     spond with alacrity to our first gentle
     call for help,  we should call again and
     again and again. This does not mean
     the government should resort to some
     of the high-pressure techniques used
     to sell commercial  products and services,
     although the need to follow through
     and properly explain the problems
     and the services to  be performed  is
     just as important in government as
     in private institutions.
10

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          Under current norms when an
     agency seeks public involvement, it
     finds an appropriate place to have
     the meeting. It puts out a press  release
     and announces the place, time, and
     purpose of the meeting. In addition,
     the agency might be able to place
     an ad in the local newspapers serving
     the area of the proposed meeting.
     It prepares materials for the meeting-
     some of which are likely to be very
     difficult for the public to understand—
     and  makes phone  calls—often only
     to those persons who have already
     demonstrated an interest in the issue,
     due  to limited resources.  Public meet-
     ings by government agencies are not
     regarded as particularly newsworthy
     events by the media, so the newspapers,
     TV,  and radio give the announcement
     minimal coverage, if any.  The meeting
     is held and very few people show up.
          But when a private institution
     wants to introduce a new service or
     product to the public—a new beverage,
     a new automobile, a new cosmetic,
     or whatever— the scenario is quite
     different.  National, regional,  State,
     and  local strategies are developed,
     redeveloped, revised, and again revised
     months or years in advance of the
     actual inauguration of the new service
     or product. Advertisements are  placed
     in all media, public relations events
     of various types are created and staged,
     and  a good number of other activities,
     generally falling under the rubric of
     advertising, public relations, and product
     acceptance, are carefully planned
     and  implemented. Moreover—-and
     this  is the principal point—these activi-
     ties  receive generous budgets because
     they are known to be just as vital as
     anything else that the company has
     done before, the research  and  develop-
     ment, engineering, production, and
     all the rest.
11

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          In government, quite the other
     way around, the Congress produces
     a very complex law, which can certainly
     be called a product even when not
     universally regarded as a service.
     This law affects everyone and many
     do not like it. It requires effort on
     the part of all levels of  government
     and the private sector as well.  It certain-
     ly is not as interesting as marketing
     a new beverage, automobile, cosmetic,
     or service that a private institution
     offers.  And as it turns out,  it is pri-
     marily the environmental managers
     at the various levels of government
     who have the unenviable job of getting
     everyone to accept the law, to under-
     stand and support it.  What's more,
     all of this must be successfully underway
     within a period of between 6 to 18
     months because  after that, the regula-
     tory provisions of the law are scheduled
     to take effect.
          In most instances the new law
     hits an environmental manager before
     staff and budgetary resources have
     caught up with the public sentiment
     that moved the Congress to pass the
     law in the first place. The manager
     and his or her staff were already very
     busy before the  law appeared.
     Regulatory agencies are busy developing,
     reviewing scientific data, making impor-
     tant decisions—and they live in an
     institutional climate in  which public
     information and participation activities
     have been regarded as an unimportant
     fringe that can be given minimal atten-
     tion after all the important  work  is
     done, which, of course,  is never.  The
     effect of all this, ironically, often
     leaves the agencies' staffs feeling
     a greater sense of guarded rapport
     with fellow engineers, technicians,
     lawyers, and others employed by the
     organizations that the Agency regulates
     rather than with the general public.
12

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     The citizen often ends up being regarded
     as an ignorant and bothersome third
     force, or fifth wheel, without whose
     interference all of us experts in govern-
     ment and industry could do the job
     much better.  We simply cannot go
     on this way.
          Public information and participation,
     and the necessary resources—both
     personnel and  budgetary—to make
     sure it is done properly, must be placed
     on the same level as other important
     tasks that environmental managers
     have always accepted as part of their
     key responsibilities. The complex
     and difficult laws we are increasingly
     called upon to implement and the  increas-
     ing need for real cooperation among
     Federal, State, regional, and local
     agencies cannot be accomplished with
     an appropriate degree of success without
     public involvement. Ensuring that
     the public is sufficiently well informed
     to be meaningfully involved in the
     public's environmental business is  just
     as important as anything else the govern-
     ment has to do.
          Since the beginning of the U.S.
     EPA, the Office of Solid Waste has
     devoted a significant portion of its
     resources to public information and
     participation programs. Even before
     the program was moved from the  Depart-
     ment of Health, Education, and Welfare
     to EPA, it devoted substantial effort
     to a publications program, serving
     both technical audiences and the general
     public.  Moreover, since 1972 the  program
     has offered annual grants to civic,
     scientific, environmental, consumer,
     labor, and other organizations to conduct
     public educational activities suited
     to their own constituencies on the
     full spectrum  of solid waste problems.
     These activities were enhanced with
     the program's  development and implemen-
13

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     tation of the public participation guide-
     lines under RCRA.  The objective of
     all this activity has been to help citizens
     understand the issues, which we all
     now know to be of critical importance
     to Federal, State, regional, and local
     efforts. The Office of Solid Waste
     public participation and education
     programs are being continued and are
     being supported, in a number of areas,
     by EPA's Office of Public Awareness.
         One major activity, titled Waste
     Alert!, has been initiated for the express
     purpose of involving citizens in planning
     and decision making at the State and
     local levels as they face the difficult
     problems of implementing RCRA now
     and in the years ahead.  Waste Alert!
     will extend over several years.  It is
     intended to involve citizens, ultimately,
     in all 50 states. While EPA is giving
     financial support and technical guidance
     to the program, it is fundamentally
     the responsibility of six eminent, national-
     ly known organizations—the American
     Public Health Association (as coordina-
     tor), the Environmental Action Founda-
     tion, the Technical Information Project,
     the National Wildlife Federation, the
     Izaak Walton League of America, and
     the League of Women Voters Education
     Fund. Waste Alert!  involves conducting
     3-day conferences around the country
     on issues related to the problems of
     abandoned waste sites, siting new facili-
     ties, implementing RCRA regulations,
     and other aspects of waste management.
         Ten regional conferences in the
     first 2 years will focus on identifying
     and training citizen leaders and reaching
     appropriate communications media;
     developing work plans for implementing
     RCRA at  the State level; planning
     for State conferences; and identifying
     State action groups and assisting them,
     if they wish, in holding State conferences.
     This is an unusually long-term public
14

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     information/participation program
     and one can only hope that the funding
     will continue so that it can achieve
     its objectives.  Its objectives will not
     be achieved, of course, unless the pro-
     gram moves from the Federal to the
     State to the local levels as time goes
     on. It is significant that EPA funding
     under RCRA's  Subtitle C hazardous
     waste program for the development
     of State public-interest coalitions
     and conferences to inform the public
     is intended to grow out of the Waste
     Alert! effort.
         The hazardous waste problem
     that we confront today underscores
     perhaps more certainly than any other
     environmental issue the importance
     of the public participation provisions
     which appear in recent Federal legisla-
     tion. The waste problem cannot be
     magically solved by science and technol-
     ogy, and government and industry alone
     cannot work out the means  of applying
     appropriate solutions. This has been
     underscored as we have learned we
     are dealing with two discrete issues:
     the management of wastes that are
     being generated today, or will be gener-
     ated in the future, and also with the
     management of wastes which have
     been improperly handled in  the past.
     It is not clear  which is the greater
     problem.
         What is clear is that the waste
     problem is too difficult to be solved
     by experts alone. It will not yield
     to shortsighted or lopsided attempts
     to place it into one discrete category
     or another. It  is a public health problem,
     a conservation problem, an  economic,
     a waste reduction, an urban, a rural,
     a social, and a scientific problem which
     will be solved  only if we do not  forget
     it is all of these things and more—and
     that only the public can properly cope
     with such complexities.
15

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EPA is charged by Congress to protect the Nation's land, air and water
systems. Under a mandate of national environmental laws focused on air
and water quality, solid waste management and the control of toxic
substances, pesticides, noise and radiation, the Agency strives to formulate
and implement actions which lead to a compatible balance between human
activities and the ability of natural systems to support and nurture life.
If you have suggestions, questions
or requests for further information, they
may be directed to your nearest
EPA Regional public information office.
 EPA Region! » JFK
 Federal Bldg. • Boston
 MA 02203 • Connec-
•ticut. Maine. Massachu-
 setts, New Hampshire,
 Rhode Island. Vermont •
 617-223-7223

 EPA Region 2 • 26
 Federal Plaza • New
 York NY 10007 • New
 Jersey. New York. Puer-
 to Rico. Virgin Islands •
 212-264-2515

 EPA Regions* 6th
 and Walnut Streets •
 Philadelphia PA 19106
 • Delaware. Maryland,
 Pennsylvania. Virginia.
 West Virginia, District of
 Columbia •
 215-597-4081
EPA Region 4 • 345
Courtland Street NE •
Atlanta GA 30308 •
Alabama. Georgia.
Florida. Mississippi.
North Carolina. South
Carolina. Tennessee.
Kentucky"
404-881-3004

EPA Region 6 • 230 S.
Dearborn • Chicago IL
60604 • Illinois. Indiana.
Ohio, Michigan, Wiscon-
sin, Minnesota *
312-353-2072

EPA Region 6 • 1201
Elm Street • Dallas TX
75270 * Arkansas. Loui-
siana, Oklahoma. Texas,
New Mexico •
214-767-2630
EPA Region 7 • 324
East 11th Street*
Kansas City MO
641O6 • Iowa. Kansas.
Missouri. Nebraska •
816-374-6201

EPA Region 8. 1860
Lincoln Street •
Denver CO 80295 • Col-
orado. Utah, Wyoming,
Montana. North Dakota.
South Dakota •
303-837-3878

EPA Regions* 215
Fremont Street • San
Francisco CA 94105 •
Arizona, California, Hawai
Nevada. Pacific Islands
• 415-556-1840

EPA Region 10* 1200
Sixth Avenue • Seattle
WA98101 • Alaska.
Idaho, Oregon. Washing-
ton • 206-442-1203
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