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.
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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.
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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
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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
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Dearborn • Chicago IL
60604 • Illinois. Indiana.
Ohio, Michigan, Wiscon-
sin, Minnesota *
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Elm Street • Dallas TX
75270 * Arkansas. Loui-
siana, Oklahoma. Texas,
New Mexico •
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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 •
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EPA Regions* 215
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Francisco CA 94105 •
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• 415-556-1840
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ton • 206-442-1203
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