EPA INDIAN COMMUNICATIONS PLAN
AND
F.Y. 1989 IMPLEMENTATION STRATEGY
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF EXTERNAL AFFAIRS
OFFICE OF FEDERAL ACTIVITIES
April 1989
-------
EPA INDIAN COMMUNICATIONS PLAN
AND
F.Y. 1989 IMPLEMENTATION STRATEGY
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF EXTERNAL AFFAIRS
OFFICE OF FEDERAL ACTIVITIES
April 1989
-------
TABLE OF CONTENTS
Executive Summary P. 1
Figure 1: Communications Flow P. 3
Figure 2: Methods of Communication P. 4
Figure 3: Structure of Communications P. 5
Figure 4: Duties of Key Communicators P. 6
Figure 5: Actions to be Taken P. 7
Introduction P. 9
Communications P. 10
Communicators P. 11
Listeners P. 14
Methods and Messages P. 15
Summary P. 21
References P. 23
F.Y. 1989 Implementation Strategy P. 24
EPA Indian Coordinators P. 26
-------
EXECUTIVE SUMMARY
EPA INDIAN COMMUNICATIONS PLAN
The Indian amendments contained in the reauthorized Safe Drinking Water Act
(SDWA), Clean Water Act (CWA) and Superfund Amendments and Reauthorization Act
(SARA) underscore the need for the Environmental Protection Agency (EPA) to
communicate directly with Indian governments. Therefore, it is important that
EPA maintain and expand its lines of communication with federally recognized
tribes and native Alaska villages.* Regular communication with Indian governments
and with intertribal organizations will be vital as EPA develops guidance for
these acts, and as it seeks Indian amendments to the remainder of its authorizing
legislation. Recent meetings with tribal governments sponsored by various EPA
national and regional offices have clearly indicated that Indian governments
expect EPA to develop and maintain a process of direct, regularized face-to-face
consultation with them as it implements environmental laws on Indian lands.
The attached plan analyzes EPA and tribal commmunication needs.
It should be noted that there is a clear difference of opinion between some
Indian governments and EPA concerning how these needs should be met. A
number of Indian groups want EPA to establish either an Office of Indian
Affairs or an Indian Desk as a primary point of communication with the Indian
community. EPA, on the other hand, prefers to communicate with Indian
governments through its regional offices and media programs in the same way
that it relates to state governments.
The goal of this plan is to establish a common ground and improve
communication with Indian governments by implementing a general approach to
EPA's Indian communications under the oversight of the Assistant Administrator
for External Affairs. This plan provides an overall framework for the
development and implementation of Indian communications by EPA
programs and offices. It calls for the use of a number of communication
methods on the headquarters and regional levels with the core method
being face-to-face communication as called for in the EPA Indian Policy
Implementation Guidance (1984:4, see figures 1 and 2). A separate
implementation strategy describes how this plan will be placed in motion
during FY 89.
In response to the requests of tribal governments for identifiable
points of contact within the EPA headquarters and regional program offices,
the plan describes how headquarters and regional Indian Work Group members and
Indian coordinators will communicate with tribes. The Work Group members will
provide technical assistance to tribes on both the headquarters and regional
levels. The coordinators will be the central points of contact for tribes within
EPA (see figures 3 and 4). They will refer tribal requests for technical assist-
ance to Work Group members in the regional and headquarters media program offices.
Latest Bureau of Indian Affairs statistics indicate that there are 312
federally-recognized Indian tribes in the 48 contiguous states. In
addition, there are 197 recognized village governments in Alaska.
There are approximately 280 parcels of land that are administratively
dealt with as having reservation status. Some reservations have more
than one tribe. In such cases the tribes usually participate in a
single tribal government.
-------
They will serve as resource persons for the tribes when communication
problems arise. And, they will work with the Agency communications
strategists to ensure that Indian tribes and groups are included in
Agency communications strategies, where appropriate.
This plan requires that nine actions be taken (see figure 5)
to facilitate communication between EPA and the Indian community.
Implementation of these will require a close budgeting of staff time,
travel, and other resources. However, it is important to recognize that
these resources are needed to satisfy both legislative mandates for tribal
consultation and the requirements of EPA Indian policy to work with tribes
on a government-to-government basis. While it is clear that a resource
base cannot be developed immediately, the Agency needs to establish a
baseline commitment to its Indian communication process over the next two
fiscal years.
A Presidential policy statement and subsequent Acts of Congress
have already led EPA to develop an Indian policy and promulgate regulations
for Indian participation in EPA programs. It is reasonable to assume that
further developments in this direction will, occur as EPA's relationship
with tribes expands. This communication plan suggests a relatively small
reallocation of resources to ensure that communication with tribes, native
Alaskan villages, and national and regional Indian organizations will be
maintained in an atmosphere that will promote maximum cooperation between
EPA and the Indian community as they pursue their mutual goal of environmental
quality on Indian lands.
-2-
-------
FIGURE 1
COMMUNICATIONS FLOW2
METHODS
COMMUNICATOR/LISTENER
E. P. A.
OFA, OPPE
HQ Media Programs
Regional Indian
Coordinators
Regional Media
Programs
MESSAGES
FEEDBACK
PRIMARY METHODS
1. FACE-TO-FACE
(CORE CHANNEL)
2. TELEPHONE
3. WRITTEN
SECONDARY METHODS
1. WDEO TAPE
2. NEWS MEDIA
MULTIPLE METHODS
1. WRITTEN/TELEPHONE
2. TELECONFERENCES
3. OTHER COMBINATIONS
MESSAGES
FEEDBACK
COMMUNICATOR/LISTENER
TRIBES,
ALASKA VILLAGES,
INTtR-TRIBAL
ORGANIZATIONS
model is based on Casagrande's communicat ions model of culture.
-3-
-------
FIGURE 2
Methods of Communication with Indian Groups
Primary:
1. Face-to-Faee Contact
A. Site visits by EPA staff to tribal facilities
B. On-site training and technical assistance to tribes
in reservation localities
1. Circuit Rider visits
2. Short-term training by EPA Institute Scholars
3. Intermediate-term training by the SEE (Senior
Environmental Employee) Program staff
C. Public forums for the Indian community at headquarters,
regional, and other meetings.
D. EPA Indian Work Group and other workgroup meetings
E. Visits by Indian leaders to EPA headquarters and regional
offices
2. Telephone
3. Written
A. Brief Announcements
B. Letters and Pamphlets
C. Detailed Documents
D. EPA Indian Announcements and EPA Journal
Secondary:
1. Video Tape
A. Special Programs Developed for Tribes
(1) Announcements
(2) Training Tapes
(3) Introductory Tapes Describing EPA Programs
B. General Distribution Materials
(i.e., Teleconference Tapes)
2. News Media
A. News Releases
B. Interviews
Mu 11 i p 1 e:
1. Written/Telephone
2. Teleconferences
3. Any other combination of the primary and or secondary
methods
-4-
-------
FIGURE 3
Structure of EPA Indian Program Communications
Indian Groups
Federally Recognized Tribes
Alaska Villages
National and Regional Indian
Organizations and Other
Interested Indian Groups
EPA Regional Offices
Regional Indian Coordinator
Regional Indian Work Group
Members
States
State Offices
State Environmental
Programs
EPA Headquarters
Headquarters Indian Coordinator
Headquarters Indian Work Group
Members
Headquarters Communications
Strategists
-5-
-------
FIGURE 4
DUTIES OF KEY COMMUNICATORS
REGIONAL LEVEL
INDIAN COORDINATOR
Initial Point of Contact
tribes in Region.
for
Communicates new developments
in EPA programs to tribes
in the Region.
Helps individual tribes develop
multi-media EPA/Tribal Agreements
and multi-media plans for the
management of reservation
environments. Is responsible
for assisting tribes when
problems in implementation
arise.
Coordinates SEE Program and EPA
Institute efforts in the region.
Directly communicates with
tribal counterparts regarding
the progress of these programs.
Advises all appropriate regional
staff of tribal concerns.
Works with Agency communication
strategists and reviews all
regional communication
for relevance to tribes in
the region.
MEDIA PROGRAM INDIAN WORK GROUP MEMBER
Oversees media program communication
with the tribes.
Develops program-specific
communication plan.
Consults with headquarters media program
Indian Work Group members and Work Group
members in other regions on their communica-
tion with tribes.
Advises appropriate regional media
program staff of tribal concerns.
Coordinates efforts with regional
Indian coordinator.
Works with Agency communication
strategists and reviews program
communication strategies for
relevance to Indians in the region.
Maintains day-to-day technical
communications with tribal counter-
parts regarding the development of
tribal media-specific management
capabilities as tribes seek to
implement their multi-media
environmental management plans.
Helps tribes solve media-specific
implementation problems. Helps
individual tribes develop media-
specific EPA/Tribal Agreements.
-6-
-------
HEADQUARTERS LEVEL
OFA INDIAN COORDINATOR
Initial EPA point of contact for
tribes.
Referrals made to programs & regions.
Provides consultation to EPA staff
on Indian issues, communications,
and the implementation and
development of Agency Indian
policy.
Communicates directly with tribes on
a variety of issues. Coordinates
these efforts with media program
Indian Work Group Members.
Provides consultation to regional
Indian coordinators and Work Group members
on their communications with tribes
and on Indian Policy implementation.
Oversees SEE Program and EPA
Institute Scholar Program efforts
transfer technology to tribes.
Works with Agency communication
strategists on the development
of communication strategies
and reviews all headquarters
communication strategies for
relevance to Indians.
Coordinates the efforts of
the Agency Indian Workgroup.
to
MEDIA PROGRAM INDIAN WORK GROUP MEMBER
Maintains day-to-day
communication with Regional
counterparts regarding the
development of tribal
media-specific management
capabilities. Relays
developments in media
program policies to
regional counterparts.
Coordinates communications
to tribes with HQ Indian
coordinator.
Advises media program staff
of tribal concerns and
problems in the development
of environmental management
capabilities.
Works with program communica-
tion strategists on the
development of communication
strategies and reviews all
program communication
strategies for relevance to
Indians.
-7-
-------
FIGURE 5
Summary of Actions to Be Taken
1. Establish regional and headquarters Media Program Indian Work Group members,
Have them develop and implement program-specific Indian communication plans,
Communication with tribes should be added to their performance standards.
2. Utilize the face-to-face communication method as the core method for
communications with the Indian community.
3. Reserve resources to ensure there are funds for communication with tribes
through travel, telephone contact, and written contact.
4. Continue developing "hands-on" approaches like the SEE, EPA Institute, and
Circuit Rider programs as means of communicating technical and managerial
skills to the Indian Community.
5. Update the master address list of Indian contacts within tribes, Alaska
villages, and Indian organizations on at least a yearly basis.
6. Offer courses in Indian culture and cross-cultural communication for
EPA headquarters and regional staff.
7. Periodically provide written updates for Indian governments on EPA Indian
activities.
8. Continue to send the EPA Journal free of charge to the tribes, Alaska
villages, and Indian organizations.
9. Consider development of a series of video-tapes to introduce the Indian
community to EPA programs.
-------
EPA INDIAN COMMUNICATIONS PLAN
INTRODUCTION:
The amended Clean Water Act (CWA), amended Safe Drinking Water Act
(SDWA), and Superfund Amendments and Reauthorization Act (SARA) require
the Environmental Protection Agency (EPA) to work directly with Indian
governments. All three acts allow for the treatment of Indian governments
as states under certain circumstances. This requires that EPA promulgate
regulations and/or guidance that determine how and when this will be
done. These acts also call for surveys to be conducted among Indian tribes
on specific issues. In addition, EPA must also implement the remainder of
its authorizing legislation on Indian lands. In order to do this, there
must be an increase in communication between EPA and the Indian community.
A number of tribes have recently stated that they desire that such
consultation be frequent, thorough, and "front end" in nature.
EPA's Indian program workload is increasing and Indian governments are
requesting more background communication with EPA management and staff in
order to implement federal environmental laws on reservations. Therefore,
it is important for EPA to expand upon the statement on Indian
communications in the EPA Indian Policy Implementation Guidance (1984:4) and
implement an overall plan for Agency communication with Indian governments
under the oversight of the Assistant Administrator for External Affairs
as part of the Agency communication process.
Much has been learned about communicating with tribes. A number of these
experiences have been positive. However, before this process of communication
proceeds further, it is important to consider what we have learned, capitalize on
the positive aspects, and institute general guidelines for communicating with
Indian governments and organizations.
This document describes the overall plan for regular consultation
and communication between EPA and the Indian community. It reviews EPA
experiences in working with Indians and relates these to general
principles of communication. The result is the creation of an EPA/Indian
communication system that will help meet the many and varied needs for
communication between EPA and the Indian community.
-9-
-------
COMMUNICATIONS:
Communicating technical material is never easy. Communicating it in a
cross-cultural environment adds to the difficulty by introducing the possibility
that the communicator and listener may not share the same cultural understandings
about what is being communicated or how it should be communicated. Edward Hall
(1959) has indicated how this can lead to miscommunication when Anglo-Americans
attempt to communicate with American Indians and other non-Western peoples.
Therefore, this plan takes a basic approach to the problem of communications.
It calls for training in cross-cultural communication for EPA staff who work
with Indians. In addition, it employs the communication model of culture
developed by Casagrande to structure EPA's communications with Indian
governments. The use of this model provides a neutral, cross-culturally
valid framework upon which a system of communications between EPA and the
Indian community can be built.
The communication model of culture views every communication act as being
composed of five elements: a communicator, a listener, a method of communication,
a message, and feedback. The communicator has a need to convey information.
The listener has a need to have that information, and may also have a need to
respond and provide feedback. They require a common method of communication
which is accessible, clear, and free of distraction. Finally, the message
must be sent and feedback must be provided in a mutually intelligible and
symbolically adequate language.
In communicating with Indian governments, EPA must be aware of these
elements and must seek to structure its communications with the Indian
community in a way that minimizes the risk of miscommunication. For example,
EPA must allow for sufficient feedback to prevent misunderstandings due to
differences in language or technological development between the.communicator
and listener.
In addition, EPA communicators must be aware of Indian customs and
communications practices so as not to introduce the kind of distractions
that can be generated when a communicator is not sensitive to the cultural
values and practices of the listener. With this in mind, it is possible to
use the communications model of culture to create an Agency-wide system for
communicating with Indian governments that minimizes the possibility for
both cross-cultural misunderstandings and also prevents confusion due to
a lack of standardization in the way that EPA communicates with tribes.
- 10 -
-------
COMMUNICATORS:
In communicating with Indian governments, the most important point to
remember is that there will frequently be two communicators: One of the most
common complaints that tribes have about federal agencies is that federal
employees speak a lot and listen very little. EPA has program goals and
legislative mandates about which tribes must be informed. However, EPA
also must recognize that many tribes have established their own goals for
environmental quality. As EPA explains its programs to tribes, they will
very li ely respond by stating their goals to EPA and by asking how EPA
can help achieve them.
This two-way communication is vital to the process of consultation. Many
tribes are unhappy that federal agencies relate to them through "briefings"
that are often given only after regulations and policies are written. The
tribes want the opportunity for face-to-face two-way discussions at the
"front end" of the policy and rule-making process, before firm positions
are taken. Therefore, adequate consultation with Indian governments during
rule-making is vital.
EPA COMMUNICATORS:
EPA is a diverse organization with many communication needs. There-
fore, there will be many EPA staff who will need to communicate with tribes on
the headquarters and regional levels. These will include Indian coordinators,
Indian Work Group members, Agency communication strategists, and others. Each
group of communicators will have its own specific role to play in the process
of communicating with triltes at the headquarters and regional levels.
At headquarters, the main focus of communication with the Indian
community will be in the area of policy development. The promulgation of
regulations, the development of guidance, the seeking of amendments to
authorizing legislation, and the development of interagency agreements and
programs represent the kinds of headquarters policy-level activities about
which Indian governments will need to be informed.
In order to get this information to the tribes, it is suggested that the
communication tasks be divided among a series of EPA communicators. On issues
where Agency policy requires formal communication strategies, the responsible
Agency communication strategists should take the lead in designing the
strategy. The strategists should be assisted by the headquarters Indian
coordinator and by the headquarters media program Indian Work Group member
of the affected media program. In cases where a formal communication
strategy is not needed, then the HQ Indian coordinator will take the lead
on multi-media issues and the media program Indian Work Group member will
take the lead when the material to be communicated is specific to one
particular media program.
-11-
-------
While headquarters staff will communicate to tribes primarily on
issues of national EPA policy, the burden of the day-to-day communication
with tribes in the areas of direct implementation and technical assistance
will occur at the regional level. Since there are not many communication
strategists at the regional level, it is expected that the bulk of communica-
ting with tribes will be conducted by the regional Indian coordinators and the'
regional media program Indian Work Group members. Again, the division of tasks
will involve the Indian coordinator as the communicator of general information
on mult-inedia issues and the media program Indian Work Group members as
communicators of program-specific information. In all cases the regional
Indian coordinator will be the initial point of contact for Indian tribes in
the region, and the person to whom tribes cone for assistance when attempts
at communications are not successful.
This plan distinguishes between Indian coordinators and media program
Indian Work Group members. It does so because of complaints from the Indian
community that EPA seems to lack a structure for dealing with tribes and has
instead, according to the tribes, appointed a confusingly large number of
Indian coordinators whose functions are not well-defined. This plan proposes
that the national and regional Indian coordinators be defined as the initial
points of contact for Indian governments within the Agency. Their function is
to represent the Agency as a whole to the Indian community, to relate to
national and regional Indian organizations, to establish relationships with a
variety of outside agencies, to work with tribes on the development of multi-
media tribal environmental management plans, to negotiate multi-media tribal/
EPA agreements, and to consult tribes on multi-media issues. In larger regions,
this is a broad full-time responsibility.
The media program Indian Work Group members serve cl media-specific
function. In most regions, these individuals work part-time on Indian issues.
On the national level they oversee Indian activities within the media program
and establish communication with tribes concerning media program policy issues.
On the regional level they represent the media pr.ograms to the Indian
governments by working with them in the areas of direct implementation and
technical assistance. The media program Indian Work Group members will be
appointed by program management and will be members of the headquarters or
regional Indian Work Groups.
TRIBAL COMMUNICATORS:
There will be many tribal communicators from the 312 federally recognized
tribes, 197 native Alaska villages, and the various and regional tribal
organizations. Various authorizing acts require a somewhat different relation-
ship between each of these entities and the media programs. SARA potentially
serves all Indians. CWA is relevant only to tribes living on reservation
lands. SDWA is somewhere in between. However, the main point is that there
are over 500 sources of Indian government input to EPA.
-12-
-------
With this number of Indian groups, the question of who speaks for
American Indians often arises. The answer is that all of the tribes and
Alaska villages are legal entities that exert various degrees of political
sovereignty. Therefore, when an environmental issue impacts a specific
tribe or village it is clear that, under the principle of the government-
to-government relationship, the tribe or village speaks for itself. It is
with national and regional issues that the difficult questions arise. Who
speaks for all Indians? There is not now and never has been one voice
for all Indians. Even major inter-tribal organizations have significant
groups of Indian supporters and opponents. Therefore none of them can be
said to represent an Indian consensus. EPA should seek the opinions of
several national and regional Indian organizations when considering issues
that affect tribes on a nationwide basis.
In addition, EPA staff may choose to discuss technical issues with
tribal staff in various tribal environmental programs. The Office of
Water did this with very positive results when it developed
guidance and regulations for the Safe Drinking Water Act and the Clean
Water Act. Office of Water staff have developed a list of names of tribal
staff who can be consulted on water issues. In addition, the Office of
Federal Activities (OFA) has developed a list of other tribal technical
staff who may be available for discussion of technical issues. Both of
these lists are maintained by the headquarters Indian coordinator and are
available to any EPA staff member who desires to use them.
-13-
-------
LISTENERS:
EPA LISTENERS:
Potential EPA listeners exist in programs at all levels of the
Agency. It is anticipated that many of the communications received from
tribes will initially be in the form of responses to inquiries from EPA.
However, as EPA increases its communication with the Indian community, tribes
will become more aware of EPA programs. It is therefore reasonable to expect
that the Indian community will increasingly initiate contacts with EPA. In
order to facilitate EPA's ability to deal with this expected influx of
requests for information, opinion, and decisions, identified points of
contact for the tribes need to be established within the regional
and the headquarters media programs. It was stated above that media program
Indian Work Group members need to be appointed within the regional and
headquarters media programs to serve as points of communication with tribes.
This network of Indian Work Group members will also respond to tribal
inquiries for specific types of assistance.
One further point needs to be raised here. Tribes working with other
agencies frequently relate to an "Indian Desk". Many tribes would like EPA
to establish such an office as their primary point of tribal contact. In
agencies that have single line-item Indian programs, this makes a great deal
of sense. However, EPA's programs are complex and are authorized by a number
of laws that have differing Indian provisions. Therefore tribes need to
directly contact the EPA staff members who deal with the specific media pro-
grams in which they are interested. A central point of communication with
the Agency as a whole already exists in the headquarters Indian coordinator.
INDIAN LISTENERS:
Although there.will be a variety of Indian listeners, the principle of
the government-to-government relationship makes it clear that most Indian
receivers of EPA communications will be tribal governments and their
environmental employees. Questions arise, however, as to whether every
EPA issue needs to communicated to every tribe and who within the tribes
needs to receive these communications.
With respect to the first question, it is clear that every tribe and every
native Alaskan village will not require information on the activities of every
EPA media program. Each authorizing lav/ is specific. Some of these laws only
apply to a portion of the over 500 Indian tribes, villages, and organizations.
Therefore, it will be possible to tailor communications. However, in order to
do this effectively, it will be important for someone within each media
program to develop a list of those tribes that are specifically affected by
developments within that program. This is where the role of the regional
and headquarters media program Indian Work Group member is important.
Over time, each of them will develop his or her own list of interested tribes
and these will be used as a source of input when program-specific Indian
communication plans are developed for each media program.
-14-
-------
The second question is who to contact. There are two sets of tribal
listeners who may have an interest in EPA programs. The first is composed
of the tribal chairmen. The second is composed of the employees of the
tribal departments that provide environmental management and health services.
Issues of policy should be addressed to the chairmen. Technical considerat-
ions are often best sent to the environmental and health agency managers.
The choice depends upon the nature of the message. Where the topic of
communication involves a problem that is shared by tribes and states, then
it is expected that there will also be communication with appropriate
people in state governments.
There are many, many tribes and villages that may need to be contacted.
It would be unfair to ask each Indian work group member or coordinator.to bear
the burden of developing a list of all potential Indian contacts. It would be
best for them to develop their lists from the central list that has been
developed by OFA. The program and regional staff can modify this list to
suit their needs and use those parts of it that are relevant to specific
topics. With respect to this issue, OFA is now providing media program
staff with a regularly-updated computerized list of addresses for a broad
variety of Indian and Indian-related environmental contacts.
METHODS AND MESSAGES
There are a number of methods (see figures 1 and 2) which EPA and Indians
can use to communicate. Choosing a method depends upon several factors.
These include: the nature of the message to be conveyed, the urgency of the
need for communication, and the availability of funding. Because methods
and messages are closely related, they will be discussed together.
PRIMARY METHODS:
There are three primary methods for communication between EPA and
tribes and Indian organizations. They are: face-to-face contact, written
communication, and telephone communication (see figures 1 and 2).
FACE-TO-FACE-CONTACT:
Even though it is expensive, the effectiveness of face-to-face
contact makes it the core element of the EPA/Indian communication system.
This method has the advantage of allowing for direct, auditory and visual
two-way communication. Issues communicated in face-to-face contacts are
subject to immediate feedback from the listener. This feedback can be
utilized to ensure that messages are understood and to immediately resolve
sensitive issues. This aspect of face-to-face communication makes it
especially useful for cross-cultural communications. Given this, it is
little wonder that tribes prefer it, and that the EPA Indian Policy
Implementation Guidance calls for its use.
-15-
-------
Because there are 312 federally-recognized tribes and 197 native Alaska
villages it is difficult for EPA staff to visit them all. However, there
are a number of communication settings and specific messages that justify
the time and expense involved in directly communicating on a face-to-face
basis.
The first such setting is the public forum. These are usually meetings
called by EPA when there is a specific need for consultation with a number
of tribes, villages, and/or Indian organizations. Public forums have been
used by EPA to deliver messages that update Indian people on statutory
amendments, regulations and guidance concerning specific environmental laws,
provide training on technical procedures, provide information on EPA Indian
pilot projects, and offer tribes an opportunity to comment on EPA policies
and programs. Such meetings are expensive for both EPA and the Indians,
since each group generally has to pay travel expenses for its own
participants. However, meetings do offer the best opportunity for clear and
concise communication and they can be time and cost effective if one considers
the amount of staff effort that would be used in trying to conduct extensive
two-way communication with a large number of tribes by either phone or mail.
Despite their expense, many tribes prefer these kinds of meetings and they
have stated that such meetings are especially important in the early stages
of policy and program development.
In order to minimize costs and increase efficiency, it is suggested that
such meetings be held in the regions and that a variety of issues be discussed
with tribes.at the same gathering. These meetings should be held in centralized
locations in Indian country where it will be easier for tribes to attend.
Because EPA usually calls these meetings and since EPA does not generally have
funding to pay for the tribes to attend, it is important that the meetings be
relatively infrequent, concentrate on substantive issues, and be broad-based
in nature.
Large meetings are not the only face-to-face settings that are useful.
Informal meetings with Indian organizations, and Indian discussants
at workgroup meetings were two settings that were mentioned above. In
addition, formal public hearings are also useful. These settings are best
employed when EPA is seeking messages from tribes concerning the decisions it
needs to make with respect to its Indian policy, the development of regulations
and guidance, and its day-to-day operations. These discussions help define
issues concerning possible EPA actions in Indian country and could help prevent
oversights of technical, cultural, or socio-economic considerations that might
adversely affect regulatory activities.
-16-
-------
The third face-to-face setting is one that is initiated primarily by
tribes. This is the office interview. Tribal officials and their
representatives frequently come to EPA offices to seek consultation regard-
ing tribal environmental programs and projects. Tribes also use these
meetings to convey a variety of messages to EPA and often provide valuable
feedback to EPA concerning its programs.
The fourth setting involves EPA and its representatives going out to
tribes for site visits. Usually they go to provide consultation on
tribal environmental planning and programs. This consultation is often
programmatic rather than technical. However, technical consultation is
also important. In Region 5 EPA funds a "circuit riding" technical
consultant through the Office of Water. TJiis person goes to the various
tribes in the region and provides technical assistance on various water
problems. Circuit riders are very popular with tribes. Several tribes
mentioned at a recent Region 5 conference that they desired more of
this kind of direct, face-to-face assistance. In seeking other ways of
providing direct, "hands-on" assistance to tribes EPA is currently using
the EPA Institute to provide on-site technical information to tribal
programs by having EPA employees work with tribal counterparts in Indian
communities. In addition EPA is providing funding for a demonstration
project that will place several Senior Environmental Employee Program (SEE)
employees in the regions to provide consultation and technical assistance to
tribes.
Face-to-face contact is both flexible and interactive. It is popular
with tribes. It has the greatest potential for overcoming misunderstanding
and problems of translation between English a"Yid traditional Indian languages
because it provides for immediate feedback. Therefore it is the core
communications method for EPA communications with tribes (see figures 1 and 2)
Effective communication with tribes will require EPA staff to spend consider-
able time in face-to-face interaction with tribes in Indian Country. This
will be especially "important for explaining regulatory issues and for
technology transfer. Both of these are vital to the development of tribal/
EPA agreements and tribal environmental planning. However, other channels
can provide vital support to this process of communication, and may increase
in importance over time as tribes gain environmental management expertise.
THE TELEPHONE:
The telephone is frequently used by EPA staff and tribes. It is
relatively inexpensive and rapid. However, it has its limitations. It
does not communicate details as well as does face-to-face interaction. For
example, when sending technical assistance messages the telephone cannot
provide the same range or quality of information as can hands-on, face-to-
face demonstrations. The telephone provides for the use of verbal symbols
only and cannot offer an opportunity for visual learning. Also telephone
communication is not appropriate for long, intensive messages. Communicators
-17-
-------
and listeners frequently tire after a relatively brief period of highly technical
conversation making it possible for distractions to decrease the effectiveness
of communication. For these reason-s, the telephone is best suited for relatively
brief discussions about subjects that have already been established through
other methods.
WRITING:
The third primary method of communication betwen EPA and the Indian
community is writing. It has a serious drawback in that it tends to be slow.
It also cannot be effectively used for simultaneous two-way communication.
Writing is a visual only method, and the visual input is usually limited to
symbols and schematics written on a piece of paper. Therefore, it
requires a considerable amount of redundancy (either in the text or in
re-reading) for the full message to be conveyed. Even then, the reader has
to use his or her imagination to completely conceptualize the ideas being
presented.
In spite of these problems, writing can be very useful. It is reasonably
inexpensive and is good for preliminary contacts through mass mailings. It
is also good for transmitting large quantities of detailed and/or complex
material such as regulations. This is because writing is permanent and can
be read and re-read in increments. Written materials can also be shared with
others whose expertise may provide additional interpretation.
With respect to .EPA/Indian relationships written communications are
effective in three areas. First, they serve an introductory function.
EPA cannot go out and meet with 3\2 tribes, 197 native Alaskan villages and
all intertribal organizations on all issues. When an issue arises and
the Indian community needs to be notified, a brief mailing will often be
sufficient. Such a letter can be used to introduce an issue, announce that
detailed information on the subject is available, and elicit tribal requests
for further information. In this way, written communications can be made to
work in an interactive manner, albeit a slow one.
A second area is the sending of summary information. While EPA has not
developed many program summaries, there are some notable exceptions such as
the EPA Indian activities report and the report on the Indian small water
system operators training program by ODW. These reports do much to concisely
explain EPA activities. Such summaries could be very helpful in the future
as a tool for introducing EPA programs to the Indian community.
-18-
-------
The third and final area is the sending of detailed information such as
regulations. This has already been explained. However, one further point
needs to be made. Regulations and guidance are complex. Often they are
written in legal terms that have highly technical meanings. Whenever EPA
sends such documents to tribes they should be preceded by executive
summaries that explain the regulation or guidance and the major issues
surrounding it in non-technical language.
A variety of EPA communicators will use written communications.
EPA communications strategists will send written communications when they
are called for in Agency communications strategies. Written communications
will also be used by the headquarters Indian coordinator and the
Indian Work Group members. Frequently it will be the Indian Work Group
members who will be closest to statutory and regulatory developments
and will therefore have the most current information. Appropriate
tribal listeners will be determined by the nature of the message sent.
The inclusion of tribal chairmen, tribal environmental managers, and other
tribal officials and staff in the mailing list has been very helpful here.
Finally, there is one other form of written communication. This is the
update. It might be very effective for the headquarters Indian coordinator
to develop a periodic summary of Agency developments to inform tribes about
specific, Indian-related events at EPA. In this way -the tribes, villages
and organizations could be kept current on EPA program events and deadlines.
This would supplement regular mail ings of the EPA Journal.
SECONDARY METHODS:
In addition to the three primary methods, there are two other methods
that have limited, but important, applications.
VIDEOTAPE:
Videotape has not yet been fully explored by EPA. Videotape messages are
both auditory and visual. Given this, videotape is often more effective than
writing for communicating technical information about scientific procedures.
In many cases, a procedure can be demonstrated in front of the camera,
allowing the viewer to get a first-hand view of how it is done. However,
videotape offers only one-way communication. Until interactive television
technology evolves further, videotaped programming will require tight scripting
and a certain amount of redundancy to ensure that the message comes through
clearly. In addition, videotapes are costly to produce, duplicate, and
distribute.
The most appropriate uses of videotape will be to transmit general
information (i.e., an introduction to the Clean Water Act and its
applicability to tribes) or to transmit information about specific technical
procedures that lend themselves to being recorded by the video camera. One
further application that EPA may look into involves the development of general
education tapes for the Indian public on environmental issues and practices.
These might be developed through contracts to Indian colleges.
-19-
-------
EPA already has a number of videotapes on environmental issues. These could
be viewed for applicability to Indian tribes and be made generally available.
In addition, EPA should consider including Indian issues, where applicable,
for all video tapes that it makes, to promote general awareness of the Indian
role in environmental regulation and stimulate coordination between state and
tribal governments.
NEWS MEDIA:
The news media offer an opportunity for broad, one-way communication.
The media are very complex. Therefore, the use of news media should focus
on subjects that are straightforward and not prone to misinterpretation.
There are a number of areas where news coverage of EPA activities can
be helpful. These concern events like the release of a report or a regulation
or the announcement of a cooperative effort with an Indian group, such as
the successful operation of a pilot project. The development of news releases
and/or the granting of interviews about such events provide EPA with an
opportunity to communicate with tribes and other groups about the progress
being made by EPA toward the achievement of the goals of its Indian policy.
To further this end, OFA has developed and distributed a list of both national
and regional news media that serve Indian country. The EPA Office of Public
Affairs is using this list to distribute all EPA news releases to the
Indian media.
MULTIPLE METHODS:
WRITTEN/TELEPHONE METHODS:
One solution to the limitations inherent in using all of the non-face-
to-face methods involves the use of multiple methods. Two varieties of such
communications are currently in use within EPA. The first involves the
combined use of written and telephone methods. EPA's authorizing legislation,
guidance, and regulations are often large, complex documents. The use of
the telephone to both announce that they are coming and to discuss them once
they have been received and read can provide important interpretive frame-
works and clarifications for tribal personnel. In addition, the use of the
telephone also provides EPA with more rapid, and often more effective,
feedback.
-20-
-------
TELECONFERENCES:
A second multiple method commmunication system employed by EPA is the
television/telephone teleconference. This system uses the phone to turn a
live television broadcast into a limited form of interactive television.
These teleconferences are popular and they do give a small number of people
a chance to interact with EPA officials on a set of predetermined topics.
However, they are expensive to produce and they are not appropriate for the
conduct of day-to-day business. They seem to be best suited for the
transmission of general information to large audiences.
OTHER MULTIPLE METHODS:
EPA does not have to limit itself to exclusive use of any of the
methods listed above. A variety of multi-channel communications can be
created. For example, a face-to-face/written method may be employed when
explaining written materials handed out at meetings. Such multi-method
uses can be very effective in tailoring communication to meet
the requirements of specific messages and specific communication
environments. Therefore a discussion of the methods to be employed
should be part of the development of each communication strategy.-
SUMMARY
This plan establishes a system of communication between EPA and the
rtore than 500 Indian tribes, Alaska native villages, and national/regional
Indian organizations. Implementation of this plan requires that EPA
enlarge its network of Indian coordinators and Indian Work Group members
within its headquarters and regional offices to convey EPA's many and varied
messages to the Indian community and to receive messages that Indian representa-
tives wish to convey to the Agency. The enlargement of this network further
requires that these coordinators and Work Group members have access to Agency
support in the form of training in cross-cultural communications and Indian
affairs, travel allotments, funds for maintaining computerized listings of
tribal officials, funds for data management activities, and funds for printing,
mailing, and telephone. Such support is critical to the establishment of
regular communication between EPA and the Indian community. It is necessary to
fully implement the national system of environmental protection on Indian
lands.
In addition to this program-based network of EPA Indian coordinators and
Work Group members, other methods of communicating with the Indian community are
necessary. These include working closely with intertribal organizations,
and the use of Indian discussants at regulation development workgroup and other
meetings. This kind of contact provides necessary feedback from the Indian
community and is an important part of the regulation development process.
- 21 -
-------
There has been an increased need for EPA to communicate with tribal
governments, Alaska native villages, and intertribal organizations as it has
become involved in the process of writing and promulgating regulations for the
Clean Water Act, the Safe Drinking Water Act, and the Superfund Amendments and
Reauthorization Act. This need will increase even further as the Agency joins
with tribes in the implementation of these Acts and seeks Indian amendments to
the remainder of its authorizing legislation. Therefore it is important
that EPA have a structured system of communications with the Indian community to
ensure that uniform, clear, and adequate communication exists between the Agency
and Indian governments in all regions of the nation.
- 22 -
-------
References:
Casagrande, J.B.
1968 Lectures on Language, Culture, and Society, University of Illinois,
Urbana.
EPA
1984 "Indian Policy Implementation Guidance", Memo from Alan L. Aim,
Deputy Administrator, Nov. 8, 1984
Hall, E.T.
1959 The Silent Language, New York: Doubleday.
-23-
-------
Implementation Strategy
for
EPA Indian Communications Plan
The EPA Indian Communications Plan establishes long-range goals for
communication with Indian governments. It will be implemented over a
period of years as the Agency acquires and dedicates increasing resources
for its regulatory activities on Indian lands. This implementation strategy
discusses the initial steps for setting the plan in motion in FY 89.
Goals for FY 89
The EPA Indian Communications Plan contains nine recommended actions.
Because they all require resources, they will be phased in over the next several
fiscal years. The following steps will be taken by the identified offices to
implement the recommended actions in FY 89:
1. Establish regional and headquarters Media Program Indian Work Group
members. Have them develop and implement program-specific Indian
communication plans. Communication with tribes should be added
to their performance standards. (Headquarters and Regional- Media Programs)
Regional and headquarters media program management will send the names
of staff members selected to serve on their respective Indian Work Groups
to the headquarters Indian Coordinator by 7-1-89. Performance standards
will be modified to reflect these work group assignments and v/orkload
models will be adjusted according to standard Agency procedures.
2. Utilize face-to-face communications as the core method of
communication with the Indian community. (All Agency Offices that
work with tribes)
Face-to-face communications will be utilized on a priority basis,
where practical.
3. Reserve resources to ensure there are funds for communications with
tribes through travel, telephone, and writing. (All Agency Offices
that work with tribes)
All offices that work with Indians will identify resources to be used
to communicate with tribes in their budgeting and workload models.
4. Continue developing "hands-on" approaches like the SEE, EPA Institute,
and Circuit Rider programs as a means of communicating technical and
managerial skills to the Indian community. (All Agency Offices that
work with tribes, HQ OFA/EPA Institute lead).
OFA and the EPA Institute will continue with the implementation of
the Institute Scholar program with the cooperation of the Media
Programs. Twenty new Institute Scholars will be trained. OFA
-24-
-------
will continue the SEE Program Demonstration Project. Media
Programs will continue to support the circuit riders currently
in place.
5. Update the master address list of Indian contacts with tribes,
Alaska villages, and Indian organizations on at least a yearly
basis. (HQ OFA lead, Media Program assistance)
Names and addresses of contacts within tribes will be forwarded
to the Headquarters Indian Coordinator for inclusion in the
master list.
6. Offer courses in Indian culture and cross-cultural communications
for EPA headquarters and regional staff. (OFA, EPA Institute,
Executive Resources Program, Regions)
A course for SES employees will be held at headquarters. In addition,
a course for Agency headquarters staff will also be held. Regional
activities will also be arranged.
7. Periodically provide written updates for Indian governments on EPA
Indian activities. (Headquarters OFA)
Updates will be produced three or four times per year by the OFA
Indian Coordinator.
8. Continue to send the EPA Journal free of charge to tribes, Alaska
Villages, and Indian Organizations. (Office of Public Affairs)
The Journal will continue to be sent as it is published.
9. Consider the development of a series of video tapes to introduce
the Indian community to EPA programs.
Reserved for future fiscal years.
Flexibility
The EPA Indian Communications plan is a basic communications system
by which EPA can relate to Indian governments. It is understood that not
all regions and media programs are alike. Therefore, implementation of
the plan must allow for differences in the communications needs of the
regional and media program offices. For example: Region 5 is employing
state Indian liaisons who increase face-to-face contact and technology
transfer through circuit riding. Region 8 is considering the development
of separate communications strategies for each tribe, depending upon their
communication needs.
Both modifications enhance the ability of these regions to communicate
with Indian governments. Such modifications will be necessary and are, in
fact, expected as the amount of contact between EPA offices and Indian governments
increases. As long as the role of the Indian coordinator as the central point
of contact with the Indian community is preserved at headquarters and at the regions,
and as long as the headquarters and regional Indian Work Group members are appointed
to perform their media-specific role in communications with the tribes, then such
modifications to meet regional and program needs are clearly in order.
-25-
-------
EPA REGIONAL INDIAN WORK GROUP COORDINATORS
ANNE FENN
INDIAN COORDINATOR
EPA REGION I .(PAG 2300)
JFK FEDERAL BUILDING
BOSTON MA 02203
617-565- 3395
FTS-8-835-3395
ROBERT HARGROVE
INDIAN COORDINATOR
EPA REGION II (2PM-E1)
26 FEDERAL PLAZA
NEW YORK NY 10278
212-264-1892
FTS-8-264-1892
ARTHUR LINTON
INDIAN COORDINATOR
EPA REGION IV (EAB-4)
345 COURTLAND STREET NE
ATLANTA GA 30365
404-881-3776
FTS-8-257-3776
CASEYAMBUTAS
INDIAN COORDINATOR
EPA REGION V (5ME14)
230 SOUTH DEARBORN ST
CHICAGO IL 60604
312-353-1394
FTS-8-353-1394
ERNEST WOODS
INDIAN COORDINATOR
EPA REGION VI (6E-FF)
1445 ROSS AVENUE
DALLAS TX 75202
214-655-2260
FTS-8-255-2260
MICHAEL BRONOWSKI
INDIAN COORDINATOR
EPA REGION VII
762 MINNESOTA AVENUE
KANSAS CIT* KS 66101
913-236-2823-
FTS-8-757-2823
SADEEHOSKE
INDIAN COORDINATOR
EPA REGION VIII (80EA)
999 18TH STREET
DENVER CO 80202
303-.294-7596
FTS-8- 564-7596
ROCCENA LAWATCH
INDIAN COORDINATOR
EPA REGION IX (E-4)
215 FREMONT STREET
SAN FRANCISCO CA 94105
415-974-8323
FTS-8-454-8323
GRETCHEN HAYSLIP
INDIAN COORDINATOR
EPA REGION X
1200 SIXTH AVENUE
SEATTLE WA 98101
206-442-8512
FTS-8-399-8512
MARTIN D. TOPPER. Ph.D.
NATIONAL INDIAN
PROGRAM COORDINATOR
U.S. EPA
401 M STREET SW
WASHINGTON, DC 20460
202-382-7063
FTS-8-382-7063
-26-
------- |