Opinion [1]: Public Participation by the US EPA [2]

Posted by : BillA on Mar 24, 2008 - 07:10 PM
environmentaltopics [3]
By Bill Arnold

Source: USEPA website (www.epa.gov)
in search box enter: RCRA public participation.
EPA uses the term “public participation” to denote the activities where permitting agencies (DEC/DOH) and permittees (facility/FMC):

Public participation is a dialogue.Reasons why:State agencies can be more restrictive but cannot be less restrictive than EPA regulations.The Public Participation TriangleA vital and successful public participation program requires a dialogue, not amonologue.Information must flow in loops between any two stakeholder groups.The regulators should not just release information to the facility owner/operator, who passes it to the community, who then contacts the regulators. The regulator should make the information available to everyoneand ask for feedback.Each corner of the triangle must keep the two-way conversation going with thetwo remaining corners.Agencies Public Participation PlanThe public participation plan is the agency’s schedule and strategy for public participation. The agency should draft a plan addressing public participation activities throughout the process.To identify activities for the public participation program, the agency should go through the following steps:1. List the major community issues and concerns.2. List the community characteristics that will have a bearing o­n how you address these issues.3. List the activities that will address the community’s concerns during the permitting process and, if applicable, corrective action.Once the agency has outlined activities for the facility, it should put together astrategy for implementing the activities which include:Agencies Formal Participation PlanEPA recommends a formal plan contain the following sections:- executive summary- introduction/overview- facility history- the RCRA action taking place- summary of community interviews, outlining concerns- a description of any early consultation (e.g., interviews with groupleaders) that led to development of the plan- a list of the major issues likely to emerge during the process- an estimation of the level of public interest likely to be generated bythe decision under consideration- public participation activities and schedule- a list of the agencies, groups, and key individuals most likely to beinterested in the process- a list of key contacts- information o­n meeting and repository locations, where applicable.Establishing Trust with the Community1. Remember the factors that are necessary for establishing trust --consistency, competence, care, and honor.2. Encourage meaningful involvement by other stakeholders.3. Pay attention to process.4. Explain the process and eliminate any mystery.5. Be forthcoming with information and involve the public from the outset.6. Focus o­n building trust as well as generating good data.7. Follow up. Get back to people. Fulfill your obligations.8. Make o­nly promises that you can keep.9. Provide information that meets people’s needs.10. Get the facts straight.11. Coordinate within your organization.12. Don’t give mixed messages.13. Listen to what other stakeholders are telling you.14. Enlist the help of organizations that have credibility with communities.15. Avoid secret meetings.Stakeholders (Citizens)Is It Working?The following are indicators that a public participation program is working:Another Item:On February 11, 1994, the President issued Executive Order 12898, directing federal agencies to identify and address the environmental concerns and issues of minority and low-income communities. In an effort to make environmental justice an integral part of the way we do business, the Agency issued a policy directive, in September 1994 (OSWER 9200.3-17), that requires all future EPA's Office of Solid Waste and Emergency Response (OSWER) policy and guidance documents to consider environmental justice issues.Recommendations
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