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What steps can EPA take to ensure that technical assistance to communities serves the needs of the whole community and not just a small group?

2010 October 8

EPA is always seeking to improve the process we use to provide communities with technical assistance. This assistance often comes in the form of grant money to help a community affected by sites contaminated with hazardous waste hire independent technical advisors to interpret information about that site. EPA provides this assistance in order to help communities better understand and address community environmental issues and concerns.

Editor's Note: The opinions expressed in Greenversations are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

22 Responses leave one →
  1. Oliver Paladin of permalink
    October 8, 2010

    What if the community hires an incompetent technical “expert”?

  2. Bob Shatten of Boreal Renewable Energy Development permalink
    October 8, 2010

    The whole community can be served by redeveloping hazardous waste sites to include and incorporate renewable energy projects; This will assure sustainability of future remedies and minimize pollution from traditional forms of electricity generation that otherwise may be utilized to power remedies.

  3. Ed Putnam of NJDEP permalink
    October 8, 2010

    At most superfund sites you will only have a small group that will stay engaged over the long haul. That will ussually be the group that requests the assisitance. Depending on when in the process the Technical Assistance is requested somewhat dictates how to then involve the larger community.
    Generally the expert that is giving the assistance should hold open public meetings separate from EPA but parrallel to EPA’s public meetings and local offical breifings. If it’s at the ROD stage, then EPA should assist in advertising those meetings. Then having the expert introduce themselves at EPA’s meeting, and annouce when the separate “locals” only meeting will be help involve a larger group that only comes out at ROD time. Haveing the municipality “spead the word” through their normal means of communication could help draw in more people.

  4. Amanda of permalink
    October 8, 2010

    I’m going to have to take this to a simple step backwards. Answering the phones! I’ve been trying to contact someone in my regional EPA and keep getting a looped recording or a recording telling me to call another number. Once I can get past that – then further technical assistance may be required.

  5. Ramona Huckstep of Missouri Department of Natural Resources permalink
    October 8, 2010

    I believe it would be helpful that when information is presented to the small group that the community as a whole have the opportunity to see it either on the web or posted to a local cable station or on a DVD provided to the local governments. Consider providing technical assistance workshops at the local universities or colleges and invite local school teachers and business people. Have partners within the community that can disseminate information from the local or state level (i.e. the environmentally focused agencies can give out that type of information when asked). I believe that at times the grant process can be cumbersome and difficult for community members who just want information not a long-term committment to a site. The money might be better spent providng staff who can go to the community or partnering with local and state agencies to provide staff to assist the citizenry with their quesitons and concerns. Thank you for the opportunity to provide input.

  6. John Schweizer of T3W Business Solutions, Inc. permalink
    October 8, 2010

    Oliver Paladin has struck on a key issue regarding how the EPA programs that provide technical assistance can benefit the largest possible local community. It is extremely important for Technical Advisors (TAs), which is the term used to define the technical experts hired by communities under EPA programs, to have solid experience and excellent credentials in all the technical areas that arise during a hazardous waste site investigation and cleanup. These include communication skills, and being able to work with diverse communities. However, important as these technical competencies are in order that a TA have the confidence not to be the servant of some narrow interest, integrity “competencies” are even more important. These include impartiality, intellectual honesty, and independence. If the TA is not of sufficient quality, the best way for the EPA to ensure that the technical assistance program serves the whole community is assist the community to replace the TA.

    An important way for the EPA to ensure that technical assistance to communities serves the needs of the whole community and not just a small group is to evaluate TA performance. TA performance should be evaluated by the community and the EPA working together. In my view, this evaluation can best be done by establishment of a Community Action Group (CAG) that consists of whoever shows up to at least one meeting or event, and the EPA’s Community Involvement Coordinator (CIC). There are several questions the CAG and the CIC can ask in evaluating the TA:
    o Does the TA demonstrate that the TA’s views and opinions do not necessarily represent those of EPA?
    o If the TA has been hired by a non-profit organization under a Technical Assistance Grant (TAG), does the TA demonstrate that the TA’s views and opinions do not necessarily represent those of the non-profit?
    o Does the TA demonstrate expertise in the technical and regulatory issues at the site, and enlist the support of other technical experts when needed?
    o Does the TA demonstrate the desire to work with the community and the EPA to develop an optimum project?
    o Is the TA effective in impartially communicating the facts to the community?
    o Does the TA’s views remain independent and impartial (both pro and con) with respect to non-community advocacy groups?
    o Does the TA’s review of EPA data and documents demonstrate technical expertise and independent thought in all the subjects that must be reviewed and reported to the community?
    o Does the TA cling to an incorrect view, or modify her/his view when the data justify modification?
    o Does the TA effectively assist a diverse community to express its views? An extremely important function of TA providers is to enhance the ability of diverse community members to speak for themselves. This benefits EPA because this assistance allows the public to more substantively contribute to the decision-making processes at sites.
    o Does the TA listen effectively so that the community’s concerns are accurately communicated to EPA, and so that EPA can address such concerns?

    Another thing the EPA can do to ensure that the widest possible community assistance is provided is to ensure that communities are aware that there is another program besides the TAG program. There is also a Technical Assistance Services for Communities (TASC) program. Unlike the TAG program, the TASC program is funded directly by the EPA instead of through a non-profit organization. Having been a TA in both programs, I have become aware of several issues regarding these two programs during the course of my tenure as TA at the AMCO Chemical Superfund site in Oakland, California:

    The community was definitely not aware of the various means available for the EPA to provide technical assistance until recently, when the TAG was rescinded from the former grantee. At that time the project CIC made everybody aware, including me, of the TASC program.

    In the very beginning of EPA activity at the site, over a decade ago, I do not believe that the community was even aware of the TAG program. I think this was the genesis of the biggest issue that I have observed, lack of trust of the EPA. Over a decade ago (1997) the EPA installed a dual-phase extraction (DPE) system with an incinerator for air pollution abatement. The system was installed as an emergency response effort by the EPA. The community felt that they were being treated as guinea pigs because of the potential for dioxin emissions from the incinerator, and ultimately prevailed in getting this emergency response measure shut down and removed in 1998. If there had been a TA in place to properly explain the risks to the community, and to communicate the community’s concerns to the EPA, I think that the adversarial relationship that grew between the community and the E PA as a result of this episode could have been avoided. The lack of an intermediary with a sound technical background allowed non-technical groups to become the community advocates, and start to affect decision making in an adverse way that created lack of trust of the EPA and ultimately wasted public money.

    The trust issue arose again when the TASC was put in place to replace the TAG when the grant was rescinded from the grantee. The prime contractor to the EPA for the Region 9 TASC program was immediately suspected of being an apologist for the EPA. However the community had experienced my work under the TAG and trusted me to be honest; the TASC was accepted and my work as TA resumed.

    I think the TAG program partially mitigates the trust issue by being more independent of the EPA, but has the disadvantage of having less control over the quality of the experts. For a time, approximately two years ago, the former executive director of the TAG grantee appeared to be desirous of replacing me with a personal friend of his. I did not believe this personal friend to be qualified to provide TA services. I think the TASC program is much better suited to promote TA professionalism, because the TAs are selected by qualified professionals instead of the non-profit. At the end of the day, I think that sound advice from experienced, honest professionals goes the furthest to dissolve the trust issue, keep politically-motivated non-technical advocates from becoming the dominant voice, and thereby reduces the cost and wasted effort on projects. I also think that having a TASC-screened qualified professional review the EPA documents assists the EPA to produce a more technically sound, more efficient, and less costly remediation product.

    A case in point regarding how professionalism benefits all parties is this: my (fairly unique) past experience managing a treatability laboratory and a mobile hazardous waste treatment division of a national firm, allows me to assist the EPA (through the document review process) to improve the chances of success of a lead soil treatment project that is being implemented by the EPA’s Emergency Response group in the residential areas around the AMCO site. The local community is very environmentally aware, and supportive of this project because it is sustainable. If the project is successful, it may benefit other urban residential communities across the nation, which the local community sees as a great “plus.”

    Sound professionalism in the TA role also helps keep all the stakeholders working together toward a solution, and helps prevent the divisiveness that can arise in diverse communities. Politically-motivated nontechnical groups, even if they come from outside the community, are essentially stakeholders and should be heard. However, these groups can be very detrimental to the interests of the larger community if they dominate the conversation. In my experience, impartial communication of the technical facts by a qualified expert goes a long way to preventing one stakeholder or another from dominating, and ensuring that technical assistance benefits the largest possible community.

    I have also experienced financial issues associated with the technical assistance programs. I was not paid for my work for nearly two years by the former AMCO site TAG grantee. I believe this was because my technical opinions diverged from views that would have supported the grantee’s agenda. In order to continue to serve the larger community, I had to work pro-bono. Under the TAG program, the EPA has no control of the contracting practices of the grantee, and can only apply indirect pressure when problems arise. Ultimately I was paid for my work under the TAG, but it took a long time and only after the EPA threatened to sue the grantee. The more standardized government contracting procedures in the TASC program are far less risky for the TA, and therefore far more preferable, in my opinion. I also think that working out a meaningful TA work plan that benefits all parties is more easily developed with other professionals in the TASC program than with a non-profit in the TAG program. However, the TASC program seems to have greater funding constraints. The bottom line is that I believe the TASC program to be more supportive of the EPA’s objective to ensure that technical assistance to communities serves the needs of the whole community and not just a small group.

    Thank you for the opportunity to give you my input, and I hope these comments and observations are helpful.
    Respectfully,
    John W. Schweizer, P.E.
    TA, AMCO Chemical Superfund Site

  7. J. M. Ensminger of Camp Lejeune Community Assistance Panel permalink
    October 8, 2010

    The EPA should consider forming community assistance panels (CAP) made up of a diverse cross section of the effected community. That way the CAP members could attend meetings with EPA officials and then disseminate the information to the community members who are unable to attend meetings. This way the community is given an active role and it empowers the people who are most likely to be effected by the contamination.

  8. Sarah Schwemin of WildLaw Staff Attorney permalink
    October 10, 2010

    If a TAG grant is awarded to a specific community organization, the EPA should be very careful to make sure they are not maginalizing or ignoring other community members/groups. I have experienced a situation where a certain community group received the TAG grant and that community group is always informed of meetings, deadlines, etc., but another large group in the community (a group that represents the community most affected by the contamination) is left receiving information second hand or not at all. I do not believe there should be any sort of preference for comments from the TAG group over comments from other groups. When the EPA engages in this sort of preferential activity, it gives the appearance of the TAG advisor and associated group as the “teacher’s pet” and the other groups as the problem children. Not only does this make the other community groups distrustful of the EPA, it creates fissures in the community itself, turning community members against each other instead of uniting to serve a common purpose. If it is not the EPA’s purpose to divide and conquer and they genuinely desire active participation from an entire community, they must be mindful of their actions and ensure that they are casting a wide enough net to engage all affected individuals.

  9. Laura Olah of Citizens for Safe Water Around Badger permalink
    October 11, 2010

    Above all, decision-making bodies must be selected in a democratic open process and its members must be trully representative of the diversity of the affected community. This requires being brave enough to invite and engage contrary and minority opinions. With such credibility, good communications and outreach will follow.

  10. Suzanne Wells of EPA permalink
    October 14, 2010

    Amanda,

    Please let us know which regional office you are trying to contact, and we will be sure someone gets in touch with you.

    Suzanne Wells

  11. Susan Sinclair of T.O.X.I.C. Inc, Tewskbury MA permalink
    October 14, 2010

    I agree that community assitance panels would be helpful. As stated above, over the long haul on most of these Superfund sites, community members that were once very active tend to lose interest. There is usually only a handful of people that stay totally involved start to finish on any of these sites because it does take so many years to accomplish the goal of clean up. It is also important for the TAG recipients to involve your local newspapers, TV stations and political representation. I feel that has been key in our community for involvement and action.

  12. Susan Sinclair of T.O.X.I.C. Inc Tewksbury MA permalink
    October 14, 2010

    One thing I think would be helpful to TAG grant recipients would be the ability to share your knowledge with other community groups that are just getting involved in a grant or that are considering applying. I went to an EPA sponsored seminar in Albeque New Mexico with TAG recipients from all over the country and I would have to say that I gained so much knowlege from others present. It was so good to have people to learn from and to share with the knowledge and experiences that we all have in common. It would be great to have some type of communication between us all. I am not sure how to make it happen. I know we cannot have meetings or gatherings like I went to all the time, but, maybe by email or mailings the EPA could help put groups in touch with one another wih similar sites to help each other out. I spent countless hours educating myself and alot of trial and error to learn and grow with my site and learn the proper way to communicate with the EPA and others about my concerns and the concerns of the community. The biggest complaint from the community members is that it appears nothing is happening. Unfortunetly your caught between a rock and a hard place. If you hold community meetings too often people feel your wasting their time but if you don’t keep your site in the forefont people fel that nothing is going on. This is whe media and local polititions can be helpful in keeping your site in the public eye. Giving updates threw your local media when a meeting is not necessary but information can be shared to ensure that the community knows that the site has been forgotten.

  13. Laurie Nehring of People of Ayer Concerned About the Environment permalink
    October 16, 2010

    The TAG support from EPA is absolutely essential for us to have sustain our commmittment of the last 14 years to oversee the remediation of our superfund sites. Admittedly, we started with a much larger group, and now have only 2 dedicated local citizens who regularly attend RAB meetings, along with our TA. It’s been a very long haul. EPA could make the process of volunteering our time and dedication to the project less stressful by reducing the reporting requirements and red tape. We spend extensive time writing up reports that ‘prove’ we did something. This is duplicative effort, since it’s all detailed in the invoices we send to EPA each month.

    I’d also like to see measures taken to support the local volunteers more, with the ability to spend grant money on things that could increase our visibility and make our meetings something to look forward to. Like FOOD! It is a known fact that good food & coffee brings adults to evening or Sat. morning meetings ~ allow us to use a small portion of the grant funds to offer FOOD or bring in other FUN speakers to promote the organization I volunteer for, and then we can get folks to make larger and more serious committments!

  14. David Roach of mo' better food permalink
    October 17, 2010

    First of all, I believe we must step one step backwards to define what the word “community” means. In the case of EPA, I believe they would define it as whomever is affected by the hazardous waste they are trying to clean up. If this definition is close to being accurate, it opens up a variety of methods to inform those residents. i.e, newsletter, door-to-door, website, etc. The problem with the above methods in these neighborhoods conducted by EPA and often consultants is that rarely do they understand the dynamics of the community. The community is rarely accustomed to the above methods. For example, in marketing events, i’ve heard it takes almost 10 times of the same message to move someone to attend. Thus, if EPA publishes a black and white newsletter, one time, I doubt EPA will receive the numbers of attendees they seek. Which leads me to my definition of what a community is, and how EPA can improve its process of outreach. EPA should partner with a number of organizations ALREADY in the community, especially the local high schools, colleges. They should become a sponsor of their publications, websites, and constantly offer job/ training opportunities for residents in the various regions they operate. EPA should purchase soil and lead testing equipment for students in the community to better understand the impacts of both. This process will enable EPA to promote future scientist from these neighborhoods as well as the outreach experts the community needs for its protection. This method will not be successful overnight, but once the system is in place, it should last for generations. If EPA continues the way it has, various individuals/organizations will come and go with very little success. In addition to the EPA, various Federal,State, and County organizations should pool their resources together, to support these communities ability to improve their communication for the generations to come.

  15. Brian Stern of NH TAG Force permalink
    October 18, 2010

    We do our best to hold public meetings and involve the community. However, the EPA should realize that the non-profit receiving the TAG grant is presumably working on behalf of the public interst/community. It should not be a numbers game of how many people are involved. It is usually a few interested persons who carry the weight of any organization.

    As to a specific suggestion: the EPA website for any particualr site should have an easy to use index of documents on record and link to those documents. There is an enormous amount of information. The documents should be indexed by date issued/submitted. A list of documents without some sort of index, at least by date, is not as useful to the public.

  16. Pam Leonard of none permalink
    October 18, 2010

    My property lies within the proposed Kinder Morgan gas line. I do not want this on (preferbly not anywhere near) my property. Reading in the Mt. Vernon News Oct.7, it states: “the route has been adjusted (by ODNR and Ohio EPA) many times to avoid several potentially sensitive environmental areas. Well, I consider my organic farm a sensitive area. Why should we have to hire a lawyer to fight this? It is our property and we should have the absolute say in this matter.

  17. Lenny Siegel of Center for Public Environmental Oversight permalink
    October 28, 2010

    Anthropologist Margaret Mead once observed, “Never doubt that a small group of thoughtful, committed citizens can change the world. Indeed, it is the only thing that ever has.” There is nothing wrong with providing technical assistance to a small group – that is, a group defined by its environmental advocacy or because it represents the people most impacted by an environmental condition.

    But EPA can encourage such small groups to both represent and provide information to the larger community. Some of the tools already exist: EPA requires that interested parties work together to apply for technical assistance grants. It asks technical assistance recipients to report how they communicate with the public at large. And it seeks broad representation when it creates or helps establish community advisory groups.

    But the key element in encouraging small activist groups to represent the interests of their entire communities is for activists to realize that they will not be effective unless they have broad local support. That support can be manifested through turnout at public meetings, petitions, newspaper editorials, resolutions by local governments, etc.

    In my experience, neither regulatory agencies nor responsible parties listen to small activist groups simply because they have access to hired-gun experts. Such groups influence decisions when they offer sensible recommendations that help them demonstrate that they speak for the community as a whole, or at least a broad segment of those paying attention. Technical assistance can help small groups speak for their communities, but only when they listen to their communities.

  18. peter strauss of pm strauss & associates permalink
    October 29, 2010

    As a long time technical advisor (TA) to communities, I have a few suggestions and best practices that I would like to share.

    First, and this may be obvious to many, technical assistance is most valuable at the beginning of the process: that is, during the investigation and feasibility study leading up to development of the proposed plan. This affords communities to be fully informed when they have a chance to make a significant difference in the remediation plan. Often this does not occur because a qualified non-profit is not available or does not come forward. EPA should consider granting technical assistance on a more limited basis (than the TAG) to community groups, or in lieu of that, organizing Community Advisory Groups (CAGs) and granting them some independent technical assistance. This may be similar to the TAPP program whereby the Dept. of Defense provided technical assistance to Restoration Advisory Boards.

    Having said that, it is also essential to create meaningful opportunities for community involvement during and after remediation. My experience has been that this is vitally important, but requires less money than the remedial planning phase.

    Second, no matter what size the group with the grant, it is their obligation to communicate the TA’s finding, analysis and comments to a broader community. In one case where I am the TA, the organization has a monthly newsletter and issues that I bring up are discussed there. In another case, the relatively small organization has put together a Community Advisory Board, which is briefed on issues that I think are important, and the CAB gives me feedback on what they believe is important to the community. In both of these cases, I am asked to present my findings at public meetings. In still another case, where the scope of the TAG was very focused, I gave public presentations in five communities around the state and established a dialogue with those who did not agree with my conclusions.

    Because the community’s interests are often not focused at the beginning of the TAG, and the Technical Assistance Grant has limited funding relative to the amount of money that PRPs and the regulatory agencies have at there disposal, I have on many occasions written “Community Guides” that provide an overview of the site and the issues as I see them. These are then discussed with the community, and the community decides on what issues it would like to focus on.

    Peter Strauss

  19. Michael Northridge of EPA permalink
    November 3, 2010

    Peter,

    It’s my understanding that you may be the only Advisor who has served community groups pursuant to both an EPA TAG (e.g., LLNL, MEW, Moffett) and to a PRP arrangement in a settlement provision (= the Casmalia site). Accordingly, given your unique position, I am interested in whether you might be willing to share your perspective as to the pro’s and con’s of these two different mechanisms (e.g., the different levels of paperwork facing the community group recipients).

  20. Reenie Rogers of Green Living Consultant permalink
    November 19, 2010

    Make sure every retail worker and cashier and others who handle thermal paper in their job all day are given the complete profile of BPA bisphenol A which coats this type of paper. It is their “Right to Know” what risks their jobs entail. It is essential that all women of child bearing age, and pregnant women, know that BPA may seriously affect the developing fetus.

  21. John Schweizer of T3W Business Solutions, Inc. permalink
    February 1, 2011

    To Peter Strauss’s comment, I say hear, hear!
    To Michael Northridge: did you get a response?
    Based on Peter’s comment and his apparent experience on NPL projects funded by PRPs, and my own experience in the TAG and TASC programs on a publicly funded Superfund project, I realize that funding is an issue for serving the needs of the whole community. Good quality, independent-minded TAs that can respond to the issues that concern diverse communities, and arise as a project progresses, should be adequately funded.
    Peter Strauss’s physical proximity to my own (he is located in San Francisco and I am located across the Bay Bridge in Berkeley) brings up another issue in how the EPA can ensure that whole communities are served. The EPA considers geographical proximity to a site as the first critereon for considering the elegibility of a TA to participate. Presumably, travel costs are the issue and also a belief that an advisor who is not local will not be accepted by the community. It seems to me the experience and character of a TA are far more important criteria than physical location to ensure that all members of an affected community are served.

  22. Michael Northridge of EPA permalink
    February 7, 2011

    No, I haven’t received a response yet from Mr. Strauss. Any assistance you could provide in connecting us would be greatly appreciated. ;-)

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