[CPEO-BIF] CPEO comments on OSWER's Community Action Initiative

[Lenny Siegel <lennysiegel@gmail.com>]

Please find below the Center for Public Environmental Oversight's 
(CPEO's) comments on the U.S. EPA Office of Solid Waste and Emergency 
Response (OSWER) "Community Action Initiative Proposed Action Plan." See 
www.epa.gov/oswer/engagementinitiative.htm

In the interest of full disclosure, readers should know that OSWER has 
been the largest source of CPEO funding for the past several years. 
Current CPEO projects are funded through the Brownfields program's 
Training, Research, and Technical Assistance Grant program and the 
Superfund Technical Assistance Grant program.

Lenny Siegel
Executive Director, CPEO
December 29, 2009



OSWER's Community Action Initiative Proposed Action Plan lays out a 
strong, positive vision for public participation in government 
environmental decisions. Its implementation will not only benefit 
impacted communities, but by strengthening best practices for community 
involvement and providing opportunities for consistent, constructive 
public participation, it will serve the long-term interests of 
responsible parties, waste generators, and government agencies.

However, there are three specific areas where we believe the Plan could 
be more proactive.

SITE-SPECIFIC TECHNICAL ASSISTANCE

EPA's Superfund Technical Assistance Grant (TAG) program is one of the 
most successful programs in existence for helping communities influence 
environmental decisions, but it is difficult for many communities to 
plug into that program. It could be strengthened by:

1) Extending the TAG program to communities that have significant solid 
and hazardous waste challenges but which do not currently "host" 
Superfund National Priorities List (NPL) sites. Sometimes high-profile 
sites are addressed through other programs, such as the Resource 
Conservation and Recovery Act, or the need for informed public input 
manifests itself well before EPA has had a chance to consider NPL inclusion.

2) Assign EPA staff or contractors to help interested communities define 
their needs for technical assistance, establish or find organizations 
capable of receiving TAGs, and completing the paperwork required to earn 
awards and receive funding. While there are cases where EPA community 
involvement specialists have done exactly this, the current system is 
intimidating and beyond the capacity of many community organization to 
take part.

3) Expand the opportunities for on-call, short-term technical 
assistance, and ensure that communities with needs for independent 
technical assistance are aware of such opportunities. The long list of 
EPA success stories in this area is matched by the number of communities 
unaware that such help may be available.

4) Provide community-oriented training for technical assistance 
consultants. The U.S. has a vast number of professionals capable of 
reviewing technical environmental documents, but most communities need 
advisers who can also help them understand when, where, and how to 
influence environmental decisions. They need consultants who can help 
them identify and prioritize key issues long before decisions are to be 
made, so they can develop constructive positions and build community 
support for those proposals. In my experience, there are only a handful 
of advisers with that capability.


COMMUNITY ADVISORY GROUPS

EPA sponsors a number of Community Advisory Groups (CAGs) throughout the 
country. At sites where a series of environmental decisions need to be 
made, and where there is strong community interest, these serve as an 
excellent forum for constructive community involvement, educate the 
public about complex technical issues, and build trust among diverse 
stakeholder constituencies. Community Advisory Groups are designed to 
represent diverse local perspectives, so they supplement – that is, they 
do not substitute for - community-based (activist) organizations.

OSWER should expand its efforts to let communities know about CAGs and 
provide support for their organization. One useful approach would be to 
bring in community participants from successful CAGs or similar 
organizations to explain the benefits and limitations of the CAG structure.

Many communities – particularly environmental justice neighborhoods – 
are home to multiple contaminated sites, waste facilities, and other 
environmental stresses. The CAG model should be broadened to provide 
area-wide environmental oversight, particularly where no single site 
generates consistent community interest, but where cleanup, 
environmental management, and revitalization present ongoing challenges 
for the community as a whole


NATIONAL POLICY INPUT

The Proposed Action Plan correctly notes, "EPA's broad national actions 
may also affect local communities." Yet the opportunities for local 
activists to participate effectively in national policy-making are 
limited. Even where community participants are invited to the table, 
they are often overwhelmed by the expertise, resources, and sheer 
quantity of private sector representatives. However, when community 
participants are well represented, they often help generate policies 
that not only serve their own interests, but which help create more 
predictable, navigable processes that serve all parties. (The Negotiated 
Rulemaking on All Appropriate Inquiries is one such success.)

Today neither national environmental organizations nor local community 
groups have the capacity to cover even a significant fraction of the 
policy-making and standard-setting activities underway at EPA. In 
general, the people who take part in local oversight have "day jobs." 
They have trouble keeping up with local activities, to say nothing of 
traveling to conferences and committee meetings - even if their travel 
expenses are covered. Foundation funding, weakened by the economic 
downturn, now focuses on combating climate change - a worthwhile goal. 
But it leaves only a handful of environmental and environmental justice 
advocates funded to devote substantial time and energy to national-level 
issues.

We propose that EPA create a grant program to support local activist 
participation in national policy-making forums, and that the EPA 
personnel responsible for ensuring openness and balance in such forums 
actively recruit community-based participants.


All of our suggestions fit the goals of the Community Engagement 
Initiative. They all build on existing, but limited practices at EPA. 
Thus, we believe they can be implemented quickly and efficiently. The 
potential benefits are enormous.

--


Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org



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