Guidance for fulfilling 415 ILCS 5/58.7(h): Community Relations in Site Remediation
Although a formal Community Relations Plan (CRP) is not required in the Illinois Site Remediation Program (SRP), years of experience has shown that communication between the Remediation Applicant and the community is a wise investment during the investigation and remediation process. Some sites may need a formal CRP and a considerable amount of effort to conduct community relations activities. However, at many sites, the only community relations activity necessary may be to notify adjacent property owners that an investigation or cleanup is to occur or about contamination that may affect their properties. The level of community relations activity will vary from site to site.
Public Act 094-0314 requires Illinois EPA (or the Remediation Applicant) to notify property owners and elected officials when contamination in soil or groundwater is identified that poses an off-site threat of exposure. Additional requirements for community relations plans and public repositories may apply as well. The Office of Community Relations has compiled information on the 2006 Right-to-Know law along with other related documents.
The Illinois EPA will assist applicants in determining when community relations is necessary and will provide guidance to those applicants who are developing and implementing CRPs. In many areas of Illinois, the Illinois EPA has local contacts and working relationships with community groups and environmental organizations. The Illinois EPA will consult with Remediation Applicants about appropriate local contacts.
Community relations activities help facilitate two-way communication between the Remediation Applicant and interested and affected individuals and groups. Community relations activities promote public participation by sharing timely and accurate information among all concerned parties, and when possible, by incorporating community concerns into investigation and response plans. What is planned? Why are certain actions being taken? How will these actions be conducted in a way that is safe for the community? These are some of the key questions to answer during the dialogue with the community. In the context of environmental remediation, a community relations program that begins at or before the start of an investigation is more likely to succeed, as relationships, credibility and trust are established over time.
Remediation Applicants who distance themselves from the public create mistrust and often encounter resentment in their community. Initiating a community relations program will:
Delaying the community relations activities until later in the investigative process can allow community concerns to grow, and can even be costly in terms of misplaced investigative efforts that could have been avoided with the input of community knowledge about a site’s history. The likelihood of liability and litigation from third-party lawsuits may be reduced when the remediation process is open and transparent for all to understand.
Any of the following site-related conditions indicate a probable need for community relations activities:
The type of CRP needed for your site will depend upon site conditions and community factors. A written plan makes it easy for all concerned parties to understand what is being done at the site. Two types of CRPs are included with this guidance, and an example is given at the end of the Community Right-to-Know rules. In addition, you may want to review the U.S. EPA Community Involvement Handbook.
Every CRP should include at least these four components:
Purpose: Provide a brief overview of the site including information about previous land uses, the type and extent of contamination known at the time, and potential or known threats to public health and the environment. A map of the site and surrounding area showing streets, homes, businesses, and geographic features should also be provided in a separate figure. The information summarized in this section will be useful when responding to inquiries, particularly from the news media, and will provide concise background information needed when preparing fact sheets and news releases.
Suggested Length: One to three pages.
Purpose: Gather information about the community including demographics of the neighborhood and how the community has reacted to activities at this site. Key community concerns should be described in detail and can be organized by population segment (nearby residents, elected officials, environmental groups) or topic (property values, odors, health threat).
Example: Residents living near the facility have observed children playing inside the building. The residents know that drums and vats containing flammable liquids are still inside the building.
How used: The Remediation Applicant can alleviate this concern by securing the building to prevent access by children or other trespassers.
Suggested Length: One to two pages.
Purpose: Describe the community relations program objectives and provide a schedule of activities to meet these objectives. Identify a contact person for the Remediation Applicant who will handle community calls; specify the location of convenient information repositories (include information about on-line repositories, if available); and explain how the public will be notified of meetings and issued fact sheets and news releases. A matrix format to illustrate the schedule of activities is acceptable.
Example: The Environmental Watch Network (EWN), a local environmental group, has repeatedly contacted newspapers and local elected officials about threats to the environment posed by this abandoned site. One objective in the CRP might be, “Provide updates to EWN on project status.” Activities to fulfill this objective could include:
Suggested Length: Two to three pages.
Purpose: Provide name, title, mailing address, e-mail address and telephone/fax numbers of local, state and federal elected officials, adjacent property owners, news media (print and electronic), government organizations, any known organized environmental or community groups, and concerned citizens. Concerned populations may include schools, hospitals, day care and senior facilities within a few blocks of the site, even though they are not adjacent to the site. The publicly available CRP may not necessarily include the names and addresses of adjacent property owners and concerned citizens due to privacy concerns. Also include contact information for Illinois EPA staff and site contractor staff responsible for site activities.
The contact list provides a reference that saves time when calling or mailing. Having this list documented reduces the chance of key groups or individuals being inadvertently overlooked. The CRP is a living document. It will need to be adjusted and updated in anticipation of, and in response to, changing events.
The CRP may be prepared by the Remediation Applicant, its environmental contractor, a community relations contractor experienced in environmental issues, or, in certain situations, Illinois EPA.
Most sites in the Illinois Site Remediation Program should not need an extensive Community Relations Plan as provided in the previous example. This short form plan may be used as a template to document essential information for sites with a low need for community relations:
February, 2010ABC Warehouse
The ABC Warehouse is located at the intersection of 1100 First Avenue and Perkins Road within the city limits of Huntsville on a two-acre site. The brick, two-story structure is bordered by farm fields on the north, west, and south. A residential area begins on the adjacent property east of the building and continues along Perkins Road into town. The building is structurally sound and secured from easy access by metal shuttered windows and padlocked metal doors. Public drinking water and wastewater services are provided by Huntsville. The Washington Grade School is three blocks southeast of the site on First Avenue. The Johnston County Senior Citizens Center is one block east of the site on Perkins Road.
This building still contains approximately 200 fifty-five gallons drums that need to be sampled, and one closed vat containing an unidentified sludge-like material. About half of the drums are corroded, and some of these drums will need to be over-packed before removal.
Five fifty-five gallon drums are labeled “Trichloroethylene.” This is a common solvent used to clean oil from metal parts. Waste oil and other suspected unknown contaminants are in the remaining drums.
All questions about community relations activities and news media inquiries should be directed to Robert Johnson, Manager, Environmental Affairs, CDX Industries, 123 Corporate Way, Harrisburg, Pennsylvania 80214 (Tel: 207/488-9977); e-mail address: Rjohns1@CDX.com.
Before remediation, we will:
When remediation commences, we will:
You are encouraged to contact:Illinois Environmental Protection Agency