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1 Community Involvement Plans Community Involvement Plans Description A Community Involvement Plan (CIP) is a site- specific strategy to enable meaningful community involvement throughout the Superfund cleanup process. CIPs specify EPA-planned community involvement activities to address community needs, concerns, and expectations that are identified through community interviews and other means. The CIP is both a document and the culmination of a planning process. 1 As such, the CIP provides the backbone of the community involvement program and serves as a useful reference that the Site Team often turns to during the Superfund cleanup for advice on appropriate activities for community involvement. A well-written CIP will enable com- munity members affected by a Superfund site to understand the ways in which they can participate in decision making throughout the cleanup process. Required Activity Yes. The National Contingency Plan (NCP) requires the lead agency to prepare a Community Involvement Plan (formerly called a Community Relations Plan) “based on community interviews and other relevant information, specifying the community relations activities that the lead agency expects to undertake during the remedial re- sponse.” The NCP specifies that the CIP must be in place before remedial investigation field activities start, “to the extent practicable.” The NCP further requires that EPA review the CIP prior to initiating the remedial design (RD) “to determine whether it should be revised to describe further public involvement activities during Reme- dial Design/Remedial Action (RD/RA) that are not already addressed or provided for” in the CIP. For removal actions lasting 120 days or more, the NCP specifies that the lead agency must prepare a CIP based on community interviews and other relevant information “by the end of the 120-day period.” For removal actions with a planning period of at least six months, the NCP requires the CIP to be completed prior to the completion of the Engi- neering Evaluation/Cost Analysis (EE/CA). These requirements are equally applicable to federal facilities and sites using the Superfund Alternative Approach (SAA). Making it Work A carefully prepared CIP provides a game plan or road map for the Site Team’s use throughout the cleanup process. While you, as Community Involve- ment Coordinator (CIC), have primary responsibility for the CIP, all members of the Site Team—the Remedial Project Manager (RPM) or On-Scene Coordinator (OSC), CIC, Risk Assessor, the enforcement case team, EPA contractor, state, tribal, or local agency staff, or others—should be involved in the development and implementation of the CIP. The CIP should be a “living” document and is most effective when it is updated or revised as site conditions change. The CIP document: Describes the release and affected areas (a.k.a., “the site”), including relevant history, type and extent of contamination, and environmental exposures and concerns, both related to the site and in a broader sense; 1 Hellier, Justin, Planning for Participation: Trends & Opportunities in Superfund’s Community Involvement Plan, 2010: Report prepared for the U.S. EPA by National Network for Environment Management Studies Fellow. Many of the ideas for this tool were informed by this report.

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Page 1: GUIDANCE REGARDING COMMUNITY INVOLVEMENT PLANS · 2016-06-22 · 2 Community Involvement Plans Children’s Environmental Health Describes the community in a comprehensive Community

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Community Involvement Plans

Community InvolvementPlansDescription

A Community Involvement Plan (CIP) is a site-specific strategy to enable meaningful communityinvolvement throughout the Superfund cleanupprocess. CIPs specify EPA-planned communityinvolvement activities to address community needs,concerns, and expectations that are identifiedthrough community interviews andother means.

The CIP is both a document and the culmination ofa planning process.1 As such, the CIP provides thebackbone of the community involvement programand serves as a useful reference that the Site Teamoften turns to during the Superfund cleanup foradvice on appropriate activities for communityinvolvement. A well-written CIP will enable com-munity members affected by a Superfund site tounderstand the ways in which they can participatein decision making throughout the cleanup process.

Required Activity

Yes. The National Contingency Plan (NCP)requires the lead agency to prepare a CommunityInvolvement Plan (formerly called a CommunityRelations Plan) “based on community interviewsand other relevant information, specifying thecommunity relations activities that the lead agencyexpects to undertake during the remedial re-sponse.” The NCP specifies that the CIP must bein place before remedial investigation field activitiesstart, “to the extent practicable.”

The NCP further requires that EPA review the CIPprior to initiating the remedial design (RD) “todetermine whether it should be revised to describe

further public involvement activities during Reme-dial Design/Remedial Action (RD/RA) that are notalready addressed or provided for” in the CIP.

For removal actions lasting 120 days or more, theNCP specifies that the lead agency must prepare aCIP based on community interviews and otherrelevant information “by the end of the 120-dayperiod.” For removal actions with a planning periodof at least six months, the NCP requires the CIP tobe completed prior to the completion of the Engi-neering Evaluation/Cost Analysis (EE/CA).

These requirements are equally applicable tofederal facilities and sites using the SuperfundAlternative Approach (SAA).

Making it Work

A carefully prepared CIP provides a game plan orroad map for the Site Team’s use throughout thecleanup process. While you, as Community Involve-ment Coordinator (CIC), have primary responsibilityfor the CIP, all members of the Site Team—theRemedial Project Manager (RPM) or On-SceneCoordinator (OSC), CIC, Risk Assessor, theenforcement case team, EPA contractor, state,tribal, or local agency staff, or others—should beinvolved in the development and implementation ofthe CIP.

The CIP should be a “living” document and is mosteffective when it is updated or revised as siteconditions change. The CIP document:

Describes the release and affected areas (a.k.a.,“the site”), including relevant history, type andextent of contamination, and environmentalexposures and concerns, both related to the siteand in a broader sense;

1 Hellier, Justin, Planning for Participation: Trends & Opportunities in Superfund’s Community Involvement Plan,2010: Report prepared for the U.S. EPA by National Network for Environment Management Studies Fellow. Many ofthe ideas for this tool were informed by this report.

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Children’s Environmental Health Describes the community in a comprehensive

Community Profile that includes demographics,local government structure, and any relevantcommunity characteristics;

Identifies key community needs, questions, andconcerns, as well as expectations and uniqueneeds of the community (e.g., translation anddisability services) or unique cultural behaviors,customs, and values. This information is typicallycollected through Community Interviews anddepicted in the Community Profile;

Describes the need for technical assistanceservices and, if appropriate, identifies appropriateprograms and mechanisms for providing accessto Technical Assistance for Communities;

Specifies EPA’s planned outreach activities andcommunity involvement mechanisms, including aprojected sequence of project milestones tied tosite activities (with projected timeframes,whenever possible), and describes the mecha-nisms that will be used to explain to the publichow community feedback is considered duringthe cleanup process;

Identifies any additional special services orapproaches EPA will use to address uniqueneeds of the community, which may includeencouraging the formation of a CommunityAdvisory Group (CAG), providing Facilitation/Conflict Resolution/Alternative DisputeResolution (ADR) services for communitymeetings or groups, Translation Services, orsupporting an approach for Community Vision-ing (i.e., allowing open-ended brainstorming forcommunity stakeholders to envision the futurepotential reuse of the site);

Allows for community comment on the draft CIPand describes the mechanisms used to receiveand consider feedback before issuing the “final”CIP (e.g., formal or informal public comments,community meetings, public meeting, etc.); and

Describes future plans for updating or revisingthe CIP.

Developing the CIP

Start the process of developing your CIP severalmonths before the remedial investigation fieldactivities begin or, for removal actions, before theend of the 120-day period. The level of effortinvolved and the amount of time required to preparea CIP will depend on many factors, including thesize, complexity and the stage in the cleanupprocess at which the CIP is being developed orupdated or revised; the number and diversity ofaffected residents and community groups; the levelof community interest; and the potential conten-tiousness of issues regarding the site.

A CIP developed early in the cleanup process for acommunity with a high level of interest in site issueswill likely be larger in scope and detail than a CIPthat is being revised in the latter stages of thecleanup process (including the five-year review), orin a community whose residents have demonstratedlittle or no interest in the site. Similarly, a CIPwritten for a small site that involves few communityinvolvement challenges is likely to be less complexthan a CIP for a large site with contentious orcomplicated technical issues and many communitygroups with special needs and concerns. While thelevel of effort required to develop a CIP is difficultto estimate because of these variations, it is notunusual for preparation of a CIP for a relativelycomplex site or a site with contentious issues torequire 200 hours of team effort over severalmonths.

In any case, the CIC should begin planning for theCIP early. The process will involve planning for,conducting, and analyzing a number of communityinterviews, preparing the community profile,coordinating with all Site Team members aboutcommunity involvement goals and objectives, andwriting the CIP. You also should factor in time toallow for your Site Team to thoroughly reviewvarious drafts of the CIP. Also, allow time for localagency input, if applicable, and for communitycomments on the draft CIP before it is finalized.Start by scheduling a planning meeting with theRPM or OSC and other members of the Site Team,including local agencies and the contractor, if

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appropriate. Consider your community involvementgoals at the site, how you plan to use the CIP, andwhat its scope ought to be. Develop a workplan forpreparing the CIP. Define the roles and tasksassigned to each member of the Site Team (includ-ing the contractor, if there is one for the site). Inaddition, assess the role your Community Involve-ment Manager plays in the preparation, review, andapproval of the CIP. (A sample CIP WorkplanTemplate is included in Attachment 1.)

CICs are often supported by EPA contractors whowork on some portion of the CIP. Use your con-tractor support wisely. The contractor generally cando much of the background demographic researchfor the community profile, prepare contacts lists,and help with scheduling of community interviews.It is strongly recommended that communityinterviews be conducted by EPA staff. But, in thelimited cases where contractors are used toconduct interviews, they should be accompanied byEPA staff. Community interviews should be led bythe CIC, preferably accompanied by the RPM orOSC. This will provide an opportunity for commu-nity members to meet the RPM or OSC, and willallow the site’s RPM or OSC to hear directly fromcommunity members about their needs, expecta-tions, questions, and concerns related to the site.

Describing the Community

A good CIP starts with good information about thecommunity. You will obtain this information fromthe community profile and community interviews,as well as through your experience around the site,interactions with members of the public affected bythe site, and insights from the Site Team. The SiteTeam should become aware of whether a commu-nity may have disproportionate burden of exposureor environmental health effects due to race,national origin, or income compared to othercommunities located nearby (i.e., issues related toenvironmental justice). In particular, you shouldcollect, analyze, and summarize information about:

The site: Its history and the key issues relatedto site contamination and the cleanup effort.

The community: Key demographic informationabout the affected community and identificationof stakeholder groups, community organizationsand institutions, and community leaders (both

official and unofficial), local government agen-cies, and media and communications outlets.

Community needs, concerns and expecta-tions: Issues of concern to residents, identifiedthrough community interviews, informal discus-sions and interactions with residents and stake-holder groups, local media reports, and otherinsights about the affected community. Keyissues of concern to the local community mayinclude perceptions and opinions of EPA and thecleanup process; how people want to be keptinformed (i.e., mechanisms to deliver informa-tion) and included in the decision-making pro-cess; what are perceived barriers to effectiveparticipation; whether there are other sources ofpollution that affect the community (see textbelow); and whether there are past experiencesof mistrust or any unique concerns. You also canuse this information to assess whether theresome groups that face unique exposure scenarios(e.g., fish consumption patterns) or whether theyexperience or perceive that they have unequalaccess to the decision-making process (i.e.,issues relating to environmental justice). Use thisinformation later—in the CIP Action Plan—torecommend any special services, includingtechnical assistance, formation of a CAG,facilitation/conflict resolution/ADR, or translationservices, that might be needed. If your commu-nity research identifies significant conflict oradversarial activities related to the site, you maywish to determine whether a third-party “conflictor situation assessment” should be conducted.

Although the CIP focuses on the Superfund cleanupprocess, you should be aware of the other environ-mental issues beyond the site that could affect howcommunity involvement is conducted or received bythe community—particularly concerns aboutenvironmental justice. Find out whether there areother regulated hazardous waste facilities orenvironmental programs administered by EPA orthe state in the community. It also is useful to checkfor any ongoing EPA, state, or tribal enforcementactions nearby that might affect community atti-tudes towards EPA and state regulatory programs.Bringing local government agencies to the tableduring the planning phase of the CIP can providelocal knowledge of existing environmental concernsin the community at that time, as well as otherinsights. Work closely with your RPM or OSC to

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Children’s Environmental Healthdetermine whether any scientifically sound healthstudies exist that provide information about otherenvironmental exposures to the population. It alsomay be useful to consider social and economicimpacts of the Superfund site and cleanup actionsand what the community’s thoughts are regardingfuture redevelopment at the site.

This “big picture” information is extremely usefulfor developing an effective plan for Superfundcommunity involvement. However, if you chooseto identify issues beyond the scope of theSuperfund program, you should clearly explain inthe CIP that issues not directly related to Superfundcleanup cannot be addressed through theSuperfund authorities, nor can EPA use itsSuperfund authorities to compel potentiallyresponsible parties (PRPs) to address these otherissues. Nevertheless, the Site Team should align ina strong collaborative relationship with peopleinside and outside the Agency to help thecommunity identify EPA contacts or contacts atother government agencies for communityconcerns outside the scope of the Superfundprogram. The CIP may be useful in identifyingresources to meet such community concerns.

Preparing the Action PlanThe next step is to develop the Action Plan for thesite. The Action Plan is a site-specific approach tomeet specific community-involvement objectivesidentified by the Site Team. CICs should use theinformation they’ve collected about the site and theaffected community, along with what has beenlearned through community interviews and fromother sources, to develop an Action Plan thataddresses the community’s needs, concerns,questions, and expectations, as well as their com-munications styles and preferences.

The Action Plan: Defines community involvement objectives for

the site, including the level of participation thatEPA is seeking (to inform the community, seekconsultation from the community, or activelyinvolve the community in site decision-making)and describes how community input will influ-ence the decision-making process. The level of

participation will be unique for each site. (For atool to help site teams define between variouspossible levels of involvement, see the Interna-tional Association of Public Participation’s(IAP2) Spectrum of Public Participation, inAttachment 2.)1

Describes the decision-making process andidentifies key opportunities for public input duringthe Superfund cleanup process. This includessignificant milestones and a proposed sequencefor community involvement activities, i.e., thepoints in the cleanup process at which specificactivities are likely to occur. This languageshould also reaffirm that community stakeholdersmay have important information to provide incharacterizing the site and developing cleanupsolutions.

Outlines a comprehensive plan that describeshow future EPA activities will address identifiedcommunity needs, concerns, questions andexpectations regarding site cleanup and howEPA will communicate with the public. Thisincludes specifying any special services (includ-ing technical assistance, facilitation/conflictresolution/ADR, or translation services) orrecommending formation of a CAG to addressspecific community needs.

Identifies appropriate communications methods,forums and opportunities for public input, consul-tation and involvement in decision-making duringthe Superfund cleanup process, e.g., the need totranslate documents, partner with specificcommunity organizations/leaders, use specificmedia outlets for outreach, or hold meetings at aspecific community location.

Putting it All Together: Writingthe CIP

Now that you’ve described the community anddeveloped the Action Plan, it is time to put theinformation together in a way that will be useful toyou and the other target audiences for the CIP. Ofcourse, you—as the CIC — are a target audience,as are future CICs, the RPM or OSC, the enforce-ment case team, and other members of the Site

2 Note that IAP2’s spectrum includes five levels of participation, with the first four appropriate for Superfundcleanups. (The fifth level of public participation on the spectrum extends beyond what EPA can offer at Superfundsites, since EPA cannot delegate decision-making by placing decisions entirely in the hands of the public.)

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Team. A good CIP always will be written withthe broader audience in mind: the community.Other audiences include the PRPs and otherfederal, state, local, and tribal agencies involved inthe cleanup. Be mindful that too much data andbackground information presented early in thedocument could be intimidating or fatiguing for thereader. Communicate the most critical informationearly in the document.

The purpose of the CIP is not to providetechnical answers to the community’s ques-tions. The CIP is EPA’s plan for informing andinvolving the community in the cleanup pro-cess. In some cases, particularly when the CIP isupdated or revised for a five-year review or wherecommunity interest is minimal, a short CIP outliningEPA’s plan for community involvement may be allthat is needed. For most sites, the CIP should bewritten to address the community directly in a waythat shows EPA’s commitment to listening to theirinput and inviting their active involvement at eachstage of the Superfund cleanup process.

While there is no standard or required outline for aCIP, it should be written to allow readers, particu-larly members of the community, to understand: (1)the Superfund cleanup process; (2) how, when andwhere EPA will provide site-related information tothe public; (3) how the public can be activelyinvolved in the cleanup process; and (4) the keypoints in the cleanup process and the ways in whichEPA takes public input into consideration duringinterim and final decisions. Keep in mind that theCIP can be a powerful way to communicate EPA’scommitment to listening and responding to commu-nity concerns, and providing timely information andopportunities for community involvement.

There are many ways to organize the basic ele-ments of the CIP in a user-friendly document thatwill do more than sit on the shelf of the localinformation repository. The order in which youpresent the information in the CIP is critical: themost important information should be presentedclearly and concisely early in the document, per-haps in an overview or executive summary. Thetables of contents for the CIPs described in the

“Templates and Models for CIPs” (Attachment 3)provide a few basic outlines that you can use as atemplates for writing your CIP. Use these examplesto find a suitable model/template for your CIP.While each example presents the information in aslightly different way, you’ll see that these ex-amples contain the key elements included below:

Site Description: A description of the site, itshistory, and the key issues related to site contamina-tion and the cleanup effort.

Community Profile: A description of the affectedcommunity, including a summary of demographicsand identification of significant subgroups in thepopulation, languages spoken, and other importantcharacteristics of the affected community, such aswhether the site is located in an area with environ-mental justice concerns. It also should includeinformation about how the profile was derived.

Community Needs and Concerns: A summary ofcommunity concerns, needs and expectationsidentified from community interviews and throughother communications and experiences with thecommunity. Identify major concerns (or “themes”)that emerge. You can present quotes from commu-nity interviews, but you should not identify theinterviewee. This section of the CIP is EPA’sopportunity to communicate what we heard andunderstand from the community. It should include adiscussion of:

The community interviews conducted, includingthe number of interviews and how intervieweeswere selected or how they represent the variousgroups in the community, along with a summaryof the findings from these interviews;

Other sources of information about communityneeds and concerns and what was learned fromthese other sources; and

Other related, but not necessarily Superfund site-specific environmental or health issues affectingthe community, particularly any other EPAprograms that may be operating in the commu-nity (optional, but recommended, if appropriate)and other environmental exposures documentedin existing, scientifically sound health studies. Ifthis discussion is included, be sure to clearlyexplain that only Superfund-related issues can beaddressed through the Superfund cleanup.

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Children’s Environmental HealthHowever, the CIP can identify resources to meetsuch community concerns, such as identifyingcontacts or programs at EPA or other govern-mental agencies.

Action Plan: EPA’s planned outreach and commu-nity involvement activities tied to site activities. Thissection should include:

A sequence of activities tied to milestones in theSuperfund cleanup process (preferably withanticipated timeframes);

Appropriate channels for reaching the commu-nity and offering opportunities for input from thecommunity (e.g., news media, communitygroups, community leaders, local elected offi-cials, social media applications, etc.);

Recommendations for addressing identifiedcommunity needs, including providing facilitationor conflict resolution assistance, using translationservices, encouraging formation of a CAG, oroffering technical assistance or other services tothe community, as appropriate. The CIP also canidentify the need for specific CI tools andtechniques to address specific concerns andissues (i.e., preparation of additional fact sheetson specific topics, etc.);

The location of the information repository; References to additional existing information

about the site that may answer people’s con-cerns, such as past human health risk assess-ments, fact sheets, etc.

Possible locations for public meetings or othersite-related community involvement activities(see Informal Activities);

Discussion of how community feedback was orwill be collected and used to develop and revisethe CIP;

Discussion of when and how the CIP will beupdated or revised; and

Sources of other relevant information, as appro-priate, as well as identification of emergencyresponse notification systems (text and emailnotification systems operated by local govern-ment) and identification of appropriate places topost notices (physically through signage, forexample, and electronically on specifiedwebsites, etc.).

Contact Lists: A reference listing of contacts(name, address, phone, email) useful for thecommunity or the Site Team. Consider whetherpermission should be obtained before includingcontact information for some of the people listed.This may go into an appendix, especially if it’s likelyto be revised regularly, and should include contactinformation for:

The Site Team; Community groups and community leaders; Local elected officials; Local, state, tribal, and federal agency staff

relevant to the site; Media contacts (including social media outlets

and citizen journalists); and Others, as appropriate.

Optional Sections: As appropriate for the site andcommunity, you may wish to include other elementsto the main body or as appendices, such as:

Executive Summary; Glossary of Superfund terms; Criteria for assessing how well the CIP is being

implemented; Graphics that visually present the Superfund

cleanup process; Visual schematic of the site; Communications Strategies on specific issues,

such as a risk communication strategy; Other sections added on a site-specific basis; and References or links to relevant existing site

information.

Making the CIP Accessible to theCommunity

To ensure the CIP is indeed informed by thecommunity, consider sharing a draft CIP with thecommunity and invite their input and feedback alongthe way. The best CIPs offer a clear invitation tothe community for feedback before they arefinalized. Describe the procedure for eliciting andresponding to comments from the community in thedraft CIP.

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Community comments can improve the quality ofthe CIP by ensuring that it is flexible and commu-nity-specific. Comments also may correct errors oradd additional information that may have beenmissed in the community interviews. Perhaps thegreatest benefit of inviting community comment onthe draft plan is that doing so helps build credibilityand trust by modeling EPA’s commitment to open,transparent, two-way communication and to involv-ing the community in the cleanup process.

Describe the ways in which EPA will collect anduse the community’s feedback on the draft andoutline the anticipated timeframe for finalizing theCIP. (Here you should spell out the ways in whichyou plan to seek or accept public comments on thedraft—such as via written comments, a website, apublic meeting or community meetings—and whatyou plan to do with the comments that you receive(e.g., incorporate them into the final draft or preparea responsiveness summary). It is not generallynecessary to hold a public meeting or prepare aresponsiveness summary for public comments onthe CIP, but you should explain the specific proce-dures you have chosen to solicit and considercommunity feedback on the CIP.

Also explain how you plan to distribute the final CIPand how and where you will make it available to thecommunity once it is final. At a minimum, the CIPmust be available in the Information Repository. Inkeeping with EPA’s move toward taking advantageof electronic media, the CIP also should be placedon EPA’s website (usually the site-specific website).

Updating or Revising the CIP

The NCP requires that the CIP be reviewed prior tothe initiation of the remedial design to determinewhether it should be revised to describe furtherpublic involvement activities. Yet, there is no stan-dard rule about when to update or completely revisethe CIP. Because the CIP should be a living docu-ment that is referred to regularly, it makes sensethat information will be continuously added orupdated. Often, all that is necessary is updatingcontact information, media and elected officials lists,

and other reference materials that usually areincluded as appendices in the CIP. However, acomprehensive revision of the CIP involves muchmore than updating lists of contacts and otherreference materials; it requires taking a fresh lookat community needs and concerns (usually byconducting another round of community inter-views), reassessing EPA’s community involvementapproach, and revising EPA’s site-specific actionplan for community involvement accordingly.

Even as you prepare an initial CIP, it is a good ideafor you and the rest of the Site Team to thinkahead and define—to the extent possible—thepoints in the Superfund cleanup process at which acomprehensive revision might be warranted. This isimportant for planning purposes, so the RPM orOSC can budget for the effort at the appropriatetime, and because the CIP should include a shortdiscussion about EPA’s plans for revising it.

In remedial action cases, updates or comprehen-sive CIP revisions may be undertaken at specificbenchmarks in the Superfund remedial cleanupprocess, such as after a record of decision (ROD)is signed, at Explanations of Significant Differencesor ROD amendments, before the remedial actionhas begun, at remedial action project completion, orat initiation of the five-year review. Others areupdated or revised according to a timetable, suchas every three or five years.

The decision to undertake a comprehensiverevision of the CIP sometimes is made based on achange in the level or nature of community interest.When there is a high level of interest at a site, theCIP should be revised regularly so that the docu-ment continues to reflect current conditions andcommunity interests. On the other hand, it may betime to conduct a comprehensive CIP revisionwhen community interest has waned over a longperiod of time. It also may be appropriate to revisea CIP after demographic, economic, or politicalchange in the community. A CIP revision is in orderwhen CICs believe that a change their strategy oninvolving communities may be necessary.

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Children’s Environmental HealthCIPs for Federal Facilities: EPA’s Role

Because other federal agencies have lead cleanupauthority at federal facilities, such as active andclosed Department of Defense installations andDepartment of Energy sites, the agencies also havethe lead for CIPs. At federal facilities, the role ofthe EPA CIC changes from “doer” to “reviewer”when CIPs are created, updated, or revised. Thekeys to successful community involvement atfederal facilities include cooperation between EPAand the responsible federal agency and prompt,effective communication among these agencies andthe local community. The NCP, CERCLA, EPA’sSuperfund Community Involvement Toolkit,EPA’s Superfund Community InvolvementHandbook and web resources, coupled with EPA’s“early and meaningful community involvement”guidance authorize the role of the CIC at federalfacilities.

The CIC should be present at community inter-views and review the federal facility’s draft CIP,ensuring federal-facility CIPs are as rigorous asEPA fund-lead and PRP-lead sites. A CIC shouldbe prepared to play a leading role in making surethe CIP addresses the community’s needs, con-cerns, and expectations and clearly explains thefederal facility’s plans for involving the community.

The initial CIP is a document that has strict negoti-ated review timeframes that trigger actions whendeadlines are missed. This means that the CICshould carefully review the federal facility CIP toensure that it includes a sequence of outreach andcommunity involvement activities with timeframestied to the current Site Management Plan. How-ever, CIP updates or revisions may not be trackedusing the same strict approach. Thus, sometimesmany years pass between CIP revisions. The EPACIC should coordinate with their federal facilitycounterpart to ensure that the CIP continues to be a“living document” that addresses community needs.

CIPs at Sites Using the SuperfundAlternative Approach: EPA’s Role

The Superfund Alternative Approach (SAA) isemployed at sites that are NPL-caliber, but are notlisted on the NPL. Often, sites using the SAA areproposed to the NPL but not finalized. Cleanupwork at such sites is performed by a PRP under asettlement with EPA and is expected to be equiva-lent to work performed at an NPL site. Accordingly,the CIP at such sites should be prepared by EPA inthe same manner as at a typical NPL site.

One key difference between NPL sites and sitesusing the SAA is that the community would not beeligible to apply for a Technical Assistance Grant(TAG) if the site is not proposed to the NPL.(TAGs are available only for sites that are on theNPL or proposed for listing on the NPL.) In suchcases, a provision is typically included in the SAAsettlement requiring the PRP to provide TechnicalAssistance Plan (TAP) funding to replace the TAGand provide the same benefit to the community. TheCIC should work with the PRP to make the com-munity aware of the availability of TAP funding. Inaddition, the CIC should include a discussion ofobtaining the TAP funding in the CIP. Although theTAP agreement is between the community and thePRP rather than the community and EPA, the CICand Site Team should be involved in reviewing andimplementing the agreement.

CIPs at State-Lead Sites: EPA’s Role

In some regions, a state can have the lead role for aSuperfund site. The state is responsible for writingand updating the CIP at such sites. At state-leadsites, the EPA CIC should be familiar with thestate’s CIP for the site and respectful of the state’slead role. CICs should work with the state andconsult the state’s CIP when planning EPA’soutreach and community involvement activities.EPA’s activities should be planned and conducted ina way that is consistent with the state’s CIP,mindful of existing relationships and methods ofcommunicating site information. Not only is thisimportant for good coordination, it also allows EPAto take advantage of the state’s experience workingwith community groups and building effectiveoutreach mechanisms.

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Tips

Write the CIP in a way that not only tells thecommunity about community involvement, butacts as an invitation to them. The Harbor IslandArea Superfund Sites: Lockheed West Seattleand Harbor Island/East Waterway CIP is anexample. (See: http://yosemite.epa.gov/r10/cleanup.nsf/sites/LockheedWest/$FILE/lockheed_harbor_island_cip.pdf)

Communicate the most critical information earlyin the document. Too much data and backgroundinformation presented early in the documentcould be intimidating or fatiguing. Avoid languageand information overload that would discouragethe reader from continuing through the documentor from participating in the public participationprocess. The CIP written for the Iron King Minesite is a good example of how to communicatethe most important information to the publicupfront and in an easy-to-understand and invitingway. (See: http://yosemite.epa.gov/r9/sfund/r9sfdocw.nsf/3dc283e6c5d6056f88257426007417a2/f771fade9d9362d7882576f80078c62e!OpenDocument)

Create a simple matrix showing key stakeholdergroups and the information of greatest interest tothem. This can help ensure that stakeholdergroups receive the information of greatest use tothem.

Use text boxes and graphics effectively tohighlight important information. Include a flow-chart of the Superfund cleanup process, mapsand photos of the site, and links to usefulwebsites.

Including contacts lists and other referenceinformation that change often in an appendixrather than in the body of the CIP will make iteasier to update often.

Many CIPs include extensive glossaries to helpreaders understand technical terminology and theSuperfund cleanup process. If you include aglossary, take entries from the official EPAglossary, “Terms of Environment: Glossary,Abbreviations and Acronyms,” at http://www.epa.gov/OCEPAterms/, which is updatedperiodically. (Note: A Spanish-language glossaryof Superfund terms is available at: http://www.epa.gov/superfund/spanish/glosario/index.html).

If a contractor helps prepare the CIP, be surethat you, the CIC, receive all deliverables;nothing should go directly from the contractor tothe RPM.

Use a binder with a spine that can receive a labelidentifying the hard copies of the CIP. Plasticbinders that do not accept a spine label aredifficult to find in the Information Repository.

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Related Tools

Community Groups Community Interviews Community Profiles Communications Strategies Community Visioning

Facilitation/Conflict Resolution/ADR International Association of Public

Participation (IAP2) Translation Services Technical Assistance for Communities

Attachments

Attachment 1: Template for Developing a CIP WorkplanAttachment 2: IAP2 Spectrum of Public ParticipationAttachment 3: Templates and Models for CIPs

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Section 1 GOAL AND PURPOSE

A. Project goal and rationale:

B. The objectives to meet this goal are:

Objective 1:

Objective 2:

Objective 3:

Attachment 1:

TEMPLATE

for DEVELOPING a CIP WORKPLAN

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Section 2 GOAL AND PURPOSE

Position Name Email Telephone# Major Responsiblities

Section 3 TIMELINE OF ACTIVITIES

Timing Tasks Lead or Forum

Section 4 CONTACT INFORMATION OF INTERESTED PARTIES/PERSONNEL

Position Name Email Telephone# Resource for:

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Attachment 2:

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CICs at a number of sites have developed creativeand effective CIPs that reach key target audiencesand meet specific community involvement objec-tives. Here are a few examples:

Iron King Mine-Humboldt Smelter Site: ThisCIP earned the first “CIP of the Year Award” for2009. It is written to address two audiences: theSite Team and the community. It clearly communi-cates a key message from EPA to the community:We’re listening to you and we want you to beinvolved. Although this CIP is fairly comprehensiveand lengthy, notice that the key information andEPA’s involvement plan for the site are presentedup front, in the first 20 pages. This information ispresented in a very clear, simple, and user-friendlyway that clearly “speaks” to the community. Thedocument also meets the needs of the Site Teambecause it provides a clear road map for communityinvolvement activities and includes (in the secondpart of the document) much supporting informationand reference materials, including contacts lists,etc. (See http://yosemite.epa.gov/r9/sfund/r9sfdocw.nsf/3dc283e6c5d6056f88257426007417a2/f771fade9d9362d7882576f80078c62e!OpenDocument)

Harbor Island Area Superfund Sites:Lockheed West Seattle and Harbor Island/East Waterway CIP: The objective, audience, andcentral message of this short CIP couldn’t beclearer: It invites the community at three nearbySuperfund sites to participate in the cleanup processand is written to them as a fact sheet or newslettermailer. The headlines communicate that EPA askedcommunity members for input, listened to theirinput, and invites them to be involved in the deci-sion-making throughout the cleanup process—starting now, by inviting them to comment on thedraft CIP. All of the key elements of the CIP arethere. An easy-to-understand graphic shows aprojected timeline tied to the key milestones in thecleanup process at the sites involved. The plan tellsthe community how and when EPA plans to keepthem informed and involved throughout the cleanupprocess. Even though it is short, this CIP also meets

the needs of the Site Team by delineating a clearcommunications strategy/plan, and includes the keyinformation the Site Team will need to implement it.(See: http://yosemite.epa.gov/r10/cleanup.nsf/sites/LockheedWest/$FILE/lockheed_harbor_island_cip.pdf)

Hudson River: This is a comprehensive andcomplex CIP for one of the largest and mostcomplicated Superfund sites in the nation. This is a“living document” that revises the original CIP toaddress the changing situation and needs of thecommunity. The CIP presents a tremendous amountof information clearly, in a way that the Site Teamcan use. It appears to serve as a comprehensivereference document for the Site Team and thecommunity. (See http://www.epa.gov/hudson/cip.htm)

Foster-Wheeler Energy Corp./Church Rd.TCE Site using the Superfund AlternativeApproach (SAA): This CIP was written primarilyas a tool for EPA’s Site Team, but also is directed tothe community. This focus is clear throughout. The“Overview” section states that EPA will use theinformation to identify and address matters ofconcern, provide guidance to EPA staff, and helpensure community needs are addressed. The goalsof the CIP also are clearly stated: The Overviewindicates that the CIP is intended to encouragecommunity interest and participation throughoutEPA’s involvement at the site; initiate and supporttwo-way communication between EPA and thecommunity; and help ensure that communitymembers understand the Superfund cleanupprocess and the opportunities offered to them toparticipate in decision-making. The Communica-tions Strategy also is presented in a way thatspeaks primarily to EPA staff and is organized likea strategic work plan. Nevertheless, the informationprovided will allow members of the community tolearn about EPA’s community involvement plansduring the course of the cleanups at these sites.(See: http://www.epa.gov/reg3hwmd/npl/PAD003031788/cip2010/FWECCRTCE_CIP-FINAL.pdf)

Attachment 3: Templates and Models for CIPs

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