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Protecting public health, welfare, and the environment from pollution is the EPA’s core purpose although, arguably, some populations have not always been equally protected. The EPA defines these “overburdened” populations as “minority, low-income, tribal, and indigenous populations or communities in the United States that potentially experience disproportionate environmental harms and risks as a result of greater vulnerability to environmental hazards.” Nationwide, evidence of such environmental damage still exists in the form of brownfields and Superfund sites, and the EPA is making EJ a priority for the future.
One of the most important aspects of EPA’s ongoing EJ efforts is that involving the permit application process. The goal is to bring permit applicants and communities together before permits are issued to address community concerns, build trust, and issue permits that meet the needs of all stakeholders. This effort is designed for those seeking EPA-issued permits and the affected communities, however, many other permitting agencies, tribes, and states also have similar programs.
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EPA’s primary EJ guidelines for permit applicants are contained in Promising Practices for Permit Applicants Seeking EPA-Issues Permits: Ways to Engage Neighboring Communities (Promising Practices). Although Promising Practices are not specifically required, they are designed to “help both the permit applicant and the surrounding communities get a reasonable return on their investment of time, energy, and other resources.” Moreover, the EPA says although the ideas were each actually implemented by permit applicants, each situation is different and may require a different set of practices, as determined by all stakeholders. EPA’s Promising Practices for Permit Applicants include:
1) Think ahead before starting community outreach activities. Consider things like geographic and demographic community information, any history of other outreach efforts, issues concerning the permitted pollutant in the community, possible facility changes, other local facilities with emissions, risk assessment information, and corporate sustainability and core values goals. In general, the greater the potential impact on the community, the greater the need for outreach during the application process. It is also very important to clearly understand the community and tailor those outreach activities most likely to engage community members.
2) Engage community leaders in a partnership relationship from the start. Many such leaders, whether elected or appointed, are often very experienced and knowledgeable, as well as familiar with how the community works, zoning and siting processes, and other related expertise. Collectively, they can provide a wealth of contacts, insights, and general assistance building networks and proactively engaging local environmental, faith-based, health, and other community groups with a stake in the process.
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3) Engage effectively and early to build trust and strengthen long-term relationships. Remember that relationships are between people, not between titles. Provide policy and planning documentation to the public, invite comments and provide feedback, progress report, and updates. Hold regular facility tours for the public and officials, and consider hosting public education workshops that are nontechnical to enable information sharing and effective discussion.
4) Communicate effectively by determining existing language barriers and the effectiveness of outreach options such as local media, social media, door-to-door, mail, and phone calls within the community. Some communities may have a high level of technology use while others may best be served by printed handouts and brochures. Most essential is keeping communications open and transparent. Practices include telephone hotlines, online options, appointing a community liaison, holding regular meetings that are convenient and comfortable, include question and answer sessions, and address stakeholder concerns in depth. If necessary, consider a neutral meeting facilitator to assist with the process and with meetings.
5) Follow-up is key to reinforcing relationships. Always discuss comments received, get clarification if needed, and explain why a comment is not included in the permit actions. Also consider a “good neighbor agreement” between stakeholders, proactively provide environmental performance data, and maintain relationships even after the permit is in place.
These are the building blocks for permit seekers to incorporate EJ in the permit process, and tomorrow we will review how the EPA is helping communities do their part as well.