Community Relations in the Site Remediation Program

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.

What is Community Relations?

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.

Why should I consider a Community Relations Program?

Remediation Applicants who distance themselves from the public create mistrust and often encounter resentment in their community. Initiating a community relations program will:

  • Facilitate obtaining property access agreements, if needed, and provide for successful negotiations with adjacent property owners and local governments, and
  • Alert the Remediation Applicant to community concerns and problems with the site, and may even provide factual information about the site not readily available.

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.

How will I know if a Community Relations Program is needed for my site?

Any of the following site-related conditions indicate a probable need for community relations activities:

  1. An actual, perceived or imminent threat to public health;
  2. Nearby residential areas, schools, parks, day care facilities, senior citizen centers, churches, or other areas where there are community functions;
  3. A contaminant release into a forest preserve, park, river, lake or other public property;
  4. A history of accidental spills, fire, explosion, complaints from the community, or regulatory violations.

What are the components of a Community Relations Plan(CRP)?

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:

I. CRP Long Version

A. Site Description

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.

B. Community Issues and Concerns

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.

C. Community Relations Program

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:

  1. Small group meeting to discuss the investigation and listen to EWN concerns;
  2. Telephone or e-mail contacts with group leaders; and
  3. Fact sheets and letters sent to EWN on investigation milestones with copies mailed to news media and others on the mailing list.

Suggested Length: Two to three pages.

D. Contact List

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.

Who Prepares the CRP?

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.

II. CRP Short Version Sample Plan

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, 2010

ABC Warehouse
Huntsville, Illinois

A. Site Description

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.

Contaminants of Concern

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.

B. Community Issues

  1. Children's Safety. There are two safety issues involving children. First, during the sampling and remediation, some of the security barriers will be removed. Consequently, curious children may seek entry to the building. The school officials will need to be updated on all work so they can advise parents of school children to make sure that children avoid the site. Second, children frequently bicycle or walk to the Washington Grade School. Truck traffic to the site should be planned away from the school route as much as possible, and a fact sheet about the site work should be developed for parents of the school children.
  2. Drinking Water. Four private drinking water wells are located within 800 feet of the site. One of the city’s three public water supply wells is located within one-half mile of the site. The direction of groundwater flow and extent of any on-site groundwater contamination has yet to be determined. Solvent contamination may migrate to groundwater and threaten private or public wells.

C. Community Relations Activities

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:

  1. Contact the Mayor's Office, school administrator, county health department, director of the Johnston County Senior Citizens Center, and the Huntsville Police Department to discuss our remediation plans and building security and to answer questions.
  2. Contact adjacent property owners, and if sufficient public interest exists, contact local news media.
  3. Conduct a preliminary environmental assessment of the site to identify any contaminant spills or leakage that would warrant further soil and/or groundwater sampling.

When remediation commences, we will:

  1. Provide schedule to Mayor’s Office, school administrator, county health department, police department, adjacent property owners, and to any other interested citizens, such as the administrator for a nearby senior citizen facility.
  2. Provide all contacts with updates of significant changes to the plan and/or schedule of site activities. Provide a project summary when the action is complete.

D. Contact List

  1. Government Officials:
    • Mayor and Clerk, Huntsville
    • Police Department
    • County Board Chair and Clerk
    • School Administrator, Huntsville
    • County Health Department Administrator
    • Illinois EPA
    • Illinois Department of Public Health
    • State and Federal Elected Representatives
    • Contractors for Remediation Applicant
  2. Interested and Affected Citizens:
    • All adjacent property owners
    • Senior Citizen Home Director
    • Chamber of Commerce or Economic Development Director
    • Civic Groups
    • Environmental Groups
  3. News Media:
    • Print
    • Electronic - T.V. and Radio

Where can I get more information?

You are encouraged to contact:

Illinois Environmental Protection Agency
Office of Community Relations
1021 N. Grand Avenue East
P.O. Box 19276, mail code #5
Springfield, Illinois 62794-9276
Tel: 217/782-7027, Fax: 217/785-7725
email: Brad Frost