RE: EPA's evolving role - communication is a two-way street.

[Emily Green <emily.green@sierraclub.org>]

I'm Emily Green - Great Lakes Program director for the Sierra Club.  Jerry, I'm glad you raised the issue of risk communication as a two-way street, as it was one I wanted to discuss as well.

As Jerry's examples show, the two-way street can and has worked very well.  However, I think we are still challenged by it, particularly at some of our more complex sites where stakeholders may have a number of diverse interests in the site and its outcome.  Some of these interests cannot be measured as threats to human health or as direct costs, and thus do not fall under Superfund's primary considerations.  This can make them difficult to factor into a decision.

We have a lot of contaminated sites in the Great Lakes, including a large number of contaminated aquatic sites, from the historic concentration of heavy industry in the region.  As we struggle to address these sites, there's been increasing emphasis on managing the risks posed by a site.  This can lead to a whole range of decisions at a site, including leaving it alone (where there is no perceived exposure of people to the contamination), closing it off to people to limit exposure, or cleaning it up to minimize or eliminate the risks.  While some decisions may "adequately manage risks" from an agency's human health perspective, they may be unacceptable to a segment of the community for other reasons.  Some issues that may be critically important to a community but difficult for an agency to include in a risk management decision, such as cultural values and preferences, may not be adequately considered.  

I don't necessarily have an answer for this, but some of the things that I think are important for agencies to do include:

1)  Actively engage the public/local community from the beginning of a project, even at the problem identification stage.  As Jerry noted, people are sometimes a wealth of information about local sites and are a resource that should be tapped.  This also helps build the trust and relationships necessary to engage in future discussions about risk and cleanup decisions.  This necessitates a greater up-front investment in time and money for public involvement.  However, the pay-offs in information, cooperation, and increased trust will likely be well worth it in the end.

2)  Develop some means of soliciting and considering all perspectives.  For example, the cultural importance of eating locally caught fish for some tribes should be considered as a reason to clean up contamination in a waterway.  These types of preferences cannot be directly incorporated into a risk assessment and cannot be assigned a monetary value.  However, this does not make them any less important and we must find some way of considering them.

3)  Provide communities with as much information as possible, presented in terms that are relevant to the community and their concerns.  People are very capable of understanding risk decisions if given enough information.  I know of at least one site where people were actually offered a day-long training on risk assessment.  While it can be difficult to get that type of time commitment from people at every site, in this case it worked well and gave people the information they needed to participate in site cleanup decisions.