Capacity Building Report

V. OBSERVATIONS AND CONSIDERATIONS FOR MOVING FORWARD

A. Numerous Opportunities Exist to Build Local Capacity
B. The Need to Involve the Public in Shaping Capacity Building
C. The Need to Address Lack of Public Confidence In and Inaccessibility of EPA Processes

The needs assessment interviews, viewed in light of the relevant literature and capacity building models, point to several considerations that EPA and the public should take into account in efforts to move forward on building the capacity of local communities to participate in EPA activities.

The interviews indicate that opportunities for building the capacity of local communities to participate are ample and range widely in scope and content. Some are small and incremental, such as improving EPA mailing lists. Others are more expansive and fundamental such as creating a cadre of information brokers to work with communities or ombudsmen to advocate for communities within the Agency. Capacity building efforts can also include effective traditional approaches, such as increasing the convenience of meetings and the use of mailing lists. In addition, newer approaches, such as using the Internet to disseminate information and pursuing more collaborative approaches to participation such as the Common Sense Initiative, can build capacity by increasing access to information and technical assistance. The plethora of approaches and suggestions offered by interviewees and represented in many capacity building models that already have been tested does not solve the challenge of determining how to focus EPA’s capacity building efforts, but it is encouraging that communities have many ideas as to how to move forward.

Moreover, there was considerable agreement as to the basic components of capacity building. For example, information was described, in a variety of ways, as the most important aspect of local capacity building. Furthermore, in-person delivery of that information, also described in a variety of ways, was viewed as the best mechanism for achieving the dissemination of the information. In addition to in-person delivery of information, other approaches emerged with broad support, as discussed in section III above. Thus, despite the wide range of approaches for addressing the needs highlighted by the interviews, several starting points for moving forward on capacity building are evident, as described in section VI on next steps.

In any step forward on local capacity building, public involvement in developing these efforts will be crucial to both their acceptance and effectiveness for several reasons. First, the capacity building needs of various stakeholders may vary; therefore, public input is necessary to understand the range of these needs and how to prioritize and address them. Second, capacity building efforts will only be effective if they are supported and welcomed by the communities that they are intended to assist. If capacity building initiatives and approaches are developed independently by EPA or with a limited group of stakeholders, they will not have credibility and are likely to be less effective. Third, public involvement in developing an approach to capacity building can serve to build confidence in EPA processes and, therefore, may help to chip away at a serious barrier to capacity building efforts, the public's skepticism about EPA’s true interest in community concerns.

If not addressed, community concerns about EPA’s fundamental approach to public participation may interfere with capacity building efforts. As discussed above, a key impediment to capacity building is the perception among stakeholders that their participation is futile because EPA does not listen to their perspective and sometimes has already decided how to resolve issues before considering their input. While this perception does not directly address the capacity to participate per se, if communities choose not to participate even when they have the capacity to do so (e.g., information and technical assistance), capacity building efforts will not produce increased levels and quality of participation. A concerted effort to address this lack of confidence in EPA’s public participation processes may help to facilitate capacity building efforts.

This lack of confidence and trust in EPA processes could be addressed in part by clearly defining the role of the public in each decision or pending action. The failure to do so can result in a disconnect between EPA's and the communities' expectations with respect to the communities' role in public participation processes. While some constraints on the use of public input may be dictated by statute or regulation, in many cases EPA is likely to have considerable discretion as to how to involve the public and incorporate stakeholder views into Agency decisions. To the extent that a community role can be clarified and communicated to the public before a proceeding begins, confidence in participation processes may be increased. This approach is consistent with the Report of the Common Sense Initiative Council's Stakeholder Involvement Workgroup, which recommended a "process model for early planning of stakeholder involvement" that would, among other things, "ensure that when involvement techniques are chosen, EPA staff members will have set clear goals and know what they are hoping to accomplish with the public. . . ."[69]

Furthermore, providing timely and more extensive feedback to communities about whether and how their input was used by EPA could help ensure citizens that the Agency is listening to them even if their views are not adopted. When EPA does not provide adequate feedback to stakeholders that participate, it is easy for the participants to assume their views were not taken into account if the Agency did not adopt their positions. EPA has recognized this problem in its Stakeholder Involvement Action Plan: "[I]t might not be clear how the [stakeholder involvement] activities contribute to actual Agency decisions. This can lead to frustration as participant expectations do not concede with Agency actions."[70]

In order for EPA to determine an effective role for the public in specific proceedings, the Agency may need to step back and examine more broadly and comprehensively the purpose of pubic participation in general and the appropriate role for the public in the many different types of decisions that the Agency makes. EPA is in the process of developing a set of principles for public participation as part of its Stakeholder Involvement Action Plan that may help toward this goal. It is essential, however, that EPA involve the public in an early and clearly defined manner in the process of developing its principles. Otherwise, the principles are less likely to be accepted by the public and serve their intended purpose of facilitating EPA's participation efforts.

Finally, overhauling EPA's public participation processes in an effort to make involvement less burdensome and more accessible could make capacity building efforts far easier. A common concern among interviewees was the time and energy that is required to participate in EPA activities. Ways to make community participation easier range from fundamental reforms – such as developing entirely new processes that allow for community input in a more efficient manner – to improving current approaches such as stepping up efforts to make documents more readily available in communities and holding meetings in convenient locations. In addition, the perception that EPA staff are inaccessible, overly bureaucratic, and uncomfortable working with communities continues to be an impediment to capacity building. Again, this concern could be addressed through a wide variety of approaches ranging from training phone operators in how to direct calls from the public to new programs that use community members or staff trained in community outreach to disseminate information from EPA.

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