New EPA Draft Manual for Meaningful Public Participation in RCRA Action
20 years in the making, a comprehensive update to this seminal 1996 resource has been published as a draft open for public comment
The Resource Conservation and Recovery Act (RCRA) is the principal federal law at work in the disposal of solid waste and hazardous waste in the U.S. You may have never heard of RCRA before, but it is foundational legislation that governs many aspects of day to day life for us all.
RCRA amended the Solid Waste Disposal Act of 1965 and set national goals for protecting human health and the natural environment from the potential hazards of waste disposal. The RCRA program is implemented at all levels of government—by EPA, by state agencies and by local governments to protect our built and natural environments from the threats of solid and hazardous waste. RCRA cleans up land and water and conserves resources. RCRA also empowers community members by delivering information and opportunities that enable communities to participate in decision-making processes.
But how do you build a foundation for successful public participation?
EPA’s release of a draft workbook, the 2016 Draft RCRA Public Participation Manual, explains how to implement public participation activities throughout the RCRA permitting and corrective action processes. There are many public participation activities required by federal RCRA permitting regulations, and the manual details them all. This “How To” guide describes the many advantages of public involvement and breaks down how RCRA public participation works and how community members, regulators, and industry can cooperate to make it even better.
EPA believes that all stakeholders in RCRA permitting actions have a role in providing for meaningful public participation. Brownfield Listings also believes strongly that each stakeholder group—regulators, public interest organizations, community members and regulated facilities—can take steps to increase participation, improve communication and develop better outcomes. The robust draft manual details activities that EPA hopes will empower all stakeholders to maximize their role in the process and contribute in driving overall success for everyone involved.
The manual also describes a wide assortment of activities to enhance public participation, highlights the use of digital and social media, provides a guide to integrate public participation into the permit modification process, and incorporates lessons learned and best practices. It provides detailed descriptions for dozens of public participation techniques—required and optional, formal and informal. These invaluable tips for opening up dialogue with other stakeholders, for assessing communities and being sensitive to their concerns, and for planning public participation strategies can help drive constructive public engagement.
The draft 2016 edition of the draft RCRA Public Participation Manual gives specific details and describes each step in the permit decision-making process, from the pre-application stage through the application stage, the preparation of the draft permit, and the final permit design in the RCRA permitting process. The manual also includes information on public participation during the life of a permit and permit modifications, as well as information on closure and post-closure at both permitted and interim status facilities.
The manual provides an overview on public participation in corrective action, including special considerations for public participation activities under section 3008(h) orders, as well as:
initial site assessment (i.e., RCRA Facility Assessment or RFA)
site characterization (i.e., RCRA Facility Investigation or RFI)
evaluation of remedial alternatives (i.e., Corrective Measures Study or CMS)
remedy implementation (i.e., Corrective Measures Implementation or CMI)
completion of remedy
This comprehensive 196 page draft RCRA Public Participation Manual provides background and information on public participation plans, and how to assess the community to plan for participation. This rich public resource also provides checklists for Environmental Justice Public Participation and other public participation activities.
EPA has published this resource for public and professional comment. The agency hopes to receive input about specific enhanced approaches, as well as innovative projects that will facilitate public participation and address the perception of diminishing public interest.
Your input will assist EPA in updating the 1996 edition of the RCRA Public Participation Manual to make it relevant in today’s climate. You can provide input by submitting your comments to RCRAPPM@epa.gov by Friday, September 9, 2016.