Social Aspects of Siting RCRA 

Hazardous Waste Facilities

United States

Environmental Protection 

Agency

Solid Waste and

Emergency Response

(5305W)

EPA530-K-00-005

April 2000

http://www.epa.gov
Table of Contents

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

A Tale of Two Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Going the Extra Mile . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Environmental Justice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Environmental Justice at EPA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Environmental Justice and State/Local Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

What Are Quality of Life Concerns? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Location Concerns–Preserving the Community’s Use of Its Space . . . . . . . . . . . . . . . . 5

Nuisance Concerns–Preserving the Enjoyment and Value of Property . . . . . . . . . . . . . 5

Cultural and Social Concerns–Preserving the Community’s Sense 

of Belonging and Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Economic Concerns–Promoting Economically Sound Resource Protection . . . . . . . . . 5

Identifying and Addressing Quality of Life Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Identifying and Getting to Know a Community . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Recognizing Potentially Cumulative Impacts on a Community . . . . . . . . . . . . . . . . . . 9

Conducting Effective Stakeholder Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Enhancing Stakeholder Dialogue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Providing Technical Assistance Puts All Stakeholders on a Level Playing Field . . . . . . 12

Accelerating Progress by Learning from the Community . . . . . . . . . . . . . . . . . . . . . . . 13

A Checklist on Siting Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Resources for Further Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Introduction

It has been almost 20 years since EPA began the Resource Conservation

and Recovery Act (RCRA) hazardous waste permit program. During that time,

valuable lessons have been learned about how communities deal with siting

and permitting concerns. Although proposed hazardous waste facilities have

been granted or denied RCRA permits based on technical evaluations, some

businesses have succeeded or failed based on the level of communication and

trust built with the neighboring communities.

Local communities often have understandable concerns about why their

site was selected and how the facility will affect their quality of life. These

concerns encompass a broad array of issues that range from health and

environmental effects to social and economic impacts. Social and economic

issues are not evaluated during the RCRA permitting process, but this does not

diminish the legitimacy of the community’s concerns and the need to address

them promptly, honestly, and thoroughly when siting a facility.

EPA encourages facility owners and operators as well as state, tribal, 

and local governments to get to know and collaborate with communities from

the beginning of the site exploration process. Early collaboration can stimulate

creative solutions to concerns and facilitate site selection and permitting.

At the request of the Waste and Facility Siting Subcommittee of the 

National Environmental Justice Advisory Council (NEJAC), this booklet has

been developed for industries and for government agencies that interact with

communities when hazardous waste facilities are sited. It offers examples of

quality of life concerns raised by environmental justice communities when

facilities are sited. However, the primary purpose of this booklet is to share

experiences and creative mechanisms that have been developed in order 

to work effectively with communities, as well as encourage businesses and

government agencies to address community concerns early, collaboratively,

and compassionately. 
2

A Tale of Two Sites

The XYZ Company wants to construct a new

hazardous waste treatment facility.

• The company notifies prospective states in its

marketing region. It notifies the states’ environmental

and commerce agencies and holds a meeting with 

the agencies to discuss matters, including availability

of property.

• After narrowing options to three properties, the 

XYZ Company identifies and approaches key local

government and community leaders and requests 

an open meeting to introduce concepts and obtain

advice about local interests and sensitive social 

and environmental issues. 

• After investigating issues raised and exploring

potential remedies, the company turns again to the

state and local leaders, who call a public meeting.

• Prior to the meeting, the XYZ Company prepares 

a press release, establishes a liaison office, grants

interviews to the local press, and answers citizens’

calls.

• The XYZ Company announces the meeting with

posters, local newspapers and newsletters, and

through community groups and organizations.

• At the meeting, the XYZ Company displays information posters. It asks attendees to flag where they

live, work, or play. The meeting proceeds with 

a presentation and questions and answers. The

company asks for volunteers to serve on advisory

committees.

• Following the meeting, the company grants the press

another interview and mails letters to attendees

thanking them for their input, summarizing issues

raised, outlining future activities, listing volunteers,

etc.

• The company modifies its plans based on community

negotiations.

• Dialogue progresses and collaboration continues

through successful permitting, construction, and

operation of the facility. 

The ABC Company wants to construct a new

hazardous waste treatment facility. 

• The company begins by having someone scout

property in a county of the chosen state. 

• The company scout contacts commercial real estate

agencies and requests anonymity and confidentiality

as inquiries are made about taking options on land. 

• After finding an affordable site that appears to meet

company criteria, such as cost, environmental suitability, transit, and utility access, the ABC Company

takes out an option on the property.

• The local news media learn of the land option,

attempt to contact the ABC Company, obtain

secondhand information, and print a story.

• In response to the article, the ABC Company

contacts local government officials to confirm 

its interest. Government officials have already

received calls from citizens expressing concerns.

• The ABC Company and local government hold 

a public meeting to answer community questions.

• Attendees arrive at the meeting with a preconceived

notion of the facility and its impacts on the quality 

of community life.

• The meeting fails to communicate the ABC

Company’s information.

• Citizens begin writing their county commissioners, 

legislators, governor, and congressional representatives, seeking to block the facility’s construction.

• The ABC Company abandons its plans for the site;

the state agency is held responsible for the situation

and does not have the information to respond to the

Legislature and Governor’s Office.

It was the best of times... It was the worst of times...
3

Traditionally, businesses and government agencies involved in siting

know and strive to comply with regulations. But what incentives are there

to go beyond the “letter of the law”? 

As demonstrated in the “Tale of Two

Sites,” taking extra steps to work with

the community can benefit businesses

and government, as well as the community. By integrating the cultural/

social and economic needs of a

community into early site planning,

businesses and government can

encourage sustainable resources and

reduce the negative physical, social,

and economic effects of site activities.

By establishing partnerships with

communities–for example, through a

good neighbor agreement–businesses

and government can speed up the

permitting process and promote

constructive dialogue between

communities and businesses. 

Businesses that take the time to

find out about a community’s quality

of life concerns and engage the community in an ongoing dialogue may

• save on construction costs (it’s 

easier to redesign than to rebuild)

• reduce expenses of possible

litigation or enforcement

• speed up the permitting process

• build trust with the community

• discover innovative solutions to

problems.

Local agencies (e.g., zoning 

and planning departments, siting

boards, health departments) and state

government play critical roles in facility site selection: they are caretakers

of area resources, facilitators of

constructive community dialogue, and

protectors of the community’s health.

They are also creators and administrators of the community development

plan and permit decision makers. By

getting involved, state and local governments will find that

• soliciting public involvement is

“good government”

• stakeholders listen and respect their

views and ideas

• decisions are more likely to be

accepted and supported

• more informed and balanced policies and permit decisions are made

• innovative and more technically

sound solutions to siting and permit

issues are found

• public health and the environment

are preserved as well as citizens’

social and cultural welfare

• the risk of community-based 

legal action may be reduced.

Integrating a 

community’s

social character 

and needs

into site selection 

and planning can 

complement and

enhance RCRA

permit activities.

• A Sound Investment in Society

• A Smart Business Strategy

Going the Extra Mile

Early, Open Dialogue Can Prevent Legal Actions

Stakeholders may avoid drawn--out court proceedings if they

• seek out and address the social concerns of the community

• become involved in alternative dispute resolution and mediation 

when appropriate.

Mechanisms to Address Community Concerns

When facilities and agencies demonstrate that local citizens will share in the economic benefits of a facility, it

becomes easier to build trust and create dialogue. This can be done by hiring a local caterer for public meetings or

using local print shops for written materials. Once a facility is in place, it can continue to build trust by recruiting at

local high schools and colleges. Sometimes local job skills are mismatched with facility needs. Some facilities have

been successful by offering training courses to help local citizens develop the needed skills.
In recent years, national attention

has been focused on the concern that

minority and low-income communities carry a disproportionate share of

the burdens and consequences of the

siting of hazardous waste facilities

near or within their communities.

Research has shown that these communities have been disproportionately

chosen as potential sites for RCRA

facilities (Bryant and Mohai, 1992;

Bullard, 1994; United Church of

Christ, 1987). In addition, numerous

communities have raised such

concerns to EPA.

Environmental Justice 

at EPA

EPA is working to ensure that all

segments of society have a healthy

and safe environment. Executive

Order 12898, Federal Actions to

Address Environmental Justice in

Minority Populations and LowIncome Populations, helps to achieve

that goal. Executive Order 12898

directs federal agencies to make

achieving environmental justice part

of their mission by identifying and

addressing, as appropriate, disproportionately high and adverse human

health and environmental effects of

their program, policies, and activities

on minority populations and lowincome populations.

Environmental justice communities

also lack access to information and

government or business decisionmakers. To correct this situation, 

EPA conducts outreach, works with

communities, and encourages all

stakeholders to work collaboratively

to address social and economic

concerns as part of their activities.

Many years of experience have led

EPA to conclude that community concerns are best addressed when government agencies or companies make

early and proactive efforts to understand the nature of community concerns and address them. This can be

best accomplished if there is a robust

understanding of the often complex

range of social and economic factors

that accompany disproportionate and

adverse environmental impacts.

Environmental Justice 

and State/Local Programs

Tribal, state and local environmental agencies also are working to

address environmental justice issues,

partly as a result of responsibilities

under their own laws and under Title

VI of the Civil Rights Act of 1964.

Under Title VI and EPA’s implementing regulations, recipients of EPA

financial assistance may not take

actions that are intentionally discriminatory or have a discriminatory effect

based on race, color, or national

origin.

Historically, siting boards, zoning

and permitting agencies, and industry

have often not considered such factors

as quality of life and aesthetic,

historic, cultural, economic, or social

impacts. Although ecological and

health impacts are generally considered by environmental agencies, the

evaluations may not be oriented

toward the issues confronting minority

and/or low-income communities. In

particular, they may fail to consider

the cumulative nature of such impacts.

EPA firmly believes that addressing

quality of life concerns represents an

important part of good business and

good government. Siting boards,

zoning and permitting agencies, and

industry can greatly enhance the

quality of all programs. Although

these concerns are often most pronounced in environmental justice

communities, they are by no means

limited to such communities. Quality

of life is a universal concern of all

communities, regardless of race,

income, culture or level of education. 

For further information on

environmental justice, see

• Executive Order 12898, Federal

Actions to Address Environmental

Justice in Minority Populations 

and Low-Income Populations,

http://www.epa.gov/docs/

oejpubs/execordr.txt.html

• EPA’s Office of Environmental Justice

activities, http://es.epa.

gov/oeca/main/ej/index.html

• EPA’s Office of Civil Rights, on ensuring compliance with nondiscrimination

laws, http://www.epa.gov/

civilrights/extcom.htm

• EPA’s Office of Solid Waste

Environmental Justice website,

http://www.epa.gov/epaoswer/

osw/ej/index.htm

4

Environmental Justice

“...fair treatment for people of all races, cultures, and incomes, regarding the

development and execution of environmental laws, regulations, and policies.”

–U.S. EPA Environmental Justice Grants web site. http://es.epa.gov/oeca/oej/epagrantoffer.html

Additional reading

Bryant, Bunyan and Paul Mohai. (1992)

Race and the Incidence of Environmental

Hazards: A Time for Discourse. Boulder,

CO: Westview Press, 1992.

Bullard, Robert D., ed. (1994) Unequal

Protection: Environmental Justice and

Communities of Color. San Francisco:

Sierra Club Books.

United Church of Christ Commission for

Racial Justice (1987) Toxic Wastes and

Race in the United States: A National

Study on the Racial and Socio-Economic

Characteristics of Communities Surrounding Hazardous Waste Sites. New York:

United Church of Christ.
“Our quality of life outweighs the

business profit.” This is a common

sentiment expressed by communities

being considered as potential hazardous waste facility sites. Each community (and even each stakeholder)

defines quality of life differently.

“Quality of life” is difficult to define

and measure but is critically important

to communities involved in RCRA

hazardous waste siting and permitting.

Location Concerns–

Preserving the Community’s

Use of Its Space

How near a facility is to homes,

parks, schools, retirement centers,

hospitals, and other public areas

where people live, work, garden,

learn, and play can be a concern.

Residents and other community

members want to know about

• exposure to hazardous substances

through air, water, soil, and food 

(for example, garden vegetables)

• the likelihood of exposure to 

sudden, accidental environmental

releases.

Facility-related vehicle traffic

could present a problem to a nearby

community if transportation routes are

through “sensitive” community areas

(e.g., schools). Concerns include

• threat of spills

• proximity of primary evacuation

routes to facility

• incidental exposure to sudden

releases

• exhaust from idling trucks.

Nuisance Concerns–

Preserving the Enjoyment

and Value of Property

Some hazardous waste facilities

can present nuisance concerns to a

neighboring community such as noise

and odors that 

• decrease outdoor activities 

• discourage development of 

neighboring property 

• devalue surrounding land and 

personal property.

Air emissions can be a nuisance

when they deposit on homes, automobiles, and laundry and impair scenic

views.

Citizens may also be concerned

that a facility will change the look of

their community for the worse.

Cultural and Social

Concerns–Preserving the

Community’s Sense of

Belonging and Security

How the community uses its land

(e.g., fishing, gardening, or cultural

purposes) is important to know. For

example

• Do they garden in the area or fish

in nearby streams, thus increasing

their exposure to potential toxic

releases by eating contaminated

food?

• If so, do they depend on this food

for sustenance or income?

• Will the facility deny or eliminate

their access to social activities

linked to land use? Disturbing 

or denying access to areas may 

be viewed as an attack on the

community.

• Will the facility affect or diminish

culturally and socially significant

areas (e.g., sacred sites, historic

structures)? 

Economic Concerns–

Promoting Economically

Sound Resource Protection

Communities want to improve 

their economy and, therefore, are

sensitive to the impact of new businesses on local human, economic, 

and natural resources.

• Will RCRA facilities devalue 

residents’ investment in their

community and discourage future

investors?

• Will new development bring new

employment that does not match

residents’ job skills?

• Will the new facility displace

people from existing jobs?

• Will the community feel it has lost

economic value while others have

gained?

5

What Are Quality of Life Concerns?

Quality of Life reflects the values a community places on its cultural, social, and natural resources.

Local residents strive to preserve those resources for current and future generations. Businesses and

state and local governments should recognize and respect these often intangible values and integrate

them into their planning.

Mechanisms to Address Community Concerns

At some facilities, real estate tools that can quantify the effect of a RCRA facility on housing value have been used

for properties bordering the facilities. Agreeing to compensate homeowners if housing values are reduced can be a

powerful way to alleviate quality of life and environmental justice concerns.
An open dialogue among stakeholders is required to identify and

address community quality of life

concerns. Dialogue helps to develop

an understanding of the core issues of

all parties involved and facilitates the

exchange of information so that

stakeholders can make informed decisions. Although public meetings are

required during the prepermitting and

permitting phases under the RCRA

Expanded Public Participation Rule, 

it is always best to approach communities and address their concerns as

early as possible, preferably in the

initial stage of the process. Because

community concerns vary greatly,

solutions will vary; this is why it is

important to get to know the community and its concerns before proceeding with siting plans.

Identifying and Getting 

to Know a Community

The starting point for effectively

communicating with a community is

to give the community the opportunity

to define itself. At the same time,

initial research should include gathering background information to identify issues and conditions affecting

that community.

A basic knowledge of who the

community is and what helps shape

the community may suggest ways to

approach and work with the community.

Many types of information may 

be reviewed to better understand who

community members are and what

shapes their community:

• maps of community boundaries 

for residential and commercial use

• demographics, including education

level, culture, and languages

spoken

• existing use of the land

• existing traffic patterns

• emissions from existing industrial

sources

• environmental permitting history 

of the community (not just RCRA)

• identification of key community

members and institutions (e.g.,

local health and community centers, schools, religious institutions).

Some of this information is available through local, state, and federal

agencies. However, such data serve

only as an introduction to the community. RCRA facilities operate within 

a real-life context. To know and

understand the real issues requires

getting to know those who live there. 

Community Layout–Understanding the layout of a community is

important to understanding the community itself. Maps can provide information on geologic and environmental

considerations, planned types of

development, property owners, natural

and man-made features, and neighborhood/town/city layout. However,

communities may define themselves

in cultural and social terms. For

example, people who attend a place 

of worship near a proposed RCRA

facility may be considered part of the

community even though they do not

live there. Thus, maps can be useful

tools on which citizens can define

areas of concern.

Community History and Values–

Community members may have

strong feelings about past decisions

on land use. For some communities,

their quality of life has been deeply

impacted by these historical events

and decisions. It is therefore critical to

gain an understanding of these issues

from the community’s standpoint.

In addition, each community has a

unique set of values that is based on

cultural traditions, geographic location, personal dynamics, and local

institutions. These values need to be

understood and respected in order to

understand what “quality of life”

means to each community.

6

Identifying and Addressing Quality of Life Concerns

EPA strongly encourages tribal, state, and local permitting agencies to provide the most effective 

and constructive opportunities for all stakeholders to communicate concerns, exchange information, 

and reach mutually acceptable understandings as early as possible.

Mechanisms to Address Community Concerns

Providing amenities packages, including landscaping, lighting, and local park areas, may address some basic concerns

of community members with regard to the proposed RCRA facility. In addition, facilities have provided health

services in response to local health needs independent of discussions of site impacts on local health.
Demographics–A community’s

demographics includes variables such 

as age, income, language, education,

population, ethnicity, household size,

and employment status. A study of

these factors will reveal information

about social and economic conditions

as well as the cultural basis for some

of the community’s concerns and

needs (e.g., high level of unemployment or fixed-income populations).

Identifying ethnic and socioeconomic

characteristics of a potentially affected

community may be helpful in determining if there are potential environmental justice considerations. Such

research is also helpful in developing

an outreach strategy. Mapping systems can be used to identify potential

environmental justice areas by overlaying demographic, land use, permitting, and environmental data. 

Identification of Populations with

Health Sensitivities–Sensitive people

are those that show an adverse effect 

to a toxic substance at lower doses or

show more severe or more frequent

adverse effects after exposure than the

average person. Biological sensitivity

may result from age (e.g., children),

gender (e.g., lactating females), genetics, dietary and health deficiencies

(e.g., calcium deficiency), or other

factors. There is concern that releases

from or activities associated with

RCRA facilities may increase risks to

sensitive populations. Although the

state of scientific knowledge and

regulatory consideration of these

issues is still evolving, it is prudent to

identify areas that are being used by

sensitive populations such as schools,

hospitals, recreation areas and unofficial playgrounds, and address possible

impacts on their users. Possible risks

to these sensitive people can be minimized or avoided entirely if the issues

and facts are fully understood and

considered before making final

decisions.

A geographic information system (GIS) is an excellent tool for overlaying information

on maps to make comparisons and gain a greater understanding of a community.

See the following web sites 

for information on sensitive 

populations:

• U.S. Census Bureau, American Fact

Finder (facts such as age distribution,

education,and ethnicity, etc. about

specific geographical areas).

http://factfinder.census.gov

• National Institute of Environmental

Health Sciences. http://www.

niehs.nih.gov

• National Toxicology Program (NTP)

Chemical and Safety Data (information

on different chemicals and the hazards

that they may pose). http://ehis.niehs.

nih.gov/ntp/docs/chem_hs.html

• HazDat Database (information on

hazardous waste from Superfund 

sites and its effects on communities).

http://www.atsdr.cdc.gov/

hazdat.html

• National Center for Health Statistics

(various health statistics from across the

country). http://www.cdc.gov/nchs

• State and Local Health Departments.

http://www.cdc.gov/other.htm

• U.S. EPA’s Sociodemographic Data

(used for Identifying Potentially Highly

Exposed Populations). http://www.

epa.gov/ncea/sociodeg.htm

7
Identification of Potentially Highly Exposed Populations–Some populations can experience greater risk

than the general population through

higher than average exposure. Potentially highly exposed populations can

be identified by factors such as

geographic area of residence, age,

gender, occupation, commuting patterns, lifestyle, race or ethnic origin,

income level, or other demographic

factors. Exposure and risk among

these populations may differ from that

of the general population as a result 

of cumulative exposure from multiple

sources or pathways, food consumption patterns, or behavioral or cultural

factors. Although much anecdotal and

circumstantial evidence suggests that

some subgroups may be more at risk

from environmental pollution than the

general population, little direct evidence exists on actual exposures and

risk levels for other than a few specific chemicals or physical agents in the

environment.

Many factors—both social and

environmental—make it difficult to

identify patterns or clusters of adverse

health effects that can take significant

time to become apparent. Existing

exposures (especially cumulative

exposures) may not have been

assessed previously or their effects

observed. Thus, it is important to

consider a community’s existing condition and activities before selecting a

site. Communities with data that indicate relatively high incidences of noncommunicable disease (e.g., asthma),

cancer, infant mortality, low birth

weight, or birth defects may be concerned about the impact of a future

RCRA facility. However, communities whose current data on cumulative

exposures, risks, and disease rates are

incomplete may also be concerned

about the addition of a new facility.

Responding to community concerns

about these issues may involve additional data collection, assessment, and

discussion, including identifying

opportunities for reducing existing

exposures in potentially highly

exposed populations. 

Land Use–Official land use generally planned and governed by the

tribal government, the local county,

the city, or town may give permitting

agencies and RCRA facilities information on the character of the community that residents wish to develop.

However, zoned or planned land uses

may not show how different parcels

of land are actually used. 

A clear understanding of land use

areas in a community requires a threestep process

1. Examine zoning/planned use and

actual use. A community’s use of

its space is not always based on

property lines, zoning areas, and

plans. Customs, religion, language,

nation of origin, race, education,

and social standing can be important factors that indicate how a

community uses its space.

2. Examine customary uses (e.g.,

local fishing, gardening, and

sacred/cultural sites). Representatives of permitting agencies and

facilities should talk to community

members and/or periodically visit

locations near the site to determine

what activities are taking place.

8

EPA has developed a number of environmental databases 

that may be helpful when assessing cumulative impact:

• Resource Conservation and Recovery Act Information System (RCRIS)

• Toxic Release Inventory (TRI)

• Biennial Reporting System (BRS)

• Comprehensive Environmental Response, Compensation and Liability Act

Information System (CERCLIS)

• Aerometric Information Retrieval System (AIRS)

• Permit Compliance System (PCS) in the Wetlands, Oceans, and Watersheds (OWOW) and Storage Retrieval Database (STORET)

Data on existing community health and environmental conditions are an

important input to cumulative risk assessment. The data should be used

as a tool to alert the assessor to subgroups that may experience greater

exposures than the general population. The data also should be used to help

the assessor determine the number of individuals who may be subjected to

increased exposures. When possible, assessors are encouraged to collect

site-specific data to help confirm if any groups are experiencing high exposures. A comprehensive risk analysis method must also be used to properly

characterize the effects of cumulative exposure.

For additional information, visit EPA’s database website at

http://www.epa.gov/epahome/dmedia.htm
3. Understand the community’s

visions and values for the future.

Through contact with the community, representatives should also

determine what values the community places on the land. For example, siting a hazardous waste facility in certain areas may change the

character of rural or agricultural

communities because of the types

of roads, sewer designs, and waterline changes needed for suburban

development.

Zoning–The choice of locations

for siting RCRA facilities is limited

by local zoning and planning decisions; this may also limit possibilities

for addressing or resolving some of

the community concerns. Although

local zoning decisions must be

respected, additional factors may need

to be considered to determine the

appropriateness of a site for hazardous waste facilities:

• Determine existing and potential

community concerns.

• Involve local governments in 

decision-making dialogue.

• Allow local governments to

suggest alternatives based on the

community’s long-term plans.

• Consider the effects of industrial

growth on the community.

• Consider the potential for environmental justice issues.

Recognizing Potentially

Cumulative Impacts 

on a Community

Existing permitted and nonpermitted activities and potential polluting

sources may be of concern to the

community. To identify these activities

• Examine the history of all permitted activities in the area (not solely

RCRA permitting), including the

environmental history. 

• Ask the community about the relative burden of existing facilities.

• Consider the location of these

sources relative to the community, 

particularly sensitive areas such as

neighborhoods, schools, and public

areas or where there are high rates

of infant mortality, cancer, and

asthma, for example.

• Look beyond the potential/

proposed site. Be aware of the

potential impacts from other

stationary and mobile sources. 

• Learn how the community uses its

space.

• Consider all information, not just

technical impacts.

• Talk to the community to understand its concerns and record its

oral history of the community’s

health (e.g., their perspective on

the incidence of asthmatic children

or cancer mortalities).

9

Mechanisms to Address Community Concerns

Memoranda of Understanding or Good Neighbor Agreements reassure communities that quality of life commitments

will be honored. When these agreements are drawn up to be legally enforceable, they promote trust between the

community and facility because the community is secure in knowing that protective actions cannot later be ignored.
10

To understand the character and

concerns of a community, establish a

strong interaction with the community

prior to the RCRA permitting process.

Going beyond the minimum required

interactions between agencies, facilities, and the public can be advantageous. Promoting productive and

ongoing dialogue and addressing

stakeholder concerns can greatly

smooth any environmental permitting

process by reducing conflict, delays, 

and permit challenges.

Important elements of effective

communication include understanding

the following:

• how the community communicates

with its members and others

• how the community gets its information (e.g., church bulletins,

ethnic radio, ethnic or local paper,

word of mouth, and languages

commonly used).

Enhancing Stakeholder

Dialogue

Communicate Early–EPA strongly

encourages permit applicants and

authorities to reach out to communities in advance of site selection and

permit filing. Often, notifying the 

public and holding hearings after a

site has been chosen and technical

design decisions have been made

provokes distrust among communities,

industry, and permitting authorities.

Early, honest communication develops

credibility for all parties and can 

lead to cooperative problem solving

instead of stand-offs and delays. 

During the Initial Phase–Community members offer a variety of useful

information that may influence siting

decisions: 

• historic land uses (official and

unofficial)

• existing environmental conditions

• conflicting land uses (e.g., use 

of a stream for fishing, use of a

vacant lot for community vegetable

gardening)

• vision of sustainable uses of land,

water, and air resources

• acceptable alternatives or modifications to proposed plans

• religious, cultural, or other special

values of the land. 

As a result, facility plans are less

likely to encounter opposition and be 

delayed because of permit challenges.

During the Design Phase–Design

issues that may benefit from community involvement include

• facility risk management plan

• visibility and buffering of site

• location of outfalls (if any)

• hours of operation

Conducting Effective 

Stakeholder Communication

Resources for effective outreach and communication include 

the following:

• The Model Plan for Public Participation. EPA National Environmental Justice 

Advisory Council. Contact EPA Office of Environmental Justice. http://es.epa.

gov/oeca/oej/nejac/publicat.html

• American Society for Testing & Materials (ASTM) Standard Guide to the Process 

of Sustainable Brownfields Redevelopment. (ASTM Standard E-1984-98). 

Contact ASTM Subcommittee E50.03. http://www.astm.org

• RCRA Public Participation Manual. (EPA 530-R-98-007). Contact the RCRA Information Center. http://www.epa.gov/epaoswer/hazwaste/permit/

pubpart/manual.htm

• Improving Dialogue with Communities: A Risk Communication Manual for 

Government. New Jersey Department of Environmental Protection. 1988.

• Public Participation and the Environment: What Works. Caron Chess and Kristen 

Purcell, 1997. Center for Environmental Communication, Rutgers University, 

31 Pine Street, New Brunswick, NJ 08901-2883.

• Constructive Engagement Resource Guide: Practical Advice for Dialogue Among

Facilities, Workers, Communities, and Regulators. (EPA-745-B-99-008). June 1999.

Contact EPA’s National Service Center for Environmental Publications.

Mechanisms to Address Community Concerns

During and after the permitting process, communications can become strained. It pays to discuss and agree upon

protocols for communication early to avoid delays due to disputes. For instance, parties might agree to have a trained

facilitator or mediator present during discussions.
• inclusion of pollution prevention 

activities

• truck routing – community knowledge of congested areas and alternate routes. 

Businesses may be concerned

about incurring open-ended costs if

they promise to address quality of life

issues not addressed by regulation.

Such concern can be alleviated by

working with communities to define

and prioritize quality of life issues that

are most important and agreeing on a

schedule for resolution. Likewise, any

compensation agreements can be

defined and their limits set. 

Build Trust–As a result of past 

siting decisions, a history of distrust

has built up in many communities,

leaving some feeling burdened by

industrial facilities. To overcome the

legacy of distrust, permit applicants

and permitting agencies must seek to

begin and develop a dialogue with the

community very early in the siting/

permitting process. Effective steps

would be to 

• Approach the community early 

in the process.

• Respond to community concerns

and explain clearly how concerns

will be addressed (e.g., routine

releases, spill response, truck

operating hours).

• Arrange open houses and tours for

neighbors at hours fitting community needs.

• Hold events, such as training

sessions, dinners, or picnics, to

bring plant employees together

with members of the community.

• Annually review the status of

relations with the community to

ensure the facility is addressing

any concerns related to protection,

resources, rights, and lands.

• Obtain annual feedback from the

community on how the facility is

performing environmentally.

• Annually review state or local

agency’s performance to ensure

that the facility fulfills its obligations.

• Maintain an open and accessible

channel of communication with the

community.

Keep the Dialogue Open–Developing trust through early dialogue is

only the beginning. To maintain

communication

• meet regularly to ensure that

everyone understands the issues 

• be honest

• be direct and open

• respond to all comments

In addition, a Community Advisory

Panel (CAP) that reflects local diversity can be formed. CAPs can provide

insight and external input and may

oversee administration of amenities or

compensation agreed upon 

as part of siting discussions. For

instance, a CAP might be formed to

administer funds allocated for planning, education grants, or job training

programs.

Hold Effective Public Meetings–

Effective public meetings inform and

address the concerns of community

members. Such meetings also send a

message to community members that

they have a part in the actual decisionmaking process. Goals are best

achieved when community organizations cosponsor the meetings and help

establish the meeting’s goals, agenda,

and outreach. To ensure effective

meetings

• Engage a facilitator who is experienced or trained in working with 

communities and in addressing

environmental justice concerns.

11

There is no doubt in my

mind that when a neighborhood or community becomes

informed and involved, they

will do a far better job of

deciding what is right for

their children, for their air,

for their water, than any

government agency. 

–EPA Administrator Carol Browner

http://www.epa.gov/docs/oejpubs/

strategy/strategy.txt.html

Central objectives of an 

effective communication plan:

• Build trust

• Keep the dialogue open

• Hold effective public meetings

• Devise effective outreach methods.

Mechanisms to Address Community Concerns

An industry may agree to provide pull-off areas for trucks so they don’t have to idle in line, increasing exhaust

emissions. Agreements can also be arrived at with the community concerning truck routes, truck traffic, and turning

off motors.
12

• Include an assortment of tools that

attendees can use to share their

concerns, such as maps with colorcoded pins, handouts, brief surveys, and individual comment

cards.

• Where possible, arrange seating to

promote an atmosphere of equal

participation. (This might mean

having community members at the

head table, or even avoiding the

head table layout entirely.)

Public meetings are often designed

so that many members of the public

are given time to speak and raise

questions. More constructive, however, are meetings designed so that

members of the public can engage in

substantive dialogue with agencies

and permittees. During these meetings

• Break out into small discussion

groups to facilitate productive

discussion.

• Reassemble all attendees so that

small groups can report their views

to everyone.

Devise Effective Outreach Methods– Communities, agencies, and

other stakeholders may have different

ideas on what constitutes public participation. An agency or industry may

feel that it has fulfilled its public participation obligations while the potentially affected community may not. To

ensure effective public outreach

• Schedule meetings at convenient

times and locations for community

members.

• Announce meetings through

community channels, such as

church bulletins and local papers.

• Announce meetings in common

languages.

• Provide easy-to-understand information to community members.

• Provide publications and speakers

in the appropriate languages other

than English.

Providing Technical

Assistance Puts All

Stakeholders on a Level

Playing Field

Community members can readily

become legitimate participants when

they understand the issues at stake,

their roles, and the regulatory processes. Individuals responsible for informing and responding to the community

should have the appropriate knowledge, training, and ability to provide

clear explanations of technical issues.

They should 

• Inform the community of technical 

and legal considerations by using 

understandable terms, familiar 

language, and similar experiences.

• Explore what type of information 

needs to be made available to the 

public and how that information 

is to be presented, including

languages other than English.

• Provide information on regulatory

processes, technology performance,

and stakeholder rights. 

• Present relevant technical and regulatory information available from

RCRA facilities and permitting

agencies as simply as possible—in

a language people will understand.

• Collect and maintain pertinent

technical information in a publicly

accessible place, such as the local

public library or community center.

Independent Consultants–Under

some circumstances, the community

may require impartial independent

technical assistance to ensure unbiased, informed opinions and information. Many case studies report successes when grants are awarded for

this purpose. Success is attributed to

• creating the same degree of

credibility as other stakeholders

• lowering frustration levels, because

consultants can “translate” community quality of life concerns into

terms that are commonly used

within the siting or permitting

process.

Community Monitoring–After the

facility is permitted and constructed,

some communities have obtained

resources to perform their own emissions monitoring. This type of monitoring is comparable to the “riverkeeper” concept used in water quality

scenarios. At first the idea may make

Mechanisms to Address Community Concerns

Keeping the doors of communication open is a two-way process. One effective mechanism for communication is 

a facility newsletter that informs community members about RCRA facility-related information, such as accidental

releases, site tours, community outreach programs, and emergency response procedures.

Permitting can progress with strong community support when public outreach

and participation are carefully planned and implemented from the beginning.

Community participation and consent can be critical to business development.

For example, a city’s community development agency can build a neighborhood working group to meet periodically in open meetings to discuss prospective business plans. The working group can identify and report its concerns and

call on the city and business to implement actions. Once the city and prospective businesses negotiate or agree on what’s to be done, the site’s development

and permitting may move forward with stronger public support.
the facility uncomfortable, i.e., turning

over monitoring to the public, but it

may be worth the time invested to

promote good community relations.

Councils of Government–Local

councils of government are good

resources for providing planning

guidance and identifying consultants 

(if independent technical assistance is

sought by the community).

Accelerating Progress 

by Learning from the

Community

Agencies and permittees must

recognize that community values and

feelings are a legitimate aspect of

environmental health issues. Residents

are often very aware of subtle changes

that take place around them. Ignoring

factors that influence public perceptions of risk, labeling them as irrational, or discounting public concerns

may lead to hostility between community members, the facility, and the

permitting or siting agency. Public

trust can disintegrate if it appears that

community concerns are not being

taken seriously.

Agencies and RCRA facilities

often focus on risk-based technical

information from monitoring data,

reports, and risk assessments; yet the

public may be more likely to take 

into account public perceptions and

cultural values. For instance, the

threat of loss of enjoyment and the

potential devaluation 

of their property resulting from

nuisances may be as serious and as

important as health concerns to a

community. A community may also be

uncomfortable with the “look” of the

facility—it may not fit with how residents view their community’s general

appearance. 

13

Address the fundamentals

❐ Integrate cultural/social and

economic needs of a community

into early site planning

❐ Establish partnerships with

communities

❐ Take time to find out about 

a community's quality of life

concerns

❐ Learn about environmental

justice programs that may apply

at the site

Be prepared to answer questions on

❐ Routine environmental exposure

❐ Threat of spills and likelihood 

of exposure from accidental

releases

❐ Evacuation routes and alternate

routes

❐ Noise and odor

❐ Influence on outdoor activities

❐ Influence on development 

of neighboring property

❐ Devaluation of surrounding land

and personal property

❐ Gardening and fishing activity

nearby—recreational or subsistence

❐ Effect on property of cultural and

social significance

❐ Displacement of existing jobs or

potential for new jobs and skills

match

Collect information on

❐ Community boundaries—

residential and commercial

❐ Demographics

❐ Education level of residents

❐ Cultural background and values 

of residents

❐ Actual land use

❐ Relative burden of existing facilities, e.g., existing emission sources

and cumulative impacts

❐ Environmental permitting history

❐ Key community members and

institutions

❐ Existing contamination information

❐ Areas used by high-risk populations (schools, hospitals, recreation

areas)

❐ History of all environmentally

permitted activities

❐ Oral history of community’s health

❐ Location of sites of special cultural, religious, or historical importance

Develop effective communication plan

based on

❐ How the community members

communicate with each other

❐ How the community gets its

information

❐ Building trust with a two-way,

open dialogue, responding to all

comments and questions

❐ Holding effective public meetings

❐ Early on, devising and using 

an effective outreach strategy

❐ Providing technical assistance 

to community members

❐ Reaching out before site selection

A Checklist on Siting Facilities

Analytical methods are being developed to help incorporate quality 

of life concerns into a technical

decision-making framework. Local

universities may be able to provide

researchers familiar with the application of these methods.
Resources for 

Further Information

For further information on the 

environmental justice and public 

participation issues discussed in this

brochure, see the following sources:

Publications:

Chemistry Cleans Up A Factory,

New York Times, July 18, 1999.

Executive Order 12898, Federal

Actions to Address Environmental

Justice in Minority Populations 

and Low-Income Populations

http://www.epa.gov/docs/oejpubs/

execorder.txt.html.

Community Advisory Panels within

the Chemical Industry: Antecedents and Issues, F. Lynn and C.

Chess, Business Strategy and the

Environment, Summer 1994, 3, 

Pt. 2, pp. 92-99. An examination of

potential problems with corporate

CACs, based on research on government citizen advisory committees.

Industry Relationships with Communities, C. Chess and F. Lynn, in 

K. Fisher et al. (eds.), The Greening of Industry Network: Resource

Guide and Annotated Bibliography

(Washington, DC: Island Press,

1996), pp. 87-110. A discussion of

the relationship between the chemical industry and communities,

including mediations, community

advisory committees, and good

neighbor agreements.

Interim Guidance for Investigating 

Title VI Administrative Complaints

Challenging Permits

http://es.epa.gov/oeca/oej/

titlevi.html

Telephone Contacts:

• Office of Solid Waste, Permits 

and State Programs Division 

(703) 308-8404

• RCRA Hotline (800) 424-9346 

(TDD 533-7676)

• Office of Environmental Justice 

(800) 962-6215

• RCRA Information Center 

(703) 603-9230

Web Sites:

• Environmental Justice

http://www.epa.gov/oeca/main/

ej/index.html

• Office of Solid Waste

http://www.epa.gov/epaoswer/osw/

index.htm

• Envirofacts (RCRIS, AIRS, etc.)

http://www.epa.gov/enviro/

index_java.html

• Environmental Atlas

http://www.epa.gov/ceisweb1/

ceishome/atlas

• Technical Outreach Services 

for Communities (TOSC) 

http://www.toscprogram.org/

• U.S. Department of Justice, 

Civil Rights Division

http://www.usdoj.gov/crt/

• USEPA, Office of Civil Rights,

http://www.epa.gov/civilrights