Attachment 5
Overview of Community Involvement Plan (Draft)

Note: The AFCEE/MMR Community Involvement Office has updated the 1993 edition of the Community Relations Plan/Public Involvement Plan. A draft of the updated Community Involvement Plan (CIP), dated December 30, 1996, was released on January 9,, 1997 for a 60-day public review and comment period. The CIP is currently undergoing revisions, and therefore, the information provided below is subject to change.

Introduction

Both state and federal Superfund laws have requirements for public involvement. In 1989, a public petition for public involvement resulted in the Massachusetts Department of Environmental Protection (MADEP) designating MMR as a Public Involvement Plan site. Also in 1989, the U.S. Environmental Protection Agency (USEPA) designated it as a Superfund site on the National Priority List, a listing of the nation’s worst hazardous waste sites. Under USEPA and MADEP regulations, MMR was then required to develop a Community Involvement Plan (CIP). The first version of the CIP was released in May 1991. Since then, the CIP has been, and will continue to be, revised on a regular basis to meet the needs of the community. The CIP will be reviewed, at a minimum, every two years to determine if it should be revised.

This CIP is designed to enhance the MMR Joint Public Involvement Plan/Community Relations Plan, which was last revised in June 1993 and endorsed by the USEPA and the MADEP. The CIP is a part of the Federal Facility Agreement (FFA) between the Air Force and the USEPA and was developed by the IRP Community Involvement Office in close coordination with the MADEP, USEPA Region I, and representatives from the office of the Deputy Assistant Secretary of the Air Force.

The purpose of the Plan is to ensure public participation and involvement in the decisions that affect the cleanup process of the IRP sites at MMR. This is being accomplished by actively listening to the questions, concerns, and needs of the community and by presenting information that is timely, accurate, and understandable. The CIP also demonstrates the Air Force’s belief that enhanced community involvement, as well as a greater public understanding of the cleanup process, will result in a better solution to the environmental problems at MMR.

Objectives

The CIP is designed to:

  • Document concerns regarding environmental contamination in and around MMR.
  • Respond to the concerns of the communities via specific activities.
  • Document opportunities the Air Force will provide for community members to be involved in and have an impact on environmental cleanup decision-making at MMR.
  • Further enhance partnering relationships with regulators and the community.

Community Interviews

The December 30, 1997 draft CIP is based on information gathered from personal interviews with stakeholders interested in and/or involved in the IRP. These community interviews were conducted to examine effectiveness of current communications activities, keep communication lines open, and update the CIP. The interviews enable the Air Force to understand the diverse interests and concerns of community members affected by the MMR cleanup and provide community involvement opportunities that most effectively fulfill the mutual needs of all interested parties.

Seveny-four interviews were conducted in the summer of 1996. Interviews were conducted by representatives of the IRP, DEP, and EPA with assistance from IRP contract staff. Interviewees included community members participating in various citizen teams, residents from areas surrounding MMR, regulators, local and state officials, base officials, members of the real estate and banking community, and others. Questions focused on current concerns, information needs, and feedback regarding improvements to the Community Involvement Program. The interview information was used to tailor the draft CIP and community involvement activities to respond to community concerns.

The interviews revealed five major areas of concern. Following are the major concerns and the IRP’s proposed actions in response:

1. Government Credibility/Lack of Progress

  • Interviewees expressed frustration with the length of time it is taking to solve the soil and ground-water problems at MMR.
  • Many people were skeptical about the Air Force’s ability and commitment to fully address contamination at MMR.

Response:

In May 1996, the Air Force Center for Environmental Excellence (AFCEE) took the lead management role and is moving forward with promised cleanup work (e.g., construction of treatment systems to contain and clean the plumes) at MMR. These actions will be based on technical decisions reached by taking the steps laid out in the MMR IRP Strategic Plan and attached cleanup schedule in coordination with AFCEE’s enhanced community involvement efforts. The Strategic Plan is being updated to include the plume response decision criteria and schedule. This unique process was designed to share detailed information on the technical evaluations of potential remedial alternatives and to solicit comments from the public. This process was developed in full cooperation with the state and federal regulatory agencies. It was also submitted for public review and comment before its adoption into the Strategic Plan or use as a decision-making tool.

2. Communications

  • Information coming from the IRP Office should be less technical and easier to understand.
  • Interviewees were concerned about the high number of meetings held in recent months and their lack of effectiveness.
  • Citizens need reassurance that their issues and concerns will be factored into any decisions made.
  • Interviewees expressed the need for community-wide awareness of IRP accomplishments.
  • The Air Force needs to respond to public inquiries in a timely manner.

Response:

The IRP Office is expanding its efforts to create materials that are clear and understandable for everyone. Some public information materials will be reviewed by the Public Information Team AFCEE/MMR, citizen team members, and expert facilitators have completed a comprehensive review process, examining the mission and goals of each team, modifying groundrules and planning procedures, modifying frequency and length of meetings, and setting a method by which to conduct future evaluations. This review process resulted in adjustments to the teams that reflect the challenging nature of the cleanup program and responsiveness to citizen concerns. Responsiveness summaries are produced for public comment periods and include all written comments received and the response to each. In addition, a special phone line has been established to log in citizen inquiries about activities in their neighborhoods and facilitate responses to them. AFCEE is examining ways to better communicate accomplishments of the IRP program. For example, the IRP Remediation Program Manager recently provided a verbal annual report about accomplishments, including miles of pipeline laid, numbers of wells drilled, and progress on construction of treatment systems. By encouraging participation and attendance of citizen team meetings, AFCEE/MMR seeks to listen and incorporate public concerns and comments into all phases of the decision-making process.

3. Health Issues and Risk Communication

  • Many interviewees were concerned that risks from environmental problems at MMR have not been fully communicated.
  • Several people support forming a new group to evaluate all of the public health information available.

Response:

AFCEE is engaging public health and communications experts to assist in clearly explaining the potential risks posed by MMR environmental problems. A working group of health and environmental and community involvement specialists from state, local, and federal agencies has been formed to share information to produce environmental health fact sheets. The group has produced its first fact sheet on the recreational uses of surface water bodies around MMR. Other fact sheets on risk-related issues will be produced by the workgroup and the IRP staff The Agency for Toxic Substances and Disease Registry (ATSDR) has established a citizen advisory committee called the Community Assistance Panel (CAP) to advise health agencies about health studies and to enhance communication of public environmental health concerns.

4. Economic Issues

  • Many interviewees feel ground-water plumes from MMR have negatively affected real estate values.
  • Several people were concerned that the installation of cleanup equipment could affect resale opportunities.

Response:

In order to maintain and restore property values, the Air Force is committed to contain and eventually clean up the ground-water contamination at MMR. Meanwhile, two policies, the Commonwealth of Massachusetts’ Good Neighbor Policy and USEPA’s Community Relief Policy, were developed to respond to local citizens’ concerns over potential effects of ground-water contamination from MMR on local property values. The policies state that owners of the land located over the MMR ground-water plumes will not be held financially responsible for the cleanup of the plumes. In those instances of unquestionable damage to property, information for filing claims against the government is available in the form of a fact sheet and claim application forms. In addition, the IRP Office will increase its efforts to share information with civic organizations and local real estate and banking representatives through speaking engagements, briefings, site tours, and direct mailings targeting this audience.

5. Other Concerns

  • Many interviewees expressed a need for a unified environmental planning function to consolidate authority and accountability for IRP and non-IRP activities.
  • Community group members are frustrated because a lot of time is wasted at meetings when the appropriate military parties are not present or are constantly referred to for concurrence and/or approval.

Response:

The IRP Office will seek to improve coordination and communication with the other organizations active at MMR and will maintain frequent contact with the newly-formed Joint Program Office (JPO), which oversees all environmental management efforts at MMR. The JPO will integrate and coordinate MMR environmental management and cleanup efforts, streamline the flow of information, facilitate decision making, and move towards solving the environmental issues at MMR in full partnership with the community.

Community Involvement Program Activities

Federal and state regulators require many community involvement activities that will inform and involve the public throughout the cleanup process. However, the CIP goes beyond the formal requirements governing community involvement by implementing supplemental activities to reach out to the community and address its needs.

Regulatory Requirements

  • Maintain an Administrative Record (located at the Falmouth Public Library) containing all documents upon which decisions are made.
  • Maintain Information Repositories (located at the five local public libraries) containing documents regarding the cleanup process.
  • Maintain a site mailing list.
  • Designate site spokesperson.

Review the CIP, at a minimum, every two years to determine if it should be revised, which includes citizen interviews as part of that process. Ensure that CIP reviews or revisions are conducted as appropriate as project design begins.

  • Develop a Proposed Plan for each site listing the alternatives for cleanup and the preferred remedy.
  • Conduct public comment periods to solicit public input for proposed plans.
  • Conduct a public meeting during the public comment period for each Proposed Plan.
  • Publish ads in newspapers of wide local distribution.
  • Prepare meeting transcript for any public meeting held during the Proposed Plan public comment period.
  • Prepare a Responsiveness Summary outlining all public comments received during a public comment period.
  • Provide a fact sheet and public briefing prior to the final engineering design before cleanup activities begin.

Supplemental Activities

  • Conduct additional public comment periods on key documents. Prepare responsiveness summaries of the comments submitted by the public and responses to them.
  • Conduct additional public meetings, posterboard sessions, neighborhood briefings, or other availability sessions during public comment periods to provide information on key documents.
  • Prepare information materials such as fact sheets, environmental updates, and news releases; make them available through regular distribution channels, the MMR IRP World Wide Web site, and a Geographic Information System.
  • Conduct speaker’s bureau presentations, which involve MMR team members attending meetings of community groups, to provide information to a wide range of audiences.
  • Offer site tours of the base and cleanup activities.
  • Sponsor citizen teams composed of representatives of the community, regulators, military, and local officials working together to reach decisions in the cleanup process.
  • Prepare neighborhood notices with details of significant off-base fieldwork activities.
  • Conduct availability sessions at local libraries or other public places to encourage the public to meet IRP staff, express concerns, and receive information.

This draft CIP conforms with requirements and guidance under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980, commonly known as Superfund, as well as the National Contingency Plan (NCP) and the Massachusetts Contingency Plan (MCP), which contains the regulations codified under the Commonwealth’s Superfund law, MGL Chapter 21E. The USEPA publication, Community Relations in Superfund: A Handbook (January 1992) was used as guidance in the development of this CIP. This CIP is consistent with The Final Report of the Federal facilities Environmental Restoration Dialogue Committee (April 1996), also known as the "Keystone Report."

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