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Community Relations Plan, August 1999
Section 6 - Public Involvement Plan
In general, it is best to implement public involvement activities while relations with the community are good. At a minimum, activities required by regulations should be carried out to address the community members� needs. Public participation in the corrective action process is required to begin upon completion of the RCRA Facility Investigation (RFI) and Corrective Measures Study (CMS). The details of the RCRA Corrective Action Process and the associated documents required by the EPA can be found in Appendix A.
In addition, information gathered during the interviews regarding the best way to provide information to the community should be taken into account. Based on the information presented in Section 5 of this plan, four objectives were developed for the CRP at CSSA:
| Provide the community with information; | |
| Establish two-way communication between CSSA and the community; | |
| Respond to community concerns and needs that arise for environmental activities; and | |
| Provide for citizen input and involvement. |
These objectives will guide the community relations activities. Under each objective, the techniques employed to ensure that the community is properly informed and included in the process is discussed.
6.1 - Provide the Community with Information
6.1.1 Administrative Record/Information Repository
The Administrative Record is a file that is maintained and contains all the information and reports used as a basis of the corrective action. The Environmental Encyclopedia will be the Administrative Record for CSSA. Establishment of an administrative record is a required activity.
A duplicate copy of the Administrative Record will be made readily accessible for public review at the main branch of the San Antonio Library, 600 Soledad Plaza, San Antonio, TX 78205. This library has a reference section that includes Administrative Records for other military facilities in the San Antonio area. The Ed Cody and Boerne libraries were also contacted, but these libraries opted not to house the record. A copy of the administrative record will also be maintained at CSSA.
Fact sheets and newsletters are an effective way to inform the public of CSSA�s mission and describe environmental activities at the installation, two information needs cited during the interview process. Possible fact sheet topics include: the history of the environmental program at CSSA, a description of current projects and findings, and state and federal regulation that pertain to environmental projects.
Information releases in the form of fact sheets can be prepared on a quarterly basis. A mailing list will be used for informing interested parties of environmental activities. This mailing list will be maintained and updated periodically through community surveys and questionnaires distributed by the Public Affairs Office. Public news releases can be used to advise interested parties of the content of materials as they are added to the libraries for public viewing. All information releases or fact sheets will also include the name, address, and telephone number of a CSSA representative responsible for inquiries about CSSA environmental activities.
Mailing lists are both important databases and essential communication tools. Mailing lists ensure that concerned community members receive relevant information. An initial mailing list for CSSA will be developed by sending out questionnaire postcards to area residents. These postcards will include a brief description of the environmental program at CSSA. Recipients will be asked to return the postcards to CSSA if they are interested in being on the mailing list. The mailing list will also include the people who indicated that they wanted to receive more information during the August 1999 interviews. In addition, the mailing list will include media representatives, city and county officials, state and federal agencies with jurisdiction over wildlife resources, and key regulatory agency officials. Furthermore, newspaper notices will invite people to be added to the mailing list so that they will receive any public notices or other information disseminated during the corrective action process.
An introductory notice explains the corrective action process and the opportunities for public involvement in that process. Although an introductory notice is not required, it may be an appropriate way to initiate community relations activities at CSSA. An introductory notice would help to acquaint community members with the RCRA process, opportunities for public involvement, as well as the fact that an environmental program exists at CSSA. This introductory notice could be a public notice in local newspapers, a fact sheet, or a flier distributed to the facility mailing list. A contact person should be identified in the notice so that interested community members can call this person if they have questions.
The contact person is one designated staff member who is responsible for responding to questions and inquiries from the public and the media. General inquiries and information requests should be directed to Lt. Colonel Ernest N. Roberson, Jr., CSSA Commander, 25800 Ralph Fair Road, Boerne, Texas, 78015, Telephone: (210) 698-5208. The Public Affairs Officer from Fort Sam Houston, Mr. Phil Reidinger, will support Lt. Colonel Roberson responding to inquiries from the public. Appendix C, Key Contacts, lists the key CSSA and regulatory personnel involved in the corrective action process.
A Statement of Basis (SB) will be prepared which summarizes the information contained in the RFI and CMS reports. The SB is designed to facilitate public participation in the remedy selection. The SB will be placed in the administrative record so that it is available for public review and comment.
Public notices provide an official announcement of proposed decisions and provide the public with the opportunity to comment on the proposed decision. A public notice is required after the CMS has been completed and a cleanup alternative is proposed. A notice and brief analysis of the SB will be published and appropriate documents will be made available to the public for review at the local information repository. Sufficient information will be included in the notice and analysis to provide a reasonable explanation of the proposed remedy and a list of the remedial alternatives analyzed during the CMS (refer to Table 6.1 for an outline). The notice and analysis will be published, at a minimum, in a major local newspaper of general circulation. The notification will also be sent to facility mailing list recipients. Appendix D, Media Contacts, lists local newspapers which will carry all public notices.
Table 6.1 - Newspaper Notification Content Summary
| The newspaper notification should include the following: |
| Facility name and location |
| Date and location of public meeting (if scheduled) - If a meeting has not been requested or scheduled, the notice will inform the public of its right to request one. |
| Public participation - The notice will inform the public of its role in the remediation selection process and provide the following information:
|
| Identification of a proposed remedy |
| Alternative remedies evaluated in the CMS |
| Request for public comments - The notice will emphasize that the agency is soliciting public comment on ALL of the corrective measure alternatives, as well as on the proposed remedy. It will include a clear statement that the proposed remedy is only a preliminary determination and that other options could be selected as the remedy based upon public comment, new information, or a reevaluation of existing information. |
6.2 - Establish Two-Way Communication Between CSSA and the Community
CSSA may give presentations or hold informal discussion about cleanup activities at scheduled meetings of organized groups in the surrounding communities. These presentations, or informal discussions, can be used to explain operational procedures that ensure protection of workers and other parties potentially affected during environmental activities and to explain the goal, constraints, and progress of the program. Various community involvement alternatives including development of a Remedial Advisory Board (RAB) or a Technical Review Committee will be discussed and considered. Groups interested in such presentations/discussions should contact Lt. Colonel Ernest Roberson, Jr., CSSA Commander, at (210) 295-7416.
6.3 - Respond to Community Concerns and Needs that Arise for Environmental Activities
CSSA will respond to concerns and questions from citizens or groups. A contact point where written inquiries may be directed has been identified in Section 6.1.5. Each question or comment will receive a telephone response with written response to follow, if requested, within 10 working days from the date of receipt.
6.4 - Provide for Citizen Input and Involvement
Public meetings will be held to facilitate two-way discussions between regulators and the community, if necessary. In the event that significant interest is expressed during the public comment period, a public meeting may be held to facilitate community participation. These meetings will be advertised in the local newspapers, and through invitation to people on the mailing list. Meetings are not recorded for the public record.
A public comment period is a designated time period in which citizens can formally review and comment on the proposed course of action or decision. A public comment period is required before corrective measures can be implemented. Upon publication of the SB for CSSA, a public comment period will be held to allow comment on the proposed remedy. The public comment period will last 45 days.
6.4.3 Response to Comments/Responsiveness Summary
A response to comments identifies changes to the SB and the reasons for the changes. It also briefly describes and responds to all significant comments received during the public comment period. The response to comments is written in a clear and understandable style so that it is easy for the community to understand how public comments were considered. Following the public comment period for the SB, a responsiveness summary will be compiled which lists all of the comments received and the responses to each.