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EPA Stakeholder Involvement Action Plan
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December 1, 1998
EPA STAKEHOLDER INVOLVEMENT
ACTION PLAN
PURPOSE
EPA has learned a tremendous amount in recent years about the value and benefits of stakeholder involvement(1) in environmental decision-making processes. The Agency has taken steps to increase opportunities for, and the quality of, stakeholder involvement in its regulatory and non-regulatory programs, and these efforts have yielded valuable results for all parties involved. However, feedback and experience from past stakeholder involvement processes reveal key issues that need to be addressed to improve such processes in the future. These issues are as follows:
- Some stakeholder involvement activities appear to be conducted because they are considered "a good thing" but it might not be clear how the activities contribute to actual Agency decisions. This can lead to frustration as participant expectations do not coincide with Agency actions.
- Because EPA's regulatory, non-regulatory, and voluntary program activities have become more extensive and interwoven, there is not always an understanding of the type of stakeholder involvement that is most appropriate in a particular situation and the model selected might not produce the type of results that are needed.
- Given the increased number of stakeholder involvement activities, some outside groups and interests find that it is difficult to commit the time and resources needed for effective participation in all of the activities to which they are invited. The result is difficulty recruiting stakeholder representatives for some activities.
- Planning and managing effective, ongoing stakeholder involvement activities requires skills that many EPA staff members have not developed as highly as their scientific or technical skills. Similarly, the Agency's data management infrastructure does not always adequately keep pace with needed support for stakeholder involvement.
The purpose of this Action Plan is to enhance stakeholder involvement at EPA, building on the lessons learned throughout the Agency. It does not represent a departure from past efforts; instead, it describes an evolution. The difference that will result from the Plan will be a more thoughtful and skillful approach to our stakeholder involvement efforts - tailoring the activity to the need more effectively and ensuring that the resources devoted to stakeholder involvement activities, by EPA and other participants, are well spent. The Action Plan is based on recommendations to the EPA Administrator by the Common Sense Initiative (CSI) Council and draws upon a report produced by a CSI Council Workgroup. Although the driving force for development of this Action Plan was a Federal Advisory Committee, the actions for improving EPA's stakeholder involvement attempt to build on the work and lessons learned from a broad range of Agency programs. The Action Plan will form the basis for an Agency-wide strategy to share lessons learned, new tools, and better planning processes for working more effectively with EPA's stakeholders.
BACKGROUND
In November 1997, participants in EPA's CSI Printing Sector Subcommittee raised stakeholder involvement issues in a presentation to the Council. Similar issues had also surfaced during the work of the other CSI sectors. The Council decided to form a Workgroup to further define and examine stakeholder involvement issues and to suggest solutions to the Council and EPA. The Workgroup was composed of representatives from industry, environmental and environmental justice groups, labor, state and local government, and EPA. It gathered information from outside sources and EPA's program offices on their stakeholder involvement activities, and concluded that "integration" is the greatest need for enhancing EPA's stakeholder involvement programs. Integration means:
- First, EPA stakeholder involvement needs to be clearly linked to decision-making and should not be viewed as an end in itself.
- Second, careful front-end analysis is necessary to determine what kind of stakeholder involvement is needed in each situation and to ensure that stakeholders are involved in ways that will provide the greatest value both to the Agency and the stakeholders.
- And third, EPA stakeholder involvement programs need to be part of a coherent network that involves all media offices so that lessons learned and information acquired in one program can be communicated to other programs.
The Workgroup presented its Report on EPA Stakeholder Involvement(2) to the Council at the June 1998 CSI meeting. The report included recommendations in three areas, all of which were endorsed by the CSI Council:
- Use Common Vocabulary and the Typology of Stakeholder Involvement Techniques to Build Common Understanding Among Participants. Use a common vocabulary to describe the terminology associated with stakeholder involvement. Use the Typology of Stakeholder Involvement Techniques (see Attachment A) as a guide to build common understanding of the purpose of and techniques used in stakeholder involvement, as well as the role of those participating. Development of this common understanding is important because participants in a process develop expectations based on the words used to describe the process. Use of a common language with terms that are understood by all will enhance communication and ensure that all participants have a clear understanding of their roles and the goals of the activity. It will also facilitate integration of the concepts of stakeholder involvement into the core business of the Agency.
- Use Analytical Tools to Enhance Effectiveness. Use analytic tools, such as the Process Model for Early Planning of Stakeholder Involvement (see Attachment B), to plan appropriate stakeholder involvement activities and to integrate stakeholder involvement with decision-making. In some cases, this will require training and guidance to EPA and the states. These tools will assist EPA staff members in setting clear goals for what they hope to accomplish with stakeholders as well as in deciding who needs to be involved, when and where in the process they need to be involved, and how their comments and ideas will be incorporated in decision-making.
- Establish Coordinating Mechanisms to Build Internal and External Capacity. Establish coordinating mechanisms to ensure that (1) EPA employees have the information, skills, resources, and tools they need to carry out stakeholder involvement and (2) stakeholders have the capacity to participate effectively.
The information that follows describes specific actions that are underway or being planned to implement the recommendations in the Report and to enhance stakeholder involvement activities across the Agency.
ACTIONS
A. Enhance Planning and Management of Stakeholder Involvement Activities
The specific actions in this area are intended to refine the processes used to plan and manage stakeholder involvement activities so that they will be more closely targeted to the anticipated results in addition to being consistent with existing laws and regulations. By focusing on the objectives of the stakeholder involvement activity and the decisions or other Agency actions the stakeholder input is designed to affect, resources can be applied more cost-effectively and expectations of participants can be met. Actions in this area are also intended to enhance the management or operation of these activities by further exploration of lessons learned and evaluation of stakeholder involvement activities. It is also important to share learning tools with and get input from our state partners, tribes and other stakeholders.
ACTION A(1): Develop Agency-wide principles for stakeholder involvement.
Although EPA recognizes that there is no "one-size-fits-all" approach to stakeholder involvement, Agency-wide principles can provide useful guidance to those planning these activities.
Lead: Bruce Engelbert, Office of Solid Waste and Emergency Response, 703-603-8711
Schedule: Initiate Fall 1998
ACTION A(2): Encourage use of a common vocabulary, the typology of stakeholder involvement techniques, and a process model for early planning of stakeholder involvement to improve understanding among stakeholders.
In the past, confusion has arisen over what stakeholder involvement entails in specific situations because people use the terms differently. When different participants have different expectations, frustration can result and the results of the activity can suffer. An EPA manual currently under development, "Better Decisions Through Consultation and Collaboration", will include additional information on the use of common vocabulary, an expanded Typology of Stakeholder Involvement Techniques (Attachment A), and an expanded Process Model for Early Planning of Stakeholder Involvement (Attachment B). The Model contains a series of questions that assist the user in deciding whether a stakeholder involvement program is needed and what type; selecting the participation techniques that will be used; and organizing the stakeholder involvement effort. Use of this Model will be encouraged through management briefings and staff training.
Lead: Deb Dalton, Office of Policy, 202-260-5495
Schedule: Winter 1999
ACTION A(3): Establish a mechanism for identifying when Federal Advisory Committee Act (FACA) committees (either new or existing) are appropriate vehicles for stakeholder involvement, and establish a mechanism for strategically managing the Agency's advisory committees.
FACA advisory committees are an excellent tool for the Agency to use to obtain group input from stakeholders. An advisory committee, however, is not an appropriate vehicle for all stakeholder involvement activities, for example, when the goal is information exchange or obtaining individual stakeholder input. EPA's current advisory committees have arisen largely through a series of ad hoc decisions, resulting in little connection between the committees and no overarching strategic vision for linking their purposes, processes, or products. This action is intended to help EPA identify when advisory committees are appropriate, and to acquire more integrated, timely, and effective committee advice on the issues of greatest importance to the Administrator and the Agency.
Lead: Bob English, Office of Cooperative Environmental Management, 202-260-5995
Schedule: 1998-99
ACTION A(4): Establish a roster of facilitators and mediators experienced in environmental stakeholder involvement and dispute resolution processes, and increase the number and flexibility of contracting mechanisms for accessing external facilitators.
One of the key lessons learned from evaluations of CSI and other stakeholder involvement efforts is the importance of neutral facilitators to the success of the process. More contentious issues and programs that require consensus are in particular need of expert facilitation. In general, EPA is not in a position to serve as a neutral facilitator, since it usually has a position on the issue in question. Although trained facilitators within EPA might be included, the roster will focus on external facilitators with proven capability and also reflect cultural, racial and geographic diversity. EPA currently has contract mechanisms for accessing external facilitators, but they need to be more easily available.
Lead: Deb Dalton, Office of Policy, 202-260-5495
Schedule: 1998-99
ACTION A(5): Examine lessons learned from stakeholder involvement experience and use this information to improve EPA stakeholder involvement programs.
Several actions are designed to increase our understanding of factors that contribute to successful stakeholder involvement programs. The results of these studies will be used to improve EPA's planning, management, and operation of stakeholder involvement efforts.
A(5)(a) Distribute the report on the survey of stakeholder involvement in EPA rulemaking, which is being completed by a graduate fellow. Distribute to EPA's Regulatory Policy Council, Steering Committee, and Program Offices.
Lead: Deb Dalton, Office of Policy, 202-260-5495
Schedule: Dec. 1998
A(5)(b) Conduct a telephone survey to learn how other federal agencies or other suggested organizations plan and carry out their stakeholder involvement work. Integrate findings as appropriate into this Action Plan.
Lead: Kathleen Bailey, Office of Reinvention, 202-260-3413
Schedule: Fall 1998
A(5)(c) Look at pilot testing innovative approaches to stakeholder involvement in developing broad-based, multi-media environmental agendas.
Lead: Kathleen Bailey, Office of Reinvention, 202-260-3413
Schedule: Initiate Fall 1998
A(5)(d) Devise performance measures to evaluate improvements in stakeholder involvement. Evaluate progress periodically.
Lead: Katherine Dawes, Office of Reinvention, 202-260-8394
Schedule: Initiate 1998
B. Enhance Internal and External Capacity for Stakeholder Involvement
Internal Capacity Building
As stakeholder involvement becomes a routine part of many EPA staff members' jobs, there is a need for training and information resources to help them develop new skills and obtain information needed to plan and manage these programs. The actions in this area are intended to build the internal capacity of the Agency to support stakeholder involvement.
ACTION B(1): Compile a directory of Internal Experts in Stakeholder Involvement at EPA, and post it on internet and intranet sites.
This action is designed to create a resource for EPA staff who have responsibility for planning or conducting stakeholder involvement activities.
Lead: Margaret Morgan-Hubbard, Office of Communications, Education and Media Relations, 202-260-5965
Schedule:1998-99
ACTION B(2): Establish a network of staff across the Agency working in stakeholder involvement.
This action will work in tandem with Action B(1). The network will provide opportunities for interaction among those with stakeholder involvement responsibilities. This network will provide a forum for sharing of experience and lessons learned, serve as a resource to those within the Agency establishing new stakeholder efforts, as well as serve as a feedback mechanism for improvements and new ideas. Meetings will be held on an ad hoc basis.
Lead: Kathleen Bailey, Office of Reinvention, 202-260-3413, and Elaine Koerner, Office of Communications, Education and Media Relations, 202-260-2623
Schedule: August 1998
ACTION B(3): Provide further opportunities for developing this network through the EPA-Wide Community Involvement Conference.
The EPA-Wide Community Involvement Conference was held for the first time on August 3-7, 1998; past conferences had focused only on Superfund. Approximately 300 EPA employees participated. It provided opportunities for EPA staff to share experiences and ideas across program offices on stakeholder involvement. Planning for the May 24-27,1999 conference is underway.
Leads: Tom Tillman, Office of Pollution Prevention, 202-260-7605, and Toxics, and Arty Williams, Office of Pesticide Programs, 703-305-6467
Schedule: Spring 1999
ACTION B(4): Publicize the availability of stakeholder involvement resources within the Agency.
EPA has developed stakeholder involvement resources that could be very useful to Agency staff who are planning or managing stakeholder involvement activities. The purpose of this action item is to make these resources more readily identifiable and available. Specifically, EPA will set up an intranet site for stakeholder involvement materials, sharing best practices/lessons learned, posting events and outreach information, staff contacts and networks, and links to other intranet and internet sites. It will also publicize the availability of assistance from external experts in managing stakeholder involvement processes.
Lead: Kathleen Bailey, Office of Reinvention, 202-260-3413
Schedule: Initial setup September 1998
ACTION B(5): Build and maintain an Agency-wide database of stakeholder organizations and representatives interested in environmental and human health protection.
This action will provide a database of interested stakeholder groups as well as pertinent information that will help Agency staff identify those who would be potentially relevant for a specific stakeholder activity. This database might relieve some of the demand on certain stakeholder groups that are routinely asked to participate in EPA stakeholder involvement programs, and open the process to additional organizations.
Lead: Margaret Morgan-Hubbard, Office of Communications, Education and Media Relations, 202-260-5965
Schedule:1998-99
ACTION B(6): Organize and Conduct EPA Reinvention Conference/Training
Incorporate successful stakeholder involvement strategies into the 1999 Reinvention Tech Transfer Series, which is being planned to explain and share innovations with EPA managers and staff at headquarters and in the regions.
Lead: Sandy Germann, Office of Policy, Economics, and Innovation (OR), 202-260-5410
Schedule: Spring 1999
External Capacity Building
In addition to expanding the capability of EPA to carry out effective stakeholder involvement programs, this Action Plan seeks to assist external stakeholders in participating meaningfully in Agency decision-making activities.
ACTION B(7): Create project or program-specific guidance materials
While there are some general principles that apply to most stakeholder involvement, it is useful to create more specific guidance materials for particular projects or programs. While many of these have already been created and may only need to be distributed more broadly, those noted below are now being produced to address the needs of specific stakeholders.
B(7)(a): Create a Manual on Constructive Engagement to improve the understanding of and expertise in constructive engagement, i.e., the partnership formed by a facility's management, its workers, government regulators, and the local community to plan, monitor, and evaluate a facility's environmental activities.
Lead: John Bowser, 202-260-1771/Janet Remmers, 202-260-1583, Office of Pollution Prevention and Toxics
Schedule: November/December 1998
B(7)(b): Create a guidance manual for use by pilot project sponsors involved in Project XL. Past, present, and potential participants in Project XL have identified the stakeholder process as an area in which all stakeholder groups (e.g., project sponsors, direct participants, commenters) would appreciate and benefit from guidance. This guidance manual is designed to clarify roles and responsibilities, enumerate guiding principles, and give ideas and tools to help conduct a successful XL project.
Lead: Kim Green-Goldsborough, Office of Reinvention, 202-260-4297
Schedule: Fall 1998
ACTION B(8): Establish internet site for stakeholder involvement.
This action is intended to provide stakeholders with a point of entry for obtaining information that is relevant to stakeholder involvement, with links to EPA or other program-specific sites.
Lead: Kathleen Bailey, Office of Reinvention, 202-260-3413
Schedule: Initial setup August 1998
ACTION B(9): Explore, identify, and address stakeholder capacity-building needs.
Experience with stakeholder involvement programs has demonstrated that many stakeholders need technical assistance to participate fully in these activities. In addition, it is important for the Agency to assess individual stakeholder groups' needs, priorities, and circumstances, including their limitations and external influences, when designing stakeholder efforts. Three specific actions are planned:
B(9)(a): EPA will work with the Environmental Law Institute to identify needs and explore the potential establishment of regional resource centers to support stakeholder involvement processes around the country.
Lead: Helga Butler, Office of Policy, Economics, and Innovation, 202-260-4179
Schedule: Work Assignment to begin October 1998
B(9)(b): Continue to provide targeted communications about Agency activities and products to key stakeholder groups. Facilitate Headquarters and Regional communications and feedback about EPA products designed for key constituents. Involve key constituents in design and feedback about EPA information products.
Lead: Margaret Morgan-Hubbard, Office of Communications, Education and Media Relations, 202-260-5965
Schedule: On-going
B(9)(c): Create a listing of technical assistance available to stakeholders as well as options on how to provide it.
Lead: Kathleen Bailey, Office of Reinvention, 202-260-3413
Schedule: 1999
Attachment A
TYPOLOGY OF STAKEHOLDER INVOLVEMENT TECHNIQUES
| ROLE OF PARTICIPANTS |
| EXCHANGE
INFORMATION |
DEVELOP
RECOMMENDATIONS |
DEVELOP
AGREEMENTS |
|
|
DECISION MAKER |
* Hearings
* Public comment periods * Town meetings * Open houses * Interviews * Focus groups |
* Advisory group or task force
* Workshops |
* Negotiated rule-making
* Consensus permits * Mediation * Negotiation |
|
EPA's ROLE PARTNER |
* Conferences
* Technical workshops * Roundtables |
* Task force
* Workshops * Community visioning process * Roundtables |
* Partnering
* Memorandum of Cooperation |
| CAPACITY BUILDER |
* Community Profiling
* Interviews * Technical assistance grants |
* Community consensus group
* Community visioning process * Technical assistance grants |
* Technical Assistance Grants |
Report of the Common Sense Initiative Council's Stakeholder Involvement Workgroup, US EPA, June 3, 1998, p. 8.
Attachment B
PROCESS MODEL FOR EARLY PLANNING OF
STAKEHOLDER INVOLVEMENT
There are three different stages of planning, as summarized below:
| PLANNING STAGE |
|
| Decision Analysis | Planners clarify the decision
being made, the decision making process that will be used, the constraints
on the process, and decide whether and what type of involvement is
appropriate. Output: Decisions about whether an involvement program is needed, and what type(s). |
| Public Participation
Planning |
Planners identify the issues,
stakeholders, information exchange, and decide upon the techniques
to be used at each step in the decision making process.
Output: A plan showing the participation techniques that will be used at each step in the decision making process, including their sequence and timing. |
| Implementation
Planning |
Planners spell out the details
of how they are going to implement specific techniques (such as a
workshop), including how many workshops will be held, in which cities,
the workshop format, the room arrangements, logistics assignments,
etc.
Output: A detailed plan of the format, logistics and assignment or responsibilities for each participation activity. |
Report of the Common Sense Initiative Council's Stakeholder Involvement Workgroup, US EPA, June 3, 1998, p.10.
1. For the purposes of this Action Plan, the definition of stakeholder is very broad, i.e. those who have a stake in EPA's decisions. It includes but is not limited to the following categories: businesses, trade organizations, environmental organizations, consumer and health groups, recreational and educational groups, environmental justice groups, organized labor, federal, state and local governments, tribes, and the general public.
2. The Report of the Common Sense Initiative Council's Stakeholder Involvement Workgroup, June 3, 1998, is available on-line: http/www.epa.gov/reinvent/epastake, or may be obtained by calling (202) 260-7417.