The Community Impact Statement is a concept I developed when I was a member of the National Environment Justice Advisory Council (NEJAC) subcommittee on Hazardous Waste. It differs from conventional environmental assessments in three major ways:

First, judgments are made by members of the affected community, not proponents of what are often environmentally questionable projects. Second, instead of reacting to proposals by others, community members develop a baseline assessment of environmental conditions in their own neighborhood. Three, it doesn't boil assessments down to one or two numbers. Instead it gives people the chance to describe issues in ways that make it easy to understand why they might be important.

The Community Impact Statement can be used to serve at least three functions:

• It can guide government agencies in the allocation of environmental and related funds.

• It can flag problems requiring an environmental or regulatory response.

• It can guide the private sector and other developers in the design and preparation of proposals. At NEJAC, corporate participants liked the idea because under the current system they don't officially seek community feedback until they have invested substantial resources in putting together a proposal. This is its principal value for Brownfields.

This exercise is based upon a paper on Community Risk Profiles that I presented at Rockefeller University in 1995. In fact, Community Impact Statements can be detailed and extensive. Their preparation can take tens of thousands of dollars and one or two years. The Community Environmental Health Assessments being piloted by members of the National Association of City and County Health Officials perhaps represent the most thorough, resource-intensive model of such an assessment.

In Clearwater we're much more limited. We'll be taking a preliminary two-hour snapshot of environmental health conditions and concerns in the local community. I believe that this portrait will prove useful both to participating community members and the staff of the local Brownfields pilot, but one of the purposes of the exercise is to determine how much value can be gleaned in such a brief exercise. One possible outcome may be to show that the community and/or responsible officials really are not aware of potential environmental health risks.

I plan to conduct the exercise in a series of three steps:

1. Geographic scope. Participants will be asked to define the geographic scope of the effort, by consensus. This should be a reflection of where they are from. If participants feel that the publicity for this event improperly expanded or constricted the scope, then that should be noted for future events.

2. Issue scope. It's also up to the participants, hopefully by consensus, to define what issues constitute environmental health. Here is a potential list. Participants may add or subtract. This model assumes that toxic substances represent at least a part of the community's concern.

   • Automotive Air Pollution
   • Creek preservation
   • Fish/game consumption
   • Friable asbestos in buildings
   • Groundwater Contamination (Fuel)
   • Groundwater Contamination (Industrial)
   • Gunshots
   • House/Code Enforcement
   • Industrial Air Pollution
   • Industrial Gases/Accidents
   • Industrial Noise
   • Lead from plumbing in drinking water
   • Lead paint in residences
   • Odor issues
   • Soil Contamination (Industrial)
   • Surface Water Contamination
   • Traffic Safety
   • Traffic Noise
   • Visual blight

3. Evaluation Criteria. The participants will rate each issue according to the following criteria. This is not a consensus activity. Instead, we will attempt to capture the "sense" of the body, either through a show of hands or simple verbal assent. For example, if about half the people feel an issue is unimportant, we should note that.

I anticipate that we will not have sufficient technical information to rate all issues by all the criteria at this time. Such gaps will be noted as potential technical assistance needs.

If the criteria prove confusing or impractical to apply, then the participants can change them. Some obviously cannot be applied to all issues.

1. Health-Toxicity Level. How hazardous is the substance (or other hazards)? A larger exercise might compare the concentrations with official standards for each substance. This effort could use three levels:

   1. Minor or none
   2. Requiring regulatory action
   3. Posing an imminent or substantial risk

2. Health-Type of risk. Though cancer risks are often used to rate the seriousness of exposures, other types of risks do not necessarily track cancer risks. It is often useful to describe the potential impact of the substance. More than one may be noted.

   1. lethal
   2. acute
   3. chronic
   4. carcinogenic (causing cancer)
   5. mutagenic (causing birth defects)
   6. endocrine disrupter
   7. development disrupter
   8. other ____________

3. Migration. Are hazards mobile? Are pathways evident, potential, and confined.

4. Routes of Exposure:

   1. Inhalation
   2. Ingestion
   3. Skin Contact
   4. Auditory
   5. Trauma
   6. other

5. Human Receptors-Type and Population. Sometimes it makes sense to lump together the entire affected population, but often it is important to break it down by age-i.e., infants, elderly, etc.-ethnicity, gender, or other factors, appropriate to the risk.

6. Ecology. Do hazardous substances or activities in the local environment threaten farm animals, pets, commercial or subsistence fish resources, sensitive species, migratory birds, or habitat?

7. Range of source. In this category, each risk is described by its breadth, not of exposure, but by where it comes from. Global-Ozone-depletion is a good example.
   Regional-Such as automotive air pollution
   Multiple-Underground storage tank leaks
   Singular-Emissions from one factory
   

8. Timing. When do exposures occur? Are they constant, frequent, occasional, or rare? Do they only occur during work hours? Or perhaps only during the summer? Are the impacts persistent or accumulative?

9. Economic Impact. Does the health threat or the proposed response have a positive or negative impact on jobs, taxes, or other local economic objectives? Is that impact significant?

10. Quality of Life. Many health threats also undermine the quality of life. Visible air pollution is an obvious example. Noise pollution may have a minor impact on health, but it can be a major irritant. Some health risks themselves both contribute and detract from the quality of life, depending upon who is making the judgment. Cigarette smokers claim to enjoy smoking, though I would consider the smell of tobacco smoke a major irritant-even if it were not a threat to my health. On the other hand, I love the sight, smell, and sounds of a wood fire, even though it too may pose a health risk. In some areas-particularly recognized native lands-environmental hazards pose a threat to an entire way of life.

11. Jurisdiction. In deciding whether to take action to reduce a risk, decision-makers must establish both legal and practical jurisdiction. Does the body considering action have legal responsibility? Is it in a position to take action? Is it owner, a responsible party, or does it merely play a regulatory/oversight role? Levels of jurisdiction include local, regional, state/tribal, and Federal. In some instances, international law-such as trade agreements-may also come to bear. And even if a problem is local, it may belong to (or be better addressed by) another local jurisdiction.

12. Causality. Can the problem be prevented, is it reversible, or is it irreversible? Is it already largely under control, or is there little hope of controlling it? Are we at a turning point that would magnify any action?

13. Responsibility. We tend to support action based upon our ability to assign responsibility. Can we identify the perpetrators, or is the blame generic or assignable only to the taxpayer for remediation? Which of the following factors are responsible for the problem: ignorance; negligence; malevolence; or bad luck? Or is the problem natural or unavoidable? Are those people principally at risk volunteering to take known risks (such as smokers)?

14. Cost. Theoretically, decisions to reduce risk are supposed to be based upon the cost per unit of reduced risk. But it's more complicated, depending upon who pays. Requiring a company to clean up its groundwater may represent a slight cost for the regulatory agency but it may represent an enormous cost for the polluter or its insurers. On the other hand, it's easier to ask a large corporation to spend millions of dollars on cleanup than a small, independent factory-owner.

    Some clean-up activities, such as source removal or containment, make sense because they reduce long-term costs. And in some instances, pollution prevention can actually save money by saving energy, water, or other materials. That is, risk reduction can actually be profitable. Similarly, cleanup of Brownfields sites may make the property useful again, and it can generate significant new taxes and fees for local government.

15. Overall importance. Once participants have attempted to judge an issue by the criteria above, we will ask them to rate their relative importance, using an informal multiple voting system.

Clearly, for such a brief exercise, many criteria will prompt the response, "unknown." Others may be "not applicable." The results should be displayed, as we proceed, on butcher paper or a blackboard chart. The result should show two things:

• It will provide a rough profile of the community's environmental health concerns.
• It will identify areas where more information is needed.