7. Public and Tribal Stakeholders Perspective

Public stakeholders should include members of the public affected by the site, environmental advocacy group members and community advocacy group members. In addition, tribal stakeholders are defined as Native Americans, Alaska Natives, Native Hawaiians, or persons who are affiliated with or are employees of Native American tribes. These public and tribal stakeholders are the voices of the communities and tribes that are affected by environmental problems and by remediation efforts.

Stakeholder involvement begins with identifying all applicable stakeholders. Stakeholders can be identified by mapping a project’s area of influence or impact. This map helps to determine what groups, areas, or activities could be affected by the planned work. In the identification of tribal stakeholders, note that many tribes by treaty have hunting, fishing, and access rights to land that may not be near the present-day reservation. Thus you must look beyond simple reservation boundaries in order to identify tribal stakeholders. Tribes also have sovereignty and must be approached with the proper protocol afforded to a governing body. Stakeholders with an interest in groundwater statistics could be a subset of all stakeholders.

After the applicable stakeholders are identified, several key questions must be answered: the role of each stakeholder group in the environmental site management project, the potential impact each stakeholder group will have on project decisions, when stakeholders will be engaged, how stakeholders will be engaged, and how information will be disseminated. It is best to engage stakeholders early and often. Stakeholder engagement is not unique to groundwater statistical analyses; many regulatory programs have clearly defined checkpoints and procedures, such as the Resource Conservation and Recovery Act (RCRA) permitting process. The RCRA stakeholder identification guidance is described on USEPA’s web page (USEPA 1996).

In communicating groundwater statistics to stakeholders, begin by explaining that the overall objective of the cleanup action is to protect human health and the environment. Groundwater statistical analyses are used to better understand the site conditions and inform the cleanup decision making. Statistical methods can be daunting to public and tribal stakeholders and many people are skeptical about the use of statistics to prove any point. A lack of agreement among the experts about statistical methods has created the perception that you can find a statistical argument to support almost any action or conclusion. Straightforward and transparent communication is the best approach. Stakeholders, and some regulatory agencies, may not have access to statistical experts, so present results as clearly as possible and provide opportunities for dialogue to answer questions.

Two general presentations of basic statistical concepts that may be helpful to stakeholders are found on the following web pages:

This public and tribal stakeholder section serves two purposes: 1) to help the state regulator to understand and anticipate likely issues, needs, and concerns of the stakeholders; and 2) to help make the document more useful to the public and tribal stakeholders. Important general principles that stakeholders should understand are that statistics are only as good as the data set and the data set is only as good as the conceptual site model. Thus, stakeholders must be aware of matters such as sampling well placement and sample validity:

  1. Stakeholders should receive explanations of how choices pertaining to seemingly neutral statistical analyses may influence remedial decision-making.
  2. A valid conceptual site model is always necessary. If a site is not properly characterized, the statistical results cannot be trusted.
  3. Statistical analyses must be performed on a data set of valid size. Consider the following simple example: suppose eight sets of samples are the necessary minimum for valid statistics. If monitoring only occurs once a year, then it will take eight years before it is known whether attenuation is occurring and whether the remediation is occurring. In this situation, the stakeholders might insist on quarterly sampling, in which case it would take two years to learn whether remediation is occurring as projected.
  4. To achieve appropriate and accurate statistical analysis, stakeholders should understand that, for data integrity, the monitoring must follow proper quality assurance and quality control procedures during sampling and laboratory analysis. Examples of appropriate procedures may include sample duplicates and blanks.

Publication Date: December 2013

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