What is a Community Impact Statement?
A Community Impact Statement is a document called for by California Public Resources Code Section 21151(c) prior to any significant permit issuance that authorizes a project that may have substantial adverse impact on the physical environment. The statute calls for the lead agency and members of the public to jointly prepare environmental review documents that include the views of the public with respect to the impact of a project. The purpose of the statutory community impact statement are to give the developer the opportunity to address any potential environmental concerns expressed by the public and gives the public an opportunity to be heard . In effect, community impact statements are meant to further environmental review under CEQA (California Environmental Quality Act).
The statute goes on to authorize a written appeal of whether the environmental review document prepared for a project has included the views of the public and the response to any such views by the lead agency and the developer. This written appeal is known as an "appeal review" or "appeal request." The Lead Agency must respond to allow for a response to public comments.
Key Components of a Well-Written Community Impact Statement
A well-constructed community impact statement includes, at minimum:
Data Collection and Analysis
Community impact statements should be built on relevant, current data. Such data may come from various public and private sources. For example, a community impact statement may address a problem or condition affecting an industry, but coming from outside the industry, such as a population change projected by the U.S. Census Bureau. It may be useful to combine the data with supporting documentation, including photographs, to clarify the associated negative impact or effect on a community.
Depending on the issue, the following data sources may be helpful:
Your data collection methods will vary based on the type of information you are seeking. For instance, if you are making a case supported by census data, city records, or other public information, you can often obtain it via direct inquiry to the issuing agency. If you need information from individuals, you can conduct a survey or compile a list of statements from community members who share your concern.
Because data alone does not create a compelling community impact statement, you must also analyze and interpret the information you collect. This is where your insight and expertise as an advocate are essential. X will be analyzed to show Y impact. Whether this is a statistical correlation or a more direct causal relationship, your analysis should be predicated on the data you have collected and organized.
Presentation Methods
The ultimate goal of an impact statement is to influence decision-makers — policymakers, funders, prospective clients, etc. The most effective approach depends on (1) the audience, (2) the issue at stake, and (3) the type of supporting data you collected and analyzed. How you present your community impact statement may depend on:
The combined power of community impact statements is that they help drive positive change for communities. By sharing your community impact statement with decision-makers and influencers, you can create positive change for you and your stakeholders (whether internal or external to your organization), as well as for your community.
How to Succeed at Writing a Community Impact Statement
The first step in drafting a Community Impact Statement is to read the actual policy on the topic you are going to comment upon. Having a good understanding of all the provisions will prepare you to write a letter that references specific sections of the policy and respond to every pertinent issue raised.
The second step is to outline your letter. In this way, you will have identified the main issues you will comment on in a logical order. Generally, a community impact statement will include:
-A summary of the important facts
-The problem itself
-Suggestions or solutions to fix the problem
-A conclusion
In your Letter we highly recommend using a clear and concise style and avoiding technical jargon or legalese. We also suggest that you mail your letter on time which means postmarked by the deadline.
The most common mistake that writers make is to go too far in their comments regarding their proposed solution or fix. While we all have plenty of suggestions for solutions to City policy, the best letter is the one that responds to the City’s plan on a specific issue and makes suggestions that will work within the confines of the City’s proposed program.
Another common obstacle facing letter writers is allowing other points of view to deflect your focus. While it is important to recognize and understand other perspectives, we do not recommend including them in your letter. As much as possible, we encourage you to stick with the main points of your letter and support your specific position.
And last but not least, be transparent about where you find issues with the desired results of a specific policy. If there is an opportunity to solve the problem by working with City Staff to create a workable approach, be honest in your letter. As a representative of the public, The Coalition encourages our members to be forthright with the City because it saves everyone time if there is a problem getting the result sought and a simple solution is available.
Community Impact Statement Examples
To get a better sense of what makes a community impact statement especially compelling, below are certain examples of community impact statements that stand out in their effectiveness. As you review these examples remember that the most effective community impact statements center on the individuals and families most impacted by the proposed action, while also capturing the attention of decision makers in a clear and concise manner.
Example One:
This is from a community impact statement submitted regarding a resolution to institute a city rental subsidy for the lowest income households, funded through an increase in the city’s sales tax. The first paragraph quickly establishes who is speaking, what they want the city to do, and why it is so important to them. The use of brief declarative sentences, and short paragraphs of one or two lines, makes it easy to read. It provides facts and figures, identifies the groups and constituencies for whom the solutions are sought, acknowledges directly and by name the public officials being asked to act, uses active voice (for example, "We demand" instead of passively saying "It is demanded of you") and resolves with a straightforward request. Also note how the writer homes in on the specific policy at issue—for example, the specific funding mechanism (sales tax)—rather than getting lost in all the problems that exist and all the things the city ought to be doing to improve conditions.
Example Two:
This is a youth-written community impact statement submitted in response to resolutions regarding the mayor’s proposed budget for the coming year. This short piece targets three different proposals ("functional areas") within the budget, each of which would benefit a different sector of the community. The approach is compelling not only because of the way the individual youth tie together different issues and create a cohesive and engaging narrative, but also because it includes specific policy recommendations for each of those issues.
The Impact of Community Feedback on Community Impact Statements
The office of the District Department of Transportation ("DDOT") in Washington, D.C. engages in a thorough process of gathering and incorporating community feedback into the preparation of an impact study. All impact statements are required to first go through a 60-day public agency and 30-day public review period. During this time, DDOT meets with the relevant ANC within 30 days of the Preliminary Plans being submitted to discuss the proposed project. Within the 30-day period, DDOT holds a public meeting and gathers public comments on the plans. During this time, DDOT also considers the recommendations made by the ANC. Once comments from the ANC are received, DDOT gathers and incorporates the public feedback and recommendations. Drafts of the impact statement are presented to the community for comment throughout the review process until the Final Impact Statement is prepared.
DDOT publishes The Planning and Sustainability Review Process Guide to provide information about the process for the preparation of an impact statement. This guide acts as a useful tool for both delivery and recipients of impact statements in navigating the requirements of the current urban planning process. As the guide notes, "…DDOT recognizes that there may need to be times where other measures, including adding parking inventory, extending loading or deliveries and TDM plans may be required in addition to traffic signal timing and protection." To that end, it is imperative that the developers collaborating with DDOT during the preparation of an impact statement are willing and able to work within the parameters of the impact statement requirements as outlined in the guide. There is great value in public engagement and collaboration with the community. In the context of an impact statement, public engagement is a vital component that can help inform the decision-making process of a proposed redevelopment project. There are many benefits to positive public engagement in this scenario. The first benefit is that residents and members of the community have the opportunity to direct their input to the actual "decision makers . " Members of different neighborhoods frequently find themselves harboring the misconception that their neighborhood associations should have the final say on local issues. The reality is that those associations may not serve as the most effective mode of direct communication with "decision makers" such as developers, government agencies, and other stakeholders involved. Public meetings and hearings are an opportunity for residents and communities to directly confront their concerns and, in some cases, opposition to the proposed plan, with the "decision makers." A second major benefit is that community input can help "decision makers" in the preservation of existing relationships. In this case, developers and government agencies are the "decision makers" and it would be in their best interest to be as collaborative with the community as possible to avoid potentially negative impacts on their reputations and future business operations. For example, although Washington D.C. is a generally wealthy city, it has its share of poor neighborhoods populated by socio-economically disadvantaged people. Similarly, there are many neighborhoods in the District that have a long-standing history of being distrustful of the "establishment," in this particular case, developers. Although collaboration between these neighborhoods and developers may be unlikely, it will likely be well received due to the history and level of trust. Kept in mind are the potential for future projects that would benefit from a good reputation and established relationships. A third benefit for developers and government agencies alike that comes from public input and comments is the opportunity to address and resolve issues and concerns early in the decision-making process. If there is conflict regarding the details of a proposed plan, it will be easier to deal with early on than later when a developer may have already invested substantial funds and resources. In Washington D.C. the above-mentioned process is often conducted in conjunction with the process of the D.C. Office of Zoning, described in an earlier section of this article. Now, you can see that community input is invaluable in the preparation of an impact statement.
Common Community Impact Statement Mistakes
A common mistake when preparing a CIS is to assume your voice matters less, the more you submit them. This is a misconception – each individual CIS has its importance, and having multiple people submit them shows that there is community consensus on how this development will impact the community.
Another mistake often made is the careful omission of information that may seem negative into one’s report. The information collected in a CIS should present a full picture that includes both the positives and the negatives as they relate to your community. In some ways, it is more important to present the negatives than the positives, as the positives are often obvious, while the negatives may be overlooked without someone from the community pointing them out.
In the same vein, some CISs present excessive negatives. If you think that the report makes an overemphasis on the negative impact of the project, it is important to reach out to the people involved in the CIS to edit it. A good CIS will demonstrate a well-thought out opinion that considers all sides of the issue. If you feel the CIS is lacking in this way, you may have to create a second CIS to give the full context that you feel is lacking in the first.
One of the most important things to avoid when preparing or signing a CIS is confusion. A reader may be confused by several CISs that seem to contradict one another, or a CIS may seem unclear in its message. In these instances, the opposition will use the confusion to undermine the credibility of the CIS overall, and none of the CISs will get any attention at all.
Community Impact Statements Trends
As technology continues to evolve, the ways in which Community Impact Statements ("CISs") can be implemented and utilized also change. Some emerging trends include:
• Understanding the impact of new development on all facets of a community and not just on housing or traffic.
• More communities are being impacted by institutional uses (for example, hospitals, colleges and universities) and the public is organizing in a more structured way to have their voices heard .
• Technology assists in enhancing public participation – not only by making the process easier for people to make their comments known, but it also holds agencies accountable for considering the public’s opinions.
• The practice of law is moving in the direction of "less paper, more e-filing", and agencies are approaching CISs the same way.