[CPEO-MEF] Public Participation comments

[Lenny Siegel <lsiegel@cpeo.org>]

[Below are my comments on EPA's Public Participation policy. As
previously posted, the URL for the policy and comment solicitation is 
http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=1999_register&docid=99-31047-filed.
 - Lenny]

I appreciate the opportunity to comment on the Review of EPA's Public
Participation Policies. The 1981 policy, surprisingly enough, still
serves as a strong, positive framework for those policies. It was ahead
of its time.

Still, we have learned a great deal over the last 18-plus years, and
there is room for improvement.

* First, the techniques and procedures required for assuring public
participation in the development of national environmental policy are
not the same as those necessary to involve the public in local or
place-based activities such as permitting, remedy selection, and
environmental assessment. To be sure there is overlap and there are many
parallels, but I believe it would strengthen the policy if it
organizationally recognized the differences. For example, it's important
to provide travel assistance to unpaid members of national advisory
groups. For local efforts, it's important to provide loaner documents
because depository access is generally inadequate to allow members of
the public to review large volumes.

* Perhaps the most daunting challenge in public participation is letting
members of the public know which policies, documents, decisions, and
activities are likely to affect them. I suggest an indexing system, in
which members of the public can indicate a zip code or other local
community identifier. For that location, EPA would identify actions and
potential actions likely to affect the community.

* This place-based index could be easily implemented on the Worldwide
Web, but it's important not too rely on the Internet as the sole means
of providing any information to the public. Despite predictions of
eventual universality, differences in economics, culture, and education
still keep vast numbers of people off the Internet.

* Differential access to the Web is a reminder of one of the greatest
lessons of the Environmental Justice movement: Communities are not
equally equipped to participate effectively in environmental oversight.
Some are empowered, educated, and wealthy. Others are not. Public
participation policies should address that gap because it perpetuates
the disproportionate negative impacts experienced by communities of
color and low-income communities. EPA, in its policy, should draw upon
the work of the National Environmental Justice Advisory Council (NEJAC)
subcommittee, but it should go further. EPA and other agencies should
offer more help - technical assistance, for example - to communities
that need it most.

* Furthermore, EPA is not only directly involved in seeking public
participation in activities that it organizes itself, but in those
managed by other federal agencies - such as the Departments of Defense
and Energy - and state, tribal and local governments. EPA's Public
Participation policy should explain to EPA staff - and the public - how
EPA will "export" its own principles of public participation to other
activities in which it plays a subordinate role.

* Finally, the preamble to the new Policy should explain the benefits of
public participation. Giving affected residents and businesses a seat at
the table, early and throughout any decision-making process, not only
reduces litigation and other adversarial behavior. It leads to better
decisions. Even polluters benefit from engagement of the public in the
practice of environmental oversight.

-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org
http://www.cpeo.org



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