Completeness of the DRAFT PIP Goals

[Peter Schlesinger <pschles@starband.net>]

I am Peter Schlesinger of Sandwich, Massachusetts, located on Cape Cod. I am 42, have a wife and two young kids. My public involvement with EPA decision-making began a few years ago when I wrote a letter to EPA Region 1 asking to participate in a review mechanism for a groundwater study of the Impact Area of the Massachusetts Military Reservation (being undertaken by EPA under the Safe Drinking Water Act). The groundwater study had already begun in earnest and its Review Team had already been named; citizen members already on the Impact Area Review Team suggested I would be a good candidate as I had professional background in the area of geographic information and analysis, so key to the assessment of damage to local environment by National Guard training and testing of munitions. Since then, I have been receiving weekly and monthly reports, via email and post, and a multitude of study documents that would challenge even the most dedicated public servant by courier. I attend meetings that are held in various communities and locations (with the intent of involving as many affected people as possible) and offer written and oral comment on the direction of the study and its findings to appropriate local EPA staff.

Regarding the Draft PIP Goals:

The paragraph which starts 'Decision makers are somtetimes concerned about delays..." needs to be moved to the end of any listing of the goals.  

One area I think is not sufficient is that of communication modes. EPA communicates in documents, press releases made into articles in newspapers, hearings where it takes public comment, and via the Internet (using text and web-based browsers). More and more, government is relying more heavily on electronic forms of communication, and those who have the ability and resources to receive that information immediately have unequal access to information and data. The PIP should strive to provide equal access to information, assistance, and consultation. The line which states "To foster, to the extent possible, equal and open access to the regulatory process for all interested and affected parties," is good, but the PIP should strive to foster equal and open access to all parts of the information flow, not just where it is most economic to do so (which is what I believe the phrase 'to the extent possible' really means). We're getting to be so dominated by electronics that many of us who rely on this mode for almost all of our communications can easily fall into the trap of assuming that everyone we know and are aware of have the same level of access and thus knowledge as we do. This is just not so. I live in a very affluent community, yet the number of regular Internet users is still quite small, and most of those users haven't the resources to access fast Internet because the phone and cable companies have not found it in their economic best interest to make that investment, thus these users' abilities to make use of EPA documents and searching capabilities online is extremely limited.

The line "To ensure that the Agency communicates to the public how its input affected the Agency's decision" is really one of the more important goals in ensuring the success of real and continued public involvement. No one wants to spend all sorts of time reviewing and commenting if they don't know where its going, or can't be sure when all is said and done where their comment actually mattered. I think this goal ought to be expanded, to say more about how the Agency communicates, to whom, and by what method.