Goals (Information/Implementation)

[Paul Orum <paul_orum@yahoo.com>]

EPA's draft Public Involvement Policy declares an intended outcome more than it sets the path to get there.  The goals are laudable, and vague.  We need to explore the "how to."  How do people have timely, meaningful information and opportunities to intervene?

My "how to thesis" for today is:  "To meet the goals of the Public Involvement Policy EPA, States, and the public need a seamless, unified national facility registry that provides basic permit application, renewal, and enforcement information for all EPA and State delegated sites."

EPA's draft policy supposes that the agency will seek public involvement at certain times, and that the public will respond by becoming involved at those times.  This view tends to preclude involvement initiated by members of the public and their organizations.  

A national facility registry admits a proactive element.  It breaks down barriers to public involvement AND effective government.  A well-organized facility registry will help people to:

1] Become involved on their own schedule - not just EPA's;

2] Identify environmental concerns affecting work, school, or home;

3] Save time, compared to slow-moving Freedom of Information Act requests;

4] Unify currently fragmented EPA and delegated information sources and programs;

5] Participate on a level and transparent playing field - or at least one that is more so.

A basic registry should inform people about:

[o] Permit applications;
[o] Expected renewal dates;
[o] Compliance history;
[o] Applicable regulatory agency;
[o] Owner-operator/parent company; 
[o] Facility location (for place-based approaches);
[o] Industrial sector;
[o] Planned test dates; 
[o] Hazardous materials;
[o] Other basic identifiers.

Indeed, EPA and States ought to be able to identify and characterize the facilities they regulate!  

Simply enabling and encouraging people to monitor, investigate, question, and communicate on their own schedule would be a great step forward.