RE: Goals (Information/Implementation)

[Steve Taylor <Steve@miltoxproj.org>]

Paul raises a critically important point.  The goals themselves are laudable, but, as always, the devil is in the details.  There are many, many laudable laws and goals which are not implemented or are implemented in ways that undercut the spirit and letter of the law or goal.

I would suggest that the goals are incomplete without at least one addition.  The public needs means to hold EPA accountable to the goals and their implementation.  Perhaps we might add a goal that says something like:

"To provide the public with means to hold the Agency accountable to these goals and to the spirit and letter of the Public Involvement Policy."

This raises another issue, which I will speak to on appropriate days, that of real public involvement in decisions.  Too often, the Agency asks for public comment but does not provide vehicles for communities to sit at the (metaphorical) decision-making table as peers.  The goal which aims to "foster...equal and open access...for all interested parties" should be amended to recognize that many stakeholders (including most polluters) have much greater resources and ability to participate than others.  True public involvement only BEGINS with open access.  The policy needs to do more to attempt to ensure parity of input and influence in decisions.

Finally, the goal which aims "to learn from the public the information it is uniquely able to provide..." should be amended to require EPA to consider such community-based information equally.  Too often, community-based information is dismissed as "anecdotal" and given less weight than other sources of information.  In addition, the public often does not have the resources to follow-up on leads such as memories of possible spills and contaminant sites.  The goal should include an EPA responsiblity to equally consider community-based information and for the agency to perform reasonable follow-up to investigate and document community memories and leads, rather than placing the burden completely on the public to provide documentation.

Steve