Comment on Goals

[Will Focht <wfocht@okstate.edu>]

EPA stated 13 goals in its draft PIP.  Of these, seven address the provision of information and the increase of understanding (#4-#10) and one addresses legal requirements (#2).  Of the remaining five, one promotes PIP in implementation (#12) and one encourages conflict management.  The leaves only three that go beyond the instrumental goals of information, law, conflict reduction, and implementation.  One of these three (#3) states that stakeholders viewpoints will be considered (but not necessarily influence decisions), though goal #13 requires EPA to report the influence that these viewpoints did in fact have on decisions.  It seems to me that all of these goals speak primarily to the substance of decisions, i.e., stakeholder involvement in an evidentiary role.

This leaves only one goal that speaks directly to the other major role that stakeholder participation can and should play in at least some environmental decisions - that is, a constitutive role.  By constitutive, I mean that stakeholders wish to participate in a manner that goes beyond the provision and receipt of information and evidence to one that involves power sharing, trust and efficacy building, process definition, and consensus.  Goal #1 states that PIP should "foster a spirit of trust, confidence, and openness between the Agency and the public."  In my opinion, trust and confidence cannot be earned by situating public involvement in an evidentiary role involving information provision, consultation, and viewpoint consideration.  As Barber has argued, trust judgments of government involve more that judgments about competence; it involves judgments about fiduciary responsibility, which concern the use of discretion, degree of shared values, responsiveness and accountability, public mindedness, and respect for autonomy and justice.

I hope that EPA will explicitly acknowledge in its PIP that stakeholder involvement is more than information sharing and consultation - especially if trust building is one of its goals.  I will provide more specific comments at the appropriate opportunities in this dialogue.