Identifying the public

[Keith Smith <ksmith@calepa.ca.gov>]

Hello, I am Keith Smith, Sustainability Program Manager for the California Environmental Protection Agency working on sustainability issues and regional and business sector EMS based partnerships.

I would like to raise a  fundamental question about the proposal. The proposed  policy addresses public participation  by "program, activity or project." We actively encourage businesses to no longer manage environmental affairs as a separate program, activity or project but to integrate environmental issues into the corporate planning and management system for the entire facility operation and product life cycle. 

QUESTION: Should EPA integrate public participation into its management systems for the entire policy life cycle (environmental problem recognition - policy formulation - implementation - control?) Should it identify and make public the type of participation sought and the participants targeted for each stage of the cycle? 

By stating this in advance, affected/interested communities will be aware of opportunities to participate at all stages of the policy life cycle, may actively seek opportunities to do so, and through participation become more educated about the issues when individual project or program requests for participation are made.

Environmental problem recognition - how to place emerging issues on EPAs agenda?  This involves processes to nominate, research, evaluate, recommend for action and educate the public on emerging environmental issues.  Participation will predominantly be scientific input by environmental scientists from government, academia, public interest groups and industry and information to the public by educators. 

Policy formulation - how EPA selects issues to address and plans regulatory and non-regulatory strategies. This involves processes to select the issues to be addressed, develop legislation and regulation, set long term goals and intermediate targets for improvement, establish measures, identify contributing sectors, select the appropriate mix of regulatory and non-regulatorty strategies to achieve the goals and targets and educate the public about the issue. Participation will predominantly be political and policy input by federal, state and local policy makers, scientists, business and environmental groups and educators.

Implementation - how EPA aligns the activities of regional offices and the States to achieve the goals and targets.  This involves processes to develop regional targets, the programs, projects and partnerships to achieve them,  and the regional measures and evaluation processes. As this is the level at which implementation occurs, EPA might want to consider a transition from participation to partnership with government agencies, scientists, environmental groups and contributing business sectors to develop these processes and with educators to inform the public. 

Control - how EPA and  State and Local authorities both maintain and continuously improve routine operating practices .  This involves processes to permit, inspect, enforce, clean-up sites and to identify regulatory and other obstacles to improved environmental outcomes.  Participation here is at the permit, project or activity level and will predominantly be the local citizens, community representatives, local public interest groups or business involved. This is where the more focused outreach that I hope we will discuss today will occur. This can also be a fruitful source for an expanding database of those interested in participating in the other three stages of the policy life cycle.  This is a bit long for an intro, but I hope it provokes some discussion.