intro and general comments

[Leslie Wildesen <lew@envirotrain.com>]

I am President of Environmental Training & Consulting 
International, Inc., a firm that specializes in environmental 
impact assessment and environmental management 
system work in the US and abroad. My experience is 
principally in the environmental planning sphere, where over 
30 years I have worked with National Environmental Policy 
Act and National Historic Preservation Act projects in the US. 
Part of the problem EPA has is that most of its projects get 
started with public involvement way too late, when people 
already have their positions established and now are angry 
not even so much about the actual thing itself but simply  
because they weren't involved sooner. And that, of course, is 
not possible to fix afterward, because the whole point is that 
it is too late.

We provided  comments last year on EPA's public 
involvement in regulatory programs guidance document (not 
the regs, but a compendium of "how to's") -- and it was 
appalling how many of the types of projects discussed didn't 
even schedule a newsletter or a meeting or a field trip until 
after decisions were already made by the agency.

A good example is a recent lengthy article in Westword, our 
local investigative newspaper (Denver, Colorado), where the 
issues around NPL listing for a mountain community were 
described. EPA and the State regulators believe their hands 
are tied (or the funds are not obtainable) until the area is on 
the NPL; the locals fear the "stigma" of listing, and believe 
the agencies should be engaging in constructive dialogue 
well before listing, and in fact that the potential for listing 
should be a major part of the dialogue.

One problem is that EPA's authorities and budgets are tied 
to NPL and other specific programs and legislation. It will 
not be possible to solve the REAL public involvement 
problems until EPA has authority to spend money and 
engage in public involvement programs as part of its regular 
planning process -- NOT after the RI/FS is drafted or a site 
is listed.

In the environmental planning process under the National 
Environmental Policy Act, for example, public involvement is 
an integral part of scoping the project from the get-go (and 
even then, lots of people complain that they get involved or 
notified too late). Under environmental management system 
frameworks such as ISO 14001, for example, organizations 
that wish to be certified under the standard are required to 
have a stakeholder involvement program that runs 
continuously, so that it is possible to get information from 
the organization and provide input and feedback at any time, 
not just for special projects....

So, one goal for EPA and for this Internet dialog might be to 
find ways to ensure that public involvement programs at 
EPA aren't just tied to specific projects, but are aimed at 
helping the public understand the whole mechanism of 
regulation, clean up, etc. Or just one big message, like 
Smokey Bear (which was not an overnight success, but took 
50 years of guys in furry suits showing up at county fairs and 
passing coloring books....)

Well, I'm interested in what happens next.