RE: Identifying the Interested Public

[Dan.Dozier, Panelist <ddozier@tlisystems.com>]

I agree with Glenn Landers when he wrote that one way of identifying interested members of the public is to look for folks who have complained; and that means one has to look in more that the obvious places.  

In cases where a site-specific dispute or issue is involved, looking for people who have expressed an interest or filed a complaint is one -- not the only -- way of identifying interested members of the public.  I think the Agency still has the responsibility, in site-specific cases, to do mailings/tv/media announcements.  

In matters involving policy issues, where in the past EPA has been willing in some cases to engage with relevant stakeholders about a proposed regulation or policy issue, the issue of identifying stakeholders requires, in my opinion, a thoughtful and complete consideration of possible stakeholders with a full discussion with as many stakeholders as possible about who should be involved and why.  This so called "convening" effort is best done (in my opinion must be done) by a neutral, that is someone with no stake in the issue.  There is a full discussion about this process in "The Negotiated Rulemaking Sourcebook" published by the now defunct Administrative Conference of the U.S.  If anyone wishes a citation to the Sourcebook, please contact me. I believe that this Sourcebook has been updated by Deborah Dalton, of EPA's Conflict Prevention and Resolution Center.  That office, by the way, was established in part to facilitate EPA's stakeholder involvement program and to work to see that it is done right.

Dan Dozier