RE: Outreach and Public Perceptions

[James Cooper <james.cooper@socma.com>]

Unfortunately, a large part of EPA's functions are determined by the laws that are passed in Congress, which have very much to do with policing-type activities.  I think EPA has gone beyond the policing approach, however, and is on the right track toward public education and involvement in environmental decision-making.  Please keep in mind that public involvement is a fairly new concept in regulatory processes.  I think if we remain patient, allow new concepts and not be too discouraged when mistakes are made, then EPA will be able to adopt approaches that allow for greater public involvement.

Regarding the Precautionary Principle, I think one of the confusing things is that there are two different versions.  The original version, the language of which was derived from a United Nations meeting in Rio, and agreed to by the international community, calls for precaution when "there are threats of serious and irreversible damage."  The second version, which is not officially endorsed by any government, softens the usage requirements to "when an activity raises threats of harm to human health or the environment."  Clearly, there is a difference between serious threats and other threats.  I think the second version is very difficult to interpret because there is no definition of what type of threat is appropriate for the Precautionary Principle.