RE: Adequate time for review - thoughts needed

[Glenn Landers <glenn.landers@sierraclub.org>]

Part of the problem with short comment periods is that citizens often are in a reactive mode, which means that there is going to be little time to absorb all the information necessary for full participation.  

For instance, a citizen's group hears that a major new facility is proposed for their neighborhood and must suddenly learn all the intricacies of the new source review permit process.  The learning curve can be very steep, especially for groups that are already burdened with a bunch of other issues. 

It would be far better in my mind to have a more pro-active approach to community involvement, where EPA identifies within communities the likely public participation interests and provides workshop that prepare citizens in advance. The workshops that EPA has done around the country on Title V air pollution permits are a good first step in this direction. The workshops provide citizens with an overview of the permit process, the rules involved, and examples of things problems in permits. Citizens come away prepared to look at actual permits and provide substantive comment.

Citizens who are familiar in general with a program are going to be better equiped to deal with specific questions when they come up. Also, they are more likely to participate, since they've already invested time.  My experience is that they are also eager for this kind of information.