permits and rules

[David Clarke <David_Clarke@americanchemistry.com>]

I am David Clarke with the American Chemistry Council's Science Policy Team, which works with our members to advocate the use of the best available scientific and economic information to help achieve cost-effective, risk-based environmental protection. Prior to joining the Council almost three years ago, I worked as a journalist for more than a decade covering environmental issues for Inside Washington Publishers. During that time, I spoke with thousands of people involved in environmental policy issues, including EPA and state environmental officials, scientists, activists, industry representatives, fellow news reporters and editors. I also read countless pages of reports, studies, and public comments on issues dealing with water, air, waste, and other environmental problems. Based on my experience as a journalist, it is clear to me that these highly contentious issues are extraordinarily complex because they involve a broad range of facts, fears, hopes, and dreams - a medley of scientific information and trans-scientific values. Equally clear to me is that decisions made with broad input are always better than decisions made without regard for the diverse information and values people can bring forward, although the open processes of democracy impose upon decision makers the difficult task of sorting through often conflicting and fragmentary advice to make choices in the larger public interest. Dialogues such as this one on EPA's Public Involvement Policy are an exciting new phase in the evolution of stakeholder involvement and the Agency should be commended for venturing into Cyberspace to enhance its outreach and interaction with the public.

The specific topic of today's discussion is consultation on permits and rules. I would like to comment on the question of how EPA should improve public input into permitting decisions. In the Agency's reference guide, "Public Involvement in Environmental Permits" (August 2000), there is a section describing additional tools to facilitate public involvement in environmental permits (section 4). One of the tools described is "Facility Tours" (page 4-5). I believe this tool would help those in the community who wish to comment on a permit to better understand what exactly a permit does. Understanding the "issues and operations at a facility" would help ensure focused and specific comments from concerned stakeholders, and would also enable facility operators to understand what the community concerns are. As some of you may know, American Chemistry Council members support this concept under our Responsible Careâ program, which has a "community awareness & emergency response code" that calls for outreach to educate government officials, the community, and others. This program includes facility tours and the involvement of Community Advisory Panels to provide input to facilities. Members that conduct Management System Verifications under Responsible Care are required to include community members among the verifiers. In addition, the Council also operates chemicalguide.com, a website that provides an opportunity for individual facilities to communicate electronically with their facilities - in fact, with the world.  

I mention this particular example because it ties in with fundamental concepts discussed in this National Dialogue such as "getting information out" and "collaborative processes," both of which are vital to improved stakeholder involvement. Too often in discussions of highly charged environmental issues disputants don't take the time to get facts because they're too busy trying to "win." I am suggesting that with facts everyone wins because facts can shape values and drive decisions.