Public involvement for commenting on rules and permits

[Lindsey Christ <lchrist@nrdc.org>]

It is important for local communities to have access to proposed rules and permits before they become final.  Again it goes back to the people who are the most affected by decisions are the least and last informed.  

EPA needs to hold true public hearings on all large or long-term actions.  By true, I mean the public hearings should include many members of the public, not just the private sector. The hearings need to be long enough that people are able to express their opinions and all public comments should be recorded at these hearings and used in the decision making process.  At the very least, clear rules on when EPA or the states have to hold a hearing need to be established because the current threshold of "significant public interest" appears to be defined in a widely diverse manner.


EPA should post public notice of comment periods in a LOCAL paper.  Often posting in just statewide papers does not get to local populations that are truly affected.

The public should be given a reasonable amount of time to comment on policy documents. This includes posting the document for comment on the same day announcement of the document. While using the Internet to post documents for comment is a good, if EPA does not make these documents available electronically as soon as the comment period begins they are really shortening the comment period. This puts the public at a disadvantage-- those who have a full-time job not related to the policy have a hard enough time commenting on documents during most comment periods.

The length of comment periods should be tied, when possible, to policy complexity. For example, allowing only 30 days to comment on a proposed TMDL is insufficient.