Public Involvement and Hearing Ruses

[susie shimek <shimek.susie@epa.gov>]

In a perfect scenario when EPA or a State or local agency issues an environmental permit (e.g., an air pollution or water pollution permit), the agency would consider:
         a. cumulative impacts of pollutants from all sources
         b. synergistic effects of exposure to multiple types of pollutants
         c. vulnerability of population (e.g., high asthma rates,high elderly population, lack of access to health care, etc.)? - which may mean involving zoning boards 
         d. lack of emergency response capacity (e.g., poor municipal services, immobility of low-income population without access to autos and other means of evacuation)? 

Realistically, the cost in time and resources makes this a difficult thing to do.  It means involving local government offices and elected officials, activists and the private sector and addressing issues raised in other comments today like public apathy and stakeholder burnout. 

Recently a stakeholder said government agencies do pay a lot of "lip-service" to the public, but could do a much better job bringing all of the stakeholders (permitting authority, industry and the affected community) together during the initial stages of the permit application.  I know that in some meetings, the public is looked at as an obstacle, rather than as a vital component of the political process and that appears reflected in the comments shared in "Hearing Ruses"
                 
Stakeholder involvement can identify salient issues that the community, hasn't thought of, aspects of emergency response, that the agency should bring forward... which in turn raises questions of whether the agency has the capacity (if it's persuaded of any of these concerns) to   insist on the resources being invested to address them, and if so by whom (another state agency?  a local government?  the permit applicant?).
     
Good input comes well before the draft reg is promulgated and achieving consensus with the key stakeholders about what outcomes the regs should seek to achieve can make all the difference in the world in  getting stakeholders to accept  the final reg.  But does the involvement really reflect the public?  I recently heard a Baltimore official say that in terms of process and public involvement ,industry groups will participate at every opportunity during the drafting of the law or regulations, but often only the NIMBY's (not in my back yard) directly affected will participate in the legislative process and figure out how to convey impacts to the rest of the county.  

We should be ready to invest periodically in new technical means of figuring out the next generation of scientific issues, which is costly and politically unsexy but necessary.  The objective to be able to become proactive rather than reactive in developing environmental  strategies requires use of technology (cost for equipment, data entry and training staff). Using organizational skills at a much more refined level, and being able to articulate in public forums, likely using political leaders (who may not want to take such a public posture) to be clear on where the bar is being moved, why, and what it will do - both short and long term would also be necessary for acceptance and success.