Opening statement for Hamilton Brown-July 19

[Hamilton Brown <hbrown@sso.org>]

I am Hamilton Brown, director of Training and Technical Assistance for the National Center for Small Communities.  EPA's Small Town Task Force concluded that, "Small towns are not just smaller, they are different."  As the impact of federal environmental regulations has increased for even the smallest communities, many local leaders do not believe that EPA has heeded the committee's advice.  Elected leaders from smaller communities and rural counties often perceive that regulations are set largely to address the needs and to match the capacity of major metropolitan areas where population and financial resources are centered.  Until recently, the best that most smaller local government leaders, or the associations that represented them at the national or state level could do, was to respond to Federal Register notices of proposed rules.  

In recent years, I believe many EPA offices are reaching out to local governments at a time when comments can still have some impact.  I think that EPA could gather far more useful input if they would provide a plain English version or explanation of a new rule at the pre-proposal stage and some discussion of the options under consideration.  This information could be disseminated to national, state and local organizations representing local and tribal government and citizen and environmental groups.  

I hope there will be some good examples offered of local citizen participation in environmental compliance efforts.  Certainly, local source water protection advisory committees come to mind immediately.