Not all the people in Deborah's email would be helped by knowledge of Title V, but some of them certainly would. I can assure you that communities all over the country are struggling right now to figure out how they can use Title V. The two Title V workshops that I've attended, both sponsored by EPA, were both well attended by community representatives. I've held several smaller workshops in Ohio for community groups, and believe me, they are anxious to know how it works.
Deborah mentioned many different issues. I used Title V just as an example of where there should a great deal of information available to citizens to help them protect their community.
I should also note that I suggested a lot more than just giving them the permit.
Finally, you say that you've never heard of citizen's comments tightening a permit. Exactly my point.
I seen numerous permits strengthened because of comments I've submitted. I've even seen a few permits withdrawn after I submitted comments. I know others who have had the same experience. Often the comments require no deep understanding of the rules; it's finding out what the rules are and who the decision maker is that causes the problem.
The majority of community groups work outside the permit process. When they do submit comments, the comments are often off-point. Why? Because no one has provided them with the basic information they need to use the public participation opportunities effectively.
I suppose that we in the environmental community could do a better job of publicizing the victories, but it is my belief that the job of aquainting people with the rules, and making them feel that public participation is worthwhile, belongs to EPA. Else why should the agency bother with public comment periods at all?
I think the Agency derives a lot of benefit when the comment periods work the way they should. I think also that it is the Agency's responsibility to make that process work well more often. Your advice to Deborah that she call an environmental group is good advice, but it's not enough.
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