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Public Comments -- Earth Day Coalition

Note: EPA no longer updates this information, but it may be useful as a reference or resource.

stakeholder contact points Subject: comments on public participation

December 29, 1999

Thank you for the opportunity to comment on the Review of EPA Public Participation Policies, and the 1981 Policy on Public Participation.

-Chris Trepal,
Executive Director Earth Day Coalition

What's good in terms of goals:

The 1981 policy has some excellent goals:

What Needs Improvement:

More resources need to be dedicated to identifying concerned groups or individuals. Sometimes service lists are difficult to locate and interested persons do not receive notice. There is no or very little "broader notice to the media and contact list" that is required by this policy. An effort should also be made to reach out to the affected communities through the radio and TV. The results of a random survey of 100 Cleveland residents in the fall of 1998 as part of the USEPA's EMPACT found:

  1. The average inner city resident is unaware of the health-environment linkage (<15% cited awareness).
  2. The crush of daily events makes this issue unlikely to rise to the level of functioning awareness without an extraordinary communications effort.
  3. The electronic media (TV and radio) emerged as the major channels of daily information entering the household (>85% cited these as one of their primary information sources).

Despite the goal to provide accurate, understandable, pertinent and timely information this is not adequate. EPA does a good job providing publications, fact sheets, news releases, and announcement in the newspaper. Providing access to fact sheets, news releases, summaries and publications may not deliver that critical information to public. Public has great difficulty understanding the significance of technical data and how it relates to a specific issue or permit. There is little context provided by EPA. An ombudsperson should be provided. Also follow up on specific calls made to the agency should be made to ensure customer service. Sometimes requests are not answered adequately.

Hearings should be better publicized. It costs $70 to subscribe to the OEPA publication of the hearing schedules. No one should be expected to access it to get current information.

Many times mailed notices are received mere days before hearings, after hearings have already occurred, or during the holidays, even when citizens request notification by making calls to EPA. It is our experience that the 45 day requirement prior to a hearing is almost never in force.

Comment periods are most often the 30 days (including responding to this notice) and that is usually not enough time for small grassroots/neighborhood/church-based organizations who usually meet monthly. Members of the public do not know that they can request extensions or how to do this. There is little technical assistance that can be quickly accessed to respond to the notice even in the 30 day period. It may take days or weeks to gain access to official records and longer than that to request items by mail or talk to a person at EPA. Please consider reworking timetables to give maximum amount of public notice at all times. Consider developing a pre-notice calendar of permits that are coming due in 6 months.

EPA is not so good in providing targeted questionnaires, surveys, interviews, public service announcements, or targeted educational activities. Also, I really like and appreciate the incredible USEPA web site. However, most of the groups and organizations that we work with locally do not have internet access. Members are very unfamiliar with computer data and have great difficulty translating data into meaningful information for public participation.

It is also not clear who develops the required 'social and economic consequences' and what part the public has in this process.

Copies of documents are rarely provided free of charge to individuals or grassroots groups with limited funds. The city of Cleveland used to charge $1 per copy and now charges $.25.

Some documents may be poorly kept or even be non-existent, causing great difficulty. If documents are missing or non-existent, it is not clear what recourse the public has. The attitude, for example, at the Cleveland Bureau of Air Pollution Control, is that is just the way it is. No apologies, no further help.

Local agency staff may not be helpful, and may be antagonistic (usually due to overwork, lack of tools to deal with the public, etc.). For example, facility engineers are usually not helpful - sometimes they are unable to answer most questions, and do not attend the hearings. EPA likes to send members of the public to the Public Interest Center where the information is helpful but too general for meaningful participation.

Sometimes hearing follow-through is not clearly communicated by hearing examiners from the agencies They do not tell the audience what would happen next, and what the timeline is.

Agency folks not familiar thoroughly with Environmental Justice issues. Sometimes EPA representatives do not know what "EJ" is, and what should be taken under consideration. This should be integral part of all hearing information. All too often the poor and communities of color are forced to live with disproportionate amounts of pollution and increased health risks, even while gains are made for others.

Efforts by advocates in low-income communities and communities of color to improve environmental quality are being frustrated by the absence of easily accessible local technical support and expertise. Residents of communities facing disproportionate amounts of pollution also face the burdensome task of accessing and deciphering immense amounts of technical and regulatory information. Information is not easily accessible, is costly to assemble and sometimes difficult to interpret and apply to a given local problem.

In many instances a high level of knowledge is required just to learn what pollutants may be found in a neighborhood and whether they pose health problems for residents. In low-income communities, the problem is heightened by economic realities that make citizen involvement even more difficult, such as lack of financial resources needed to research pollution permits or the clean-up records for abandoned properties.

Technical support and assembling/coordinating available expertise on issues such as regulatory processes, public health risks associated with pollutants of concern, best available technology for hazardous substance handling and storage, and effective remediation methods for past contamination, would equal the playing field for these communities and enable them to effectively take part in the environmental decision making process. Support in the form of research assistance, technical review, and independent oversight of the process will provide affected communities with vital information necessary to achieving environmental equity.

Thank you again. Please keep me informed of the progress on this most important topic.

"Neighbors working together to improve the health, quality of life and environment of the Greater Cleveland Community"

Chris Trepal,
Executive Director Earth Day Coalition
3606 Bridge Avenue
Cleveland, Ohio 44113-3314
Tel: 216/281-6468
Fax: 216/281-5112
Email: ctrepal@earthdaycoalition.org
Please visit our website at: http://www.earthdaycoalition.org

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