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Public Comments -- Resources for the Future

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

stakeholder contact points Below is an electronic copy of my letter to EPA dated 12/13/99. In my original submission, I enclosed three papers. Electronic versions of these papers can be found at our webite www.rff.org

*** December 13, 1999

Deborah Dalton
Environmental Protection Agency (MC 2136)
401 M Street SW
Washington, DC 20460

Dear Ms. Dalton:

I appreciate the opportunity to respond to EPA's request for comments on the agency's 1981 Policy on Public Participation. The views provided here are mine and not the views of Resources for the Future (RFF). RFF is a research organization that does not take positions on public policy issues.

In general, the actions recommended in the 1981 Policy on Public Participation, if followed, should encourage effective public participation. They seem quite consistent with "best practice." To the extent that public participation at EPA is considered in need of improvement, I would suggest that the problems are in implementing the policy rather than with the policy itself.

At RFF, we are engaged in various projects to evaluate the implementation of actual public participation efforts. The objectives outlined in Section C of the 1981 Policy on Public Participation share many similarities with the criteria (we call them "social goals") that we are using to evaluate public participation. In this letter, I will highlight some of the major conclusions of our research and then offer some comments on the 1981 policy itself. Included with this letter are two discussion papers and an article to which I refer below.

Over the past two and a half years, the Center for Risk Management at RFF has been conducting a variety of projects focused on the evaluation of public involvement programs. The first product was a discussion paper, "Public Participation in Environmental Decisions: An Evaluation Framework Using Social Goals," which outlines an evaluation framework based on six "social goals" for public participation:

The focus on social goals was motivated by a perceived need to get beyond procedural prescriptions for public involvement and to understand what value participation adds to environmental policymaking--essentially asking the question, "what are we getting from public involvement"? The framework recognizes that there are many mechanisms available for public involvement and some will be better than others for achieving particular social goals.

Our most recent discussion paper, "Public Participation in Environmental Planning in the Great Lakes Region," applied this framework to a number of cases of public involvement (mainly through advisory committees) in environmental decision-making in the Great Lakes region. We sought to understand whether the social goals outlined above were being achieved, and what contextual and procedural factors were related to their achievement. We came to a number of preliminary conclusions from the study:

We continue to examine these conclusions with a larger study of around 250 case studies in public participation in environmental decisionmaking. The project is funded by the National Science Foundation and will be completed in Fall 2000.

I have also included with this letter an article from the Environmental Law Reporter on the Federal Advisory Committee Act (FACA) and public participation: "Chilling Collaboration: The Federal Advisory Committee Act and Stakeholder Involvement in Environmental Decisionmaking." This article highlights a number of ways that FACA can hamper stakeholder collaboration on environmental policy issues, particularly at the local level. This is significant because many recent initiatives in environmental management-such as community-based environmental protection, ecosystem management, and environmental justice-call for greater collaboration with interest groups and local communities. The paper suggests some steps for reforming FACA.

In addition to the work already discussed, we are currently examining the opportunities that the Internet creates for improving public involvement. This research is being funded by EPA. Copies of the papers cited above and short descriptions of our projects can be found at RFF's web site, www.rff.org.

Based on the insights from our research, I have some comments about EPA's 1981 Policy on Public Participation and its upcoming revision. As I said, the current policy seems quite consistent with best practice and with the conclusions from our research. My comments, therefore are few.

The new policy should:

Thank you for the opportunity to comment on the 1981 Policy on Public Participation. Please contact me at (202) 328-5015 with any questions.


Thomas C. Beierle

Tom Beierle Center for Risk Management Resources for the Future 1616 P Street Washington, DC 20036 (202) 328-5015

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