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Public Comments -- Good Neighbor Project

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stakeholder contact points

gnproject@earthlink.net on 12/30/99 10:37:54 AM

To: stakeholders@epa.gov

Subject: Comment on Public Participation Policies

Deborah Dalton
U.S. Environmental Protection Agency
VIA email

Re: Request for Public Comment on Review of Environmental Protection Agency Public Participation Policies (64 FR 66906, November 30, 1999).

Dear Ms. Dalton,

These comments are submitted on behalf of the Good Neighbor Project for Sustainable Industries of the Tides Center. The Good Neighbor Project has worked with numerous grassroots groups in the US on public involvement in corporate environmental issues. We are a leading expert on community public participation to produce sustainability at local industries. We would like to submit the following comments:

I. Improve Assistance to the Public. There is a need for the EPA to play a greater role in providing resources for submittal of comments to EPA and for stakeholder-company dialogues as part of permitting and other engagement processes. These resources for issues like technical assistance should be provide with as few as possible strings attached, and the application process should be simple. The states should also be encouraged to provide such resources. For instance, citizens groups need to be able to obtain grants to prepare thoroughly for permit hearings; where such resources are available the quality of citizen input is improved markedly.

II. Encourage Pollution Prevention through Stakeholder Negotiation. The EPA's public participation program should encourage companies and stakeholders to enter binding negotiations to address anicllary issues relative to permitting. Such side negotiations are essential to addressing the fundamental issues of sustainability that are impacted by permitting. Attached find white paper "Precedents for Corporate Community Compacts and Good Neighbor Agreements", a journal article "Good Neighbor Agreements: A Tool for Social and Environmental Justice" and "Model Stakeholder Audit Guidelines" that describe this potential in detail.

III. Bring Public Oversight and Comment into the Information Age. The EPA's public participation and oversight process should be updated into the information age by establishing mechanisms for immediate posting of comments and ongoing bulletin boards for online dialogue on permitting and regulatory proposals. Much more useful comment and dialogue can occur if mechanisms are provided by agencies for ongoing dialogue online throughout a comment period, rather than only having the comments accumulate for review at the end of the process. In addition, EPA's revised program should encourage online participatory mechanisms for remote participants in proceedings, through realtime video and audio feeds on the worldwide web, and through in-meeting participation via remote submittal of questions, comments, etc.

IV. Maintain and Expand Public Access to Corporate Information Relevant to Sustainability. The EPA should continue to vigilantly oppose and seek to strike down state audit laws that lead to withholding of information from citizens through audit privilege. In addition, EPA should take a leadership role is establishing new initiatives for broad public disclosure - e.g. requiring annual corporate environmental and social responsibility reports, requiring and enforcing environmental disclosure in corporations' shareholder reports, and requiring generalized disclosure requirements that can be triggered during public participation processes as information demands are proven to be needed.

Please also add to the record of this proceeding my additional paper, "Feel Good Notions, Corporate Power and the Reinvention of Environmental Law" to describe as a cautionary note some of the issues on which the agency needs to be alert when addressing public participation in the context of regulatory reform.

Thank you for your consideration. Please contact me if you have any questions.


Sanford Lewis
Good Neighbor Project
PO Box 79225
Waverly, MA 02479 USA

617 489-3686
781 891-6889 fax
Holding corporations accountable to community, labor and shareholders
Email: gnproject@earthlink.net

Consultancy: http://home.earthlink.net/~gnproject/strategiccounsel.htm
Good Neighbor Project: http://www.enviroweb.org/gnp

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