Public Comments -- EPA Research Triangle

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

The Office of Air Quality Planning and Standards Draft Plan for Citizen Involvement in the Title V Program

What is the Purpose of This Plan?

When Congress enacted title V of the Clean Air Act and created the operating permits program, it envisioned an active, oversight role for citizens in which they would inform, work with, and hold accountable the agencies that issue the permits. Increased citizen understanding of and involvement with the operating permit program can help EPA achieve its mission by (1) complementing EPA's oversight with an additional level of oversight and accountability for the program, and (2) adding valuable information to permitting decisions. To achieve that purpose, OAQPS and the Regional Offices will work with State, local, and Tribal governments and citizens to increase the effectiveness of citizen involvement in their operating permit programs. Consistent with EPA's goals of expanding Americans' right to know about their environment and maximizing citizen participation, this draft plan outlines the major components of the Plan for Citizen Involvement that OAQPS will propose to adopt to strengthen citizen involvement in the title V permit process. The final plan will contain specific milestones, designated lead offices for specific tasks, and resources required to implement the plan.

What are OAQPS's Citizen Involvement Goals?

Our goals are to:

Help citizens develop the capacity necessary to be stewards of their air resources.
Achieve environmental benefits consistent with the goals of the title V program.
Reorient EPA's approach to implementation of the operating permits program to increase EPA's effectiveness in supporting citizen participation.

How does OAQPS Intend to Implement its Plan for Citizen Involvement?

The OAQPS proposes to adopt a three-part strategy for implementing its plan:

Build external capacity through citizen training.
- The OAQPS plans to work with EPA's Regional Offices to offer an introductory level training to citizens in each Region in FY00. This training (which would probably be State-specific) would cover how and when citizens can participate in the title V permit issuance process, with emphasis on reviewing draft permits. OAQPS expects that State permitting agencies will be involved in presenting information at these workshops.The OAQPS and Region V are revising the introductory course materials developed for a pilot citizen participation training program held in Ohio in May 1999.
- In addition, in FY00 OAQPS plans to offer an advanced training workshop for citizens who have completed the introductory training, are already engaged in reviewing permits, or are otherwise ready for a more technical training on the major issues involved with permit review and implementation of the permit program. The OAQPS would have the lead on developing and supporting the advanced training. In FY01 and beyond, EPA hopes to continue refining and offering this training.
- The OAQPS plans to develop in FY00 an appropriate cooperative agreement to support both introductory and advanced citizen trainings, which will provide OAQPS assistance in planning, curriculum development, and logistical coordination for this citizen training.
Improve citizen access to existing environmental data and information.
- The OAQPS plans to reach citizens and communities by improving its website in FY00 to better explain the operating permit program, to identify the opportunities that citizens have to become active in the program, and to link citizens to the data, information and resources they need in order to raise their concerns about permitting decisions.
- The OAQPS plans to develop a citizens' handbook in FY00 on the title V program that will describe how citizens can effectively participate in the program.
Enhance integration of citizen involvement principles into the title V program.
- The OAQPS plans to develop better lines of communication with citizens, identify and remove impediments to citizen participation, and develop program guidance on citizen participation requirements for use by permitting agencies. As a first step, OAQPS believes that the outreach components of this plan (trainings and improved access to information) will help OAQPS identify and establish a dialogue with citizens who want to provide input to OAQPS as it develops regulations and policies that shape the title V operating permits program. This outreach will also enhance communication between Regional Offices and citizens. Furthermore, the outreach components will identify barriers to effective citizen participation and help EPA (1) prioritize areas for improvement and (2) develop the most appropriate solutions. For example, discussions with citizens who attended the pilot citizen training have resulted in a list of citizens' concerns with the title V program, primarily relating to access to information from State permitting authorities. The OAQPS proposes to develop appropriate guidance in FY00 to assure that Title V programs are implemented in a manner consistent with the federal requirements for citizen participation, affording citizens the opportunity to provide input to and work collaboratively with permitting agencies to protect air quality.
- In addition, OAQPS plans to work with the Regional Offices to integrate the goal of citizen participation into program policy and review of title V program implementation by permitting agencies. The EPA will take advantage of current oversight mechanisms and other relationships with permitting agencies as effective tools for enhancing citizen participation within their programs, where needed.

How will OAQPS Measure the Success of its Plan for Citizen Involvement?

The OAQPS must be able to demonstrate the progress it makes toward realizing its citizen participation goals.

To measure changes in the public's capacity to engage in the title V permitting process, OAQPS will use the following:

Number of Comment Letters Received on Draft Permits
Number of Interested Citizens Trained
Citizen Accesses to EPA Web Page
Presence, Size, and Activity Level of Formal Citizen Network .
Citizens' Qualitative Assessment of Citizen Training
Periodic Qualitative Consultation with Citizens re: Additional Steps to Improve Effective Participation
Qualitative Assessment of Permit Changes Resulting from Citizen Participation
Number of Citizen Petitions to EPA to Object to a Permit

To measure EPA's progress towards incorporating citizen participation into program policy and review of title V program implementation by permitting agencies, OAQPS plans to measure: