The Public Interest Law Center signed on to a letter to the Environmental Protection Agency (EPA) regarding their Notice of Proposed Rulemaking (NPR) hearings.
The objective is to request additional hearings to be scheduled to ensure that the opportunity for meaningful participation is given to community-based, regional and national activists and advocates.
The letter, written by Earthjustice, raises objections to EPA’s arrangement of the hearings and their lack of effective outreach efforts. EPA’s Guidance recognizes that “involving environmental justice communities in a meaningful way presents challenges and opportunities than those presented by the general public and offers a number of specific ways in which agency rule-makers should overcome barriers, such as disseminating information using local radio stations and newspapers, conveying issues in ways that are tailored to each population (e.g. through timing and location), and various means of developing trust, among others (Id. At 33-34).” EPA seems to have paid no heed to this guidance in arranging the hearings.
The draft of the NPR and tentative dates and locations for the five hearings were made in early December, yet plans for outreach were “still in the works” near the end of the month, and registration wasn’t opened until the 28th. Given that the first hearing was scheduled for January 11th, there was not ample time to learn about the event and mobilize the communities involved. Registration was only available through Eventbrite, which blatantly disregards a majority of the stakeholders in rural areas who are not online and thus have no way of registering. EPA simply posted information on their website announcing their hearings without directly contacting stakeholders, even long-time Title VI advocates who reported that they “heard about the hearings through Earthjustice’s dissemination of the information and the networking of [their] partners.”
Despite there being hearings in multiple places across the country, location is still a major issue. The hearings are not in places where people who are disproportionately affected by environmental contamination can afford to travel. In this letter, it is requested that arrangements be made for remote access so that all affected groups have a chance to be heard.
At the core of the Public Interest Law Center’s ideals concerning environmental justice is the belief that all peoples deserve the dignity of living in a healthy and safe environment. To ensure this, we strive to make sure all people and communities are given a voice in the development of sustainable and healthy places to live, work, and play. It is imperative that EPA provide additional hearings and greater access to the stakeholders and communities involved so that they may have a considerable voice in the matter. We are committed to working with Earthjustice to guarantee significant participation for the affected communities.