The Environmental Protection Agency (EPA) is collecting ideas from the public on what its enforcement and compliance priorities should be for the next three years (the 2011-2013 fiscal years). These priorities address the most pressing environmental problems and are accompanied by strategies to tackle the problems. The public may comment on an online forum on the EPA's blog until Sept. 30.

The office in charge of this effort, EPA's Office of Enforcement and Compliance Assurance (OECA), develops a new list of priorities every three years. It last gathered public comment in 2007 for its 2008-2010 National Priorities. The current National Priorities include ensuring compliance with the Clean Water Act by factory farms and sewer systems, as well as enforcing specific violations of the Clean Air Act, Resource Conservation and Recovery Act (RCRA), and other priorities.

 

This same EPA office has begun a similar online forum to gather ideas for improving water quality. The EPA's Office of Solid Waste and Emergency Response took the lower-tech route of sending an email to stakeholders asking for comments on how to improve that office's transparency and effectiveness – although another online forum is promised for the near future.

 

To guide the online process, EPA is soliciting comments on three specific topics: EPA’s selection criteria for priorities, suggestions for future environmental priorities, and providing information for public use. Within each topic are 1–3 specific EPA-written questions. It is in response to these questions that the public may comment. (Based on recent reports, I suggest the agency boost its enforcement of the Clean Water Act, for a start!)

EPA really doesn't want to hear ideas outside the purview of these questions. They disabled the feature that would allow someone to make a comment on the entire post or the whole set of questions. To some degree this makes sense. Previous Obama administration attempts at using Web 2.0 technology to gather ideas from the public encountered difficulties keeping the comments germane, with posts often being wildly off-topic or beyond the agency's jurisdiction.

Many of the off-topic comments may be the result of a public that feels it has so few opportunities to communicate with the government that when given an opportunity, people cannot be confined to narrow issues.

I do not want to see the use of online forums become the preferred tool to engage the public at the expense of the numerous other tools available to EPA. Many advocates for the environment still draw on the Federal Register for news of government initiatives and the chance to comment. Public meetings and conference calls and webcasts should also be used. EPA has regional offices throughout the nation that can host meetings to gather comments – and foster actual discussion.

The big question is: Will EPA actually listen to the public comments and react? (We might get an answer regarding the clean water enforcement online forum on Sept. 30, when OECA must submit a report to the EPA administrator.) The deadline for commenting in this round is Sept. 30. EPA plans to open a second round later in the fall, to close on Dec. 1. The agency did not explain how the second round will be different from the first, but hopefully it will incorporate the ideas it received from the first round and provide an opportunity for participants to comment on, edit, and rank the ideas.

Additionally, I would love to see an actual two-way conversation - not just commenters responding to EPA's prepared questions, or to each others' posts, but rather to have EPA staff respond to the posts. For example, if the staff are uncertain about what a commenter meant, or if staff feel a proposal would be too difficult for reasons X, Y, and Z, then they would say so on the forum. Then the commenter could reply back explaining how reasons X, Y, and Z might be easily solved. In other words, use the internet to create a true dialogue between the public and the public servants to make government work better and more transparently and build confidence in government.

Ideally, such forums allow citizens a chance to share their expertise, without the traditional gatekeepers sucking up all the attention. As vitally important as our NGOs are – with their years of experience and hard work – the Sierra Clubs, Greenpeaces, and OMB Watches of the world do not have all the answers. It may take some time to get the system designed right and to get both the government and the public accustomed to it, but the EPA is on the right track.