Public Comment

The draft Guidelines for Cumulative Risk Assessment Planning and Problem Formulation
include some strides forward in the agency’s approach to CRAs. However, we at EDGI are
disappointed that the guidelines provide very little guidance for risk assessors to actually
integrate cumulative risks into their assessment process.

This comment and a related oral comment were delivered to the FOIA Advisory Committee. The comment urges the FOIA Advisory Committee to guide agencies to preserve key features of FOIAonline as agencies launch independent FOIA portals, particularly: (1) the public posting of completed requests, (2) the ability to search for completed requests, including across multiple agencies, and (3) the preservation of public access to the records that have already been made public through FOIAonline.

We urge the CFO Council to consider the federal efficiencies that can be gleaned by providing
browsing and powerful search functioning in agency or government-wide FOIA portals. The
better the public is able to browse and search material that has already been laboriously
collected, collated, and disseminated by agency FOIA officers, the fewer duplicative requests
will be filed. Moreover, through a more effective review of previously disseminated records, the
public will be able to file more specific requests, substantially improving efficiencies in terms of
producing more narrow requests and reducing time-consuming clarification communications.

This comment and a related oral comment were delivered to the Chief FOIA Officers Council. The comment petitions the Chief FOIA Officers Council to maintain and improve the public accessibility of records released through FOIAonline when agencies launch independent FOIA portals, especially through (1) maintaining the public availability of all previously released documents, (2) enhancing the search functionality to support discovery of already released records, and (3) developing a browser-based viewing system to view records prior to download.

EDGI supports the thoughtful and thorough recommendations presented by OIRA, and we
want to bring attention to a key obstacle to public engagement that is not addressed by
these recommendations: the lack of required regulatory information on agency websites.
Without addressing this policy gap, the effectiveness of other fruitful recommendations,
such as “Make regulatory material more accessible and useable by members of the public,”
will be severely curtailed

Comment Title: “Comments by the Environmental Data and Governance Initiative on Broadening Public Engagement in the Federal Regulatory Process.” This comment urges the Office of Information and Regulatory Affairs (OIRA) to address information policy gaps that will undermine efforts to broaden public engagement in regulatory affairs, particularly the lack of requirements for regulatory and related information to be shared through agency websites.

We generally support the CEJST methodology, and believe it can deliver tangible benefits to
communities. With that goal in mind, we believe CEQ should consider:
EDGI’s Comment on CEQ-2022-0002 1
1. Expanding the list of communities (Census tracts) based on the inclusion of
additional criteria, namely, indicators related to the enforcement of and
compliance with environmental protection laws. We find that an additional 107
tracts could be added by including these indicators.

Overall we commend the proposed themes and framework
for NCA5, and offer additional recommendations to strengthen the reception and
utilization of the information provided by this assessment.