EDGI crafted public comments
The Environmental Data and Governance Initiative
– Environmental Enforcement Watch recommends that this permit be denied, and
underscores calls from Oil and Water Don’t Mix and others for a full Great Lakes
Submerged Lands Act review of Enbridge’s proposal.
We support EPA’s determination to reopen vinyl chloride’s risk prioritization. We encourage the
EPA to go further. The historical evidence shows that the industry has pushed against the
known evidence of harm to communities, workers, and the U.S. public as vinyl chloride
(especially given the replacement of lead piping in the U.S. over the next ten years, likely by
plastic alternatives) enters every waste stream, water stream, and backyard, as “vinyl chloride
can migrate to groundwater and can be in groundwater due to the breakdown of other
chemicals.
This comment stresses that the federal government should strive to increase the tangible impact of public participation in federal decision-making. To do this, EDGI recommends OMB design public participation processes that have the appropriate timing and depth to meaningfully influence government actions, and to develop standards for information management to ensure the public can easily learn about issues and opportunities for input.
Late last fall, the Office of Science and Technology Policy (OSTP) sought to gather information and feedback for developing a coordinated Federal strategy to identify and address gaps in science, data, and research related to environmental justice. EDGI submitted a public comment responding to OSTP’s questions. Below are key points addressed in EDGI’s response: The … Read more
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.