I am stepping outside of our remit to send only ocean-specific issues in our newsletters to invite you to engage in Participatory Democracy. In these extraordinary times most of us living beings are looking on with horror as the litany of “Executive Orders” are seemingly devastating decades of conservation laws.
But these laws are not so easily disposed of; the Executive Orders are signed by the President of the United States, not the King of the Entire Universe, so there are processes that must be followed. And because the Citizens of the United States are shareholders in the national enterprise, we have some say in how these orders are (or are not) executed. This is where your efforts come in.
Under the National Environmental Policy Act, any Federal law or action which will have some impact on the natural, cultural, or economic environments of the U.S. must go through a public review and comment phase. Currently under review and public comment is “Executive Order 13777, “Enforcing the Regulatory Reform Agenda,” EPA is seeking input on regulations that may be appropriate for repeal, replacement, or modification.”
The announcement of the public review contains the information you need to file your comments. All comments submitted must be reviewed and considered. While you will not get a personalized response from the reviewers, the Agency (EPA) needs to categorized and respond to all critiques.
A bit of guidance here: As much as you might want to write “What the hell are you idiots thinking?” this type of critique is far too general to qualify as a comment. The types of comments that would have more traction would be “I am concerned that narrowly evaluating regulations in terms of job creation or job elimination will neglect the more systematic function of the regulation to protect the long term health of Americans living in rural communities” Or “I am concerned that the “costs/benefits analysis” stipulated under clause iii of the Executive Order will be framed in the context of short-term corporate profits, and not include the long-term costs and impacts on our national economy.”
Be thoughtful; be detailed; ask for a thorough analysis and justifications for the “elimination of regulations.”
In most cases – where an issue has captured the public’s imagination there may be 1000 comments. EPA Staff review of 1000 comments will take a number of months. If there are enough comments from the public, the review period could take considerably longer. As this Executive Order is the Administration’s keystone strategy for the EPA, we’d like the review process to take years.
Please share with your friends and community, roll up your sleeves and dive into Participatory Democracy!
(Stay tuned for NEPA reviews of other Executive Orders!)