59 comments
I am Kay Ferguson of ARTivism Virginia. Our work is to serve rural communities threatened by proposed new fossil fuel infrastructure. I am glad to be able to share with you what we have consistently found when we have arrived in those communities over the last 4 ½ years. Deers in the headlights. Folks who consistently find out about a permit when it is just about to be approved and who are scrambling not only to understand the health and environmental science of the proposed project but also to understand how to participate in your regulatory process. I have witnessed this scramble and its related difficulties in Union Hill, Charles City County, Norfolk, Bent Mountain and in other rural communities along the now cancelled Atlantic Coast Pipeline and the still active Mountain Valley Pipeline. Most recently our work with the Pittsylvania County NAACP has again revealed this deers in the headlights scrabble, panic and struggle.
So from my seat your public engagement is inadequate and often punishing and silencing and I am glad you are preparing to change that.
Many needed changes come to mind, among them: give notice to and engage with directly impacted communities when the project is first proposed and before formal application is filed and not when the permit is finished; give notice that actually reaches the community; institute forums where questions can be asked and answered by those wielding permit power; hold public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; give more advance notice of when public hearings will be held; allow citizens access to Citizen Boards that does not go through and is not edited by the DEQ, allow citizens to register to speak at public hearings in advance and in person day of; hold public hearings in public or citizen sponsored venues and not in private hotels. And yeah, don’t march armed police around the edges of hearing rooms while citizens are speaking. Come down off your dais and foster dialogue.
DEQ’s 2020 Environmental Justice Report from Skeo Consultants is a good resource as you seek better and more public engagement. I recommend it to you as a guide for future policy and action. Four of the nine action items recommended by the report outline and give vast resources for and examples of better public engagement.*
These are details and I don’t want to omit noting that at this point in our scientific history, these details are akin to standing together in a room with gasoline up to our ankles and arguing over how many more matches we are each going to get. There is no rational justification for any new fossil fuel infrastructure at this moment in our planet’s history.
I will close by questioning the legality of your declaration that mention of certain topics during your public forum are forbidden and noting that after I have worked with an impacted community for months, participated in all your rules for public comment, gotten up early and driven long distances - all to earn 3 minutes of your time, I will speak about any damn pending project or permit I please. And I assure you that if this comment is stricken from your public record because I say Lambert Compressor Station or MVP today, I will sue you to test the legality of this silencing.
*In brief those four action items re public engagement from the Skeo report are:
5. Accessible Information: Develop tools to provide more transparent, accessible and real-time environmental information to the public.
6. Relationship Building: Invest in proactively building productive relationships with environmental justice and other adversely impacted communities.
7. Community Engagement: Proactively and authentically engage communities on issues and decision-making that could potentially affect their health and quality of life.
8. Environmental Justice Community Capacity: Build the capacity of environmental justice communities to participate meaningfully in environmental decision-making.
Here is the link to the Skeo report: https://www.deq.virginia.gov/home/showdocument?id=8624
Kay Ferguson, ARTivism Virginia
1050 Broomley Road
Charlottesville, VA 22901
To whom it may concern:
These are the changes needed to the DEQ's public participation policy. As residents of the Commonwealth we have the right to have our voices heard.
Thank you for changing policy so that our participatory democracy is more robust. This is vital regarding projects that impact people's very lives and critical if we are to eliminate environmental racism.
Sincerely yours,
Michele Mattioli
Charlottesville, VA
Dear DEQ,
I am with Friends of Rattlesnake Creek (RC) and am heartened that you are taking up this much-needed review of your public outreach processes. Based on our experience this past winter, which led to the withdraw of access by a key homeowner and the demise of the RC project, communication shortcomings resulted in frustrations all the way around (including community members, the DPU leadership and City Council).
It is true that some form of cursory public hearings for the project occurred at an earlier time (as much as 5 years earlier). But at that time, critical aspects of the project were not shared with the public (e.g., that an environmental impact study was not conducted, that the source of the problem—the upstream watershed—was not adequately addressed, that the limit of disturbance involved clearing of as much as 100' from one side to the other., etc.).
Most of the Friends of RC were not living in the area when that earlier public hearing occurred. Further, the way they found about the impending project this past fall was by the neighbor—the very person who had agreed to allow access to RC in fall 2020, and ultimately rescinded that agreement after the full measure of the destructive so-called “restoration” project was exposed by the Friends.
Here are two lessons learned from that debacle:
Thank you for your serious attention to these and other concerns (time of day, location, advance notification, response periods, etc.).
Bill Mth
1130 West Ave
Richmond, VA 23220
Your public engagement is inadequate and often punishing and silencing and I am glad you are preparing to change that.
Many needed changes come to mind, among them: give notice to and engage with directly impacted communities when the project is first proposed and before formal application is filed and not when the permit is finished; give notice that actually reaches the community; institute forums where questions can be asked and answered by those wielding permit power; hold public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; give more advance notice of when public hearings will be held; allow citizens access to Citizen Boards that does not go through and is not edited by the DEQ, allow citizens to register to speak at public hearings in advance and in person day of; hold public hearings in public or citizen sponsored venues and not in private hotels. And yeah, don’t march armed police around the edges of hearing rooms while citizens are speaking.
DEQ’s 2020 Environmental Justice Report from Skeo Consultants is a good resource as you seek better and more public engagement. I recommend it to you as a guide for future policy and action. Four of the nine action items recommended by the report outline and give vast resources for and examples of better public engagement.*
*In brief those four action items re public engagement from the Skeo report are:
1. Accessible Information: Develop tools to provide more transparent, accessible and real-time environmental information to the public.
2. Relationship Building: Invest in proactively building productive relationships with environmental justice and other adversely impacted communities.
3. Community Engagement: Proactively and authentically engage communities on issues and decision-making that could potentially affect their health and quality of life.
4. Environmental Justice Community Capacity: Build the capacity of environmental justice communities to participate meaningfully in environmental decision-making.
Here is the link to the Skeo report: https://www.deq.virginia.gov/home/showdocument?id=8624
Emily Little, RN
As a spiritual person of conscience, I believe that the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in-person and hybrid opportunities; hold public hearings at times that are accessible to full-time workers; and give more advance notice of when public hearings will be held.
For the people, by the people should guide the initiation, planning and implementation of regulations of government. To assure engagement of ALL of the people must be the primary criterion and needs to assure diversity, inclusion and equity within the systems, functions and processes. Those people directly impacted by the outcome of a regulation must be the ones engaged in creating the prescription. Anything less is authoritarian manipulation and cannot be allowed to exist.
Question: Do you want decisions about your well-being, your future, your quality of life, decided by people who do not know who you are and your expectations? HELL NO!
Citizens of the state, particularly those most impacted by Department of Environmental Quality approvals of projects, need more and easier opportunities to provide input. Rather than being “available” for input, the department should find more proactive ways to include the community and PARTNER for the overall good of citizens. Lobbyists for Dominion and other large companies have far more access and influence than the people living in the areas impacted by projects. We need to focus on cleaning up past problems and holding those corporations responsible for them. The updated process must include proactive gathering of input on prioritizing cleanup projects already on the backlog and improving overall Environmental Quality.
As a person of faith, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
It is important that the people without money and without political power have the chance to be involved in decisions that impact them. Think about Flint Michigan and their water problem. It is important to provide information and to seek participation from those impacted by regulatory decisions.
We are persons of conscience, and we believe that it is important for the voices of marginalized communities across the commonwealth to be heard, prioritized, valued, and empowered in all decision-making processes. Too many times, folks in vulnerable places are not given opportunities to understand the impact proposed changes will cause to them, their families, and communities.
As a resident of Virginia, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
Please improve on the DEQ's outreach process. People in every community that is impacted by actions for which the DEQ has responsibility should have a chance to be heard. Be it pipelines, mining, roads, industry, or any other land use and/or other environmental quality issue, anyone who lives in Virginia, breathes in Virginia, drinks water in Virginia or otherwise enjoys our beautiful commonwealth deserves a voice. Wealth or its lack, skin color, political power and other differences should give no group more or less opportunity to determine their quality of life. The voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in-person and hybrid opportunities; hold public hearings when accessible to full-time workers; and give more advance notice as to when public hearings will be held.
As a person of conscious, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
As an agency you have the responsibility to make public comment easy and transparent. Too often highly affected communities are marginalized in the comment process. It is important that you do all you can to expand public comment opportunities so that the taxpaying citizens can be heard.
As a person of conscious, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
As a person of conscious, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers (considering times when most workers in the community are available, not only times convenient to people who can take leave to come speak); and give more advance notice of when public hearings will be held.
As a person of conscience, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes.
In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
thank you,
Michael Fox
Ashburn
The voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. The regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
As a person of conscious, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
The voices of marginalized communities across the commonwealth need to be recognized, valued, and engaged in those decision-making processes that affect the communities, directly and indirectly. In doing so, the regulation changes should include: earlier involvement of communities, scheduling of public hearings on permits in the directly impacted communities soon enough to process community concerns and recommendations. The opportunities to engage should include in-person and hybrid opportunities; arrange and hold public hearings to enable participation of workers whose hours may conflict with meeting times; and better publicize advanced notices of times and locations of public hearings.
I believe the voices of all people across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
This process needs to be open to everyone and especially those in the most affected areas. Please make it easy for everyone to give voice to their concerns by giving plenty of notice beforehand and having convenient times when full-time workers can attend.
Representation in decision making and ownership of the results should be fair and equitable across the state.
Thus, the regulation needs to include: scheduling public hearings on permits to be held in and for the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held, throughout a variety of media. Also, make clear the impacts involved in the decision. We need more equity and more forethought.
The voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. To ensure that everyone has a voice, public outreach regulation needs to include requirements to schedule public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities, hold public hearings when accessible to full time workers and give adequate advance notice of when public hearings will be held.
As a person of conscious, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
I urge you to prioritize and value the voices of marginalized communities across Virginia. To help achieve this, your regulations need to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in-person and hybrid opportunities to participate; hold public hearings at times when full-time workers can attend; and provide more advance notice of when hearings will be held.
Thank you.
"As a person of conscious, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held."
As a person of conscious, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
It has been all too clear that the voices of minorities, the poor and otherwise marginalized people have not been heard on policy decisions that impact their lives. Therefore, I urge you, as a person on conscience, to make public hearings regarding permits as accessible as possible. This would include timing, location - in the communities impacted- and perhaps both in person and virtual opportunities to hear and be heard. Adequate advance notice is also important.
"As a person of conscious, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held."
As a person of conscious, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
Thank you,
J. Abbate
To bring about environmental fairness and justice, the voices of marginalized communities across the commonwealth need to be heard, valued, and prioritized in all decision-making processes. The regulation needs to require public hearings on permits in the directly impacted communities early in the process, with both in person and hybrid opportunities, and at times when full time workers can attend. It should also require more advance notice of when public hearings will be held. The people who are most affected and who have historically been ignored need to finally have a voice.
As a person of conscience, I believe the voices of marginalised communities across the commonwealth need to be prioritised, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held.
DEQ definitely needs to retain and improve its public participation program and its implementation. Needed changes include more efforts to connect with communities of color who will be impacted by environmental decisions being considered by the State. All voices need to be heard. Improving access might include making meetings hybrid with both in-person and digital participation options and scheduling sessions when people who work would be available. The State definitely needs to do a better job in this area.
As a person of conscious, I believe the voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include: scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities; hold public hearings when accessible to full time workers; and give more advance notice of when public hearings will be held
Minority and low income communities have born the brunt of environmental problems, historically, often because they had no voice in actions (or in-actions) that affected them. I urge the DEQ to do all they can to make it easier for such communities to have public input to DEQ proposals early in the process. Improving publicity for input requests, location of public meetings in affected communities, and timing of meetings to allow participation by day workers are examples.
Public comment is essential for effective DEQ regulation of air and water quality, water supply and land protection. And it is especially important to hear from those impacted the most by DEQ decisions and actions.
The essential comment regulation needs to include well-publicized public hearings scheduled early in the process and held in directly impacted communities at times convenient for full-time workers. Providing public comment should be available for in person and for hybrid opportunities, such as electronic submission, in order to gather broad input and ensure all voices are heard.
Thank you for the opportunity to comment on the DEQ public participation regulation.
Cheryl Umbel
I believe that the voices of marginalized people should be heard:
Hello. My name is Natalie Pien. I am a retired public-school teacher from Leesburg, VA. I was a middle school science teacher and sponsored an Ecology Club for students to make personal connections to Nature and appreciate Virginia’s natural resources. Thankfully, for my students in Loudoun County, Virginia has the Department of Environmental, DEQ. DEQ’s Quality Mission, Vision, and Values statements reflect a commitment to protect & enhance Virginia’s environment as well as promote the health and well-being of all Virginians. Regrettably, for less affluent, rural, and often communities of color, the DEQ fell short and commissioned an environmental justice report conducted by SKEO, https://www.deq.virginia.gov/home/showdocument?id=8624. It includes four action items related to public engagement:
5. Accessible Information: Develop tools to provide more transparent, accessible and real-time environmental information to the public.
6. Relationship Building: Invest in proactively building productive relationships with environmental justice and other adversely impacted communities.
7. Community Engagement: Proactively and authentically engage communities on issues and decision-making that could potentially affect their health and quality of life.
8. Environmental Justice Community Capacity: Build the capacity of environmental justice communities to participate meaningfully in environmental decision-making.
Adopt these recommendations.
In addition to the SKEO report, I endorse the technical advocacy letters from Chesapeake Climate Action Network, Protect Our Water Heritage Rights, Sierra Club, and Appalachian Voices.
Finally, I would like to make my own, simple recommendations. Public notification could be improved if:
Thank you for the opportunity to share my comments with you.
Sincerely,
Natalie Pien
20644 Gleedsville Rd
Leesburg, VA 20175
natcpien1@gmail.com
The citizens and residents who live near and would be most affected by decisions deserve to have their opinions heard. Often marginalized populations are where the most dangerous polluting factories, refineries, mines, pipelines, dumps, etc choose to locate - both because property is cheap and knowing poor people can not afford the same type of legal protection as more wealthy ones.
It is IMMORAL to allow innocent people to suffer! Since many of them have little or no access to the computer, there MUST be public hearings that are well publicized in the affected areas to allow them to weigh in on decisions that will affect them more than anyone else!
The voices of marginalized communities across the commonwealth need to be prioritized, valued, and empowered in all decision-making processes. In doing so, the regulation needs to include:
1) Scheduling public hearings on permits in the directly impacted communities earlier in the process and with both in person and hybrid opportunities
2) Hold public hearings when accessible to full time workers, and
3) Give more advance notice of when public hearings will be held.
Currently on DEQ's Topics of Interest menu, https://www.deq.virginia.gov/get-involved/topics-of-interest there are five items. So I navigate to each item, looking for how to sign up to receive updates, and it is different for each, if it is available at all.
Proposed solution: let me check boxes on all the topics I wish to be updated on. Let me choose to get either a text notification or an email that topics have been updated, with a link to the relevant website. Automate this (since it seems I really need to spell it out).
What is inexcusable is the situation at present (August 19, 2021).
Green Ridge Landfill - only option is to be put on contact list of the permit seeker. I don't want them to be in contact with me! I want to know I am getting DEQ updates. I see that there are no public hearings scheduled yet - why would the permit seeker even want to notify me?
Mountain Valley Pipeline - NO option to be put on any notification list. Are they buried in submenus? Not on a cursory look.
Radford Army Ammunition plant - 'sign up for constant contact' is a link in the body of the information part-way down the page.
Tidewater Air Monitoring Evaluation Project - better. Over on the right under 'Resources' is a 'TAME email list'. You have to click on it to see that is is a sign-up, as ambiguously, it could be a list of contacts regarding the project.
Volkswagen Settlement Agreement: Fine - under resources the top item is 'Sign up to receive updates'.
Also annoying is that the gray menu on the left appears and disappears depending on the topic page you navigate to.
A few years ago, I heard residents of Union Hill talk about the noise pollution, air and water pollution, environmental destruction and inherent danger of living in the vicinity of a compressor station that was scheduled to be built in their town, I saw environmental INJUSTICE at work. This inspired me to lend my voice in areas where community feedback was being sought.
In order to ensure that vulnerable communities which are at the greatest risk of climate change impacts, positioning of dangerous, noisy and polluting fossil fuel facilities, and pollution exposure, the DEQ MUST improve its Public Participation Guidelines to be more inclusive. Here are some suggestions:
Hi, my name is Christine and I’m a native Virginian living in Floyd county. I work as a User Experience designer, making websites and online services easier to use. There are some simple things this board can do to make it easier to get the community feedback needed to make informed decisions:
thanks!
People who have less of a political voice and less economic clout especially need to be able to speak up and speak out!
In my personal experience, meetings held designed to be open for "public participation" are rarely accessible to those communities in which the decisions made at said meetings will affect the most.
Most recently, the meeting about the Lambert Compressor Station was scheduled to be held in the middle of the work day, in Richmond, 3 hours south of the community in which it would most affect. This is not an acceptable format for public participation nor is it remotely accessible for those it claims to be.
Below are some changes I would like to see in order to improve accessibility to those groups most often affected by environmental degradation and development.
Regarding the notification list:
- DEQ should maintain a list of people and organizations in EJ communities that should be notified when regulatory changes are proposed. The EJ office could maintain that list.
- To determine who is an EJ community use the definition from the EJ act 2020.
Regarding the public hearings on regulations:
-The notices for public hearing should be posted on the town hall and commonwealth calendar 15 days prior instead of 7 as is right now
Regarding the public comments:
- A minimum of 60 calendar days to respond following the publication of a notice of periodic review instead of the 21 days. This will allow community members to be informed and prepare comments.
- As much as possible, meetings should be held with options to participate both in person and virtually.
-Public notices and technical materials should be provided or available upon request in multiple languages.
-Meetings should be held at times that are accessible to those most affected by the decisions being mad. 9-5 meetings exclude the most vulnerable communities that must provide for their families during these hours.
All DEQ staff must be training in Environmental Justice and how to receive and process comments to avoid violating rights and breaking the law.
I am very concerned about the unresponsiveness of DEQ to public comments. The agency seems to have made its mind up about permits prior to opening the public comment period. The DEQ staff responses to comments seem to be merely justifications for not considering the input from the public.
There is too much control by the regulatory agency. If cases are elevated to a citizen board, please create a process when board members hear from the applicant, regulator and public in a fair way without DEQ having an upper hand to privilege or bias information.
Our citizen boards need to regain independence and to carry out all roles granted to them in their statues. DEQ and Commonwealth attorneys often suggest Board Members do not have authority to make decisions when in fact they do.
We need to uphold the 2020 EJ Act.