Activity, Law, Purpose
The Comment Period Is Open till February 19
I sat down to write about the anxiety everyone I know is feeling as our democratic institutions are being assaulted, for being a lifelong environmentalist I am being asked what to do. It’s a long story (there’s some discussion below) but there’s something everyone can do right now that is very easy and a very good thing to do.
You can comment until February 19 on the EPA’s proposed Environmental Justice framework for implementing Cumulative Impact assessments.[1]
Once we take Congress in the mid-terms, our representatives should be asked to restore this effort immediately. It says who we are as a people – we believe in fairness. Let no one say that because the current Administration will ignore this that there is no point in doing it, because it is more important than ever to stand for it.
By commenting you do two things: join others in affirming our joint will that our government be just, and draw attention to this tool, which is a significant achievement in the evolution of social responsibility. It took a long time to develop and we should be pleased with how the EPA has kept faith with this idea and worked on it to this point. As the EPA is being dismantled every means we have for embodying the truer reflection of our will – to have a quality environmental protection program and not one that buries some people under enormous burden - will help. This is one important thing that many raised voices can say, and it will be recorded for all history, right at this time of the attempted ending of environmental progress.
[1] https://www.regulations.gov/commenton/EPA-HQ-OLEM-2024-0360-0001
Be sure to put at the top: Interim Framework for Advancing Consideration of Cumulative Impacts
Docket ID Number: EPA-HQ-OLEM-2024-0360
You can comment until February 19 on the EPA’s proposed Environmental Justice framework for implementing Cumulative Impact assessments.[1]
Once we take Congress in the mid-terms, our representatives should be asked to restore this effort immediately. It says who we are as a people – we believe in fairness. Let no one say that because the current Administration will ignore this that there is no point in doing it, because it is more important than ever to stand for it.
By commenting you do two things: join others in affirming our joint will that our government be just, and draw attention to this tool, which is a significant achievement in the evolution of social responsibility. It took a long time to develop and we should be pleased with how the EPA has kept faith with this idea and worked on it to this point. As the EPA is being dismantled every means we have for embodying the truer reflection of our will – to have a quality environmental protection program and not one that buries some people under enormous burden - will help. This is one important thing that many raised voices can say, and it will be recorded for all history, right at this time of the attempted ending of environmental progress.
[1] https://www.regulations.gov/commenton/EPA-HQ-OLEM-2024-0360-0001
Be sure to put at the top: Interim Framework for Advancing Consideration of Cumulative Impacts
Docket ID Number: EPA-HQ-OLEM-2024-0360
During the 1990’s I worked with a policy official at the Massachusetts DEP on various issues (Phil Weinberg). He told me that he was starting up an effort to figure out how to do cumulative impact. I remember conversations about the health data we could look at, and how we could do more granular, closer, more real air and water monitoring. Over the years I was included periodically in the discussions and so had a chance to see how DEP was developing this, never giving up, though the recognition of its complexity grew as the pressures on the department from all sides grew. These pressures were the result of the constant, merciless, unwarranted, unpatriotic attacks by the right wing on anything EPA or an environmentally assertive state did. As I worked in the Toxics Use Reduction program and had to deal with some chemical company trade group representatives lying about us, funding repeal efforts, rallying legislators around nice-sounding ideas that served their interests, I see the simple, cold logic of it in the statement that a man can believe anything if his salary depends on it (Upton Sinclair, H.L. Mencken, others). I’ll never forget the chemical trade association representative, arguing against our Commonwealth’s plan to focus on asthmagens, saying that he himself had asthma, suddenly, in the middle of his rant against us, with no apparent logical point to it – just a moment of humanity revealed, yet no incorporation of that into what he was doing.
We are in an era of disassociation. Economists say the polluting companies don’t see their impacts – that they live in a world of bounded rationality, that these effects on the rest of us are “externalities”.
If we, as a society, behave as if our salaries depend on continued pollution, plunder, etc., we should “wake up” from that bad dream, as the green product and energy sector is here and available. When we rise above the political conflicts we see ourselves in the same hot pot and that we must use our governments to help the responsible companies compete with the dirty dinosaurs. And we need to wind them down in deals like those that are worked out in bankruptcy court concerning companies deep in debt, as these companies are to every living thing and all that will inherit this world.
Though the original intent of the founders was to assert the right to governments that serve us, not some group of overlords, recent legal Supreme Court cases and current executive policy sometimes side with the stomping dinosaurs. Though we have these bleak, dark facts to face it is true that they have gained their positions through juridical and political behavior that does not stand the test of time nor scrutiny. Shedding light on the difference between the exercise of power and legitimate authority is the first step, Recognition of illegitimacy is essential. In the past it was said that the emperor no longer had the favor of heaven. Here we measure the gap between their actions and what we the public are owed as hammered out in long-standing procedure, first, and secondly, what is owed according to just principles. Those who oppose being awake to this great and noble end – to being sensitive to people’s realities – are immature and cruel. They give us nothing to be proud of. Those grinning right now as they dismantle EPA don't care or are gambling they will not themselves pay for future fires, chemical spills, floods, toxics chemicals, heat.
T.S. Eliot may have had certain Hollow Men in mind but these are the ones of our time making of our world a wasteland. Responsibility to human and other life forms has to be at our core or we are a host of ghosts, a strange disease upon the earth. Anti-environmentalists are maybe not so united as we think, and maybe we loyal to flesh and blood are not so divided as we think. They use bluff and threats. We are in a high stakes game and have to keep our cool.
We can fortify each other by learning together, sharing information. They are attacking on every front so this is what will help. We of good will can and must unite.
Taking a moment to say you think EJ is good, and that learning how to implement it, make it real, is a good step, is just one of the many many things we can and should be doing to create the civil society that can stand up to thieves of state. If you think it should be done differently, say so! They are asking for our opinions. By commenting we create a community that says, we must continue the evolution of environmental justice.
This has been decades in the making. The Massachusetts DEP has just instituted a new air permit that looks at more than 200 things. It is a fantastic start on implementation of environmental justice. But federally, the EJ Screens that CA and New Jersey led the way in creating that were up on EPA’s website have been taken down. All the young people who did the work of environmental justice for the EPA have been placed on leave by the White House. The word from the executive is that this was what he was elected to do. Here is a chance to raise your voice for the true vision of the development of responsibility and what has been the real sense of the country about where to go, and still is, and can be again, if asserted.
It took EPA a long time to come up with their framework, which is explained here. EPA FACT SHEET: “Interim Framework for Advancing Consideration of Cumulative Impacts”. Here is where you can read the longer document and see how carefully EPA has planned out an approach to an enormously complex issue, that can be used in any context. Interim Framework for Advancing Consideration of Cumulative Impacts. It should be used as a basis for future work, and a model for other agencies having a say concerning impacts on communities.
The longer story is to promote ethically participating in democracy – find out how to be a delegate to party conventions, and go and help choose the candidates. Vote out those who shun the public interest. Go to meetings and when you hear good ideas work with others to propose and/or implement them. Target the Republicans who want to be elected again and won’t be if they go along with this violence. Learn how to engage in our amazing democratic system, which can be rather efficient at meeting our needs, if not the needs of those who want more money or power over others, (and already have enough).
The Administrative Procedure Act of 1946 is one example. It establishes the requirement of giving notice to the American public of new rules, new policies. It gives each citizen the role of commenting, of being an individual point of judgment and conscience that has a role in formulating our laws. You can participate in it so easily. You don’t have to think they have everything right here. The point is that this Administration is claiming we don’t need this stuff, it is claiming we don't want it!
Let's show them they are wrong. Let the American people be heard on everything that is happening – we can bring our voices together – here is just one place, one example, where each of us can say, this is the future we want. This is the government we want, one that is fair and just and which works to meet that standard. Keep this up. Implement it as soon as you can.
We are in an era of disassociation. Economists say the polluting companies don’t see their impacts – that they live in a world of bounded rationality, that these effects on the rest of us are “externalities”.
If we, as a society, behave as if our salaries depend on continued pollution, plunder, etc., we should “wake up” from that bad dream, as the green product and energy sector is here and available. When we rise above the political conflicts we see ourselves in the same hot pot and that we must use our governments to help the responsible companies compete with the dirty dinosaurs. And we need to wind them down in deals like those that are worked out in bankruptcy court concerning companies deep in debt, as these companies are to every living thing and all that will inherit this world.
Though the original intent of the founders was to assert the right to governments that serve us, not some group of overlords, recent legal Supreme Court cases and current executive policy sometimes side with the stomping dinosaurs. Though we have these bleak, dark facts to face it is true that they have gained their positions through juridical and political behavior that does not stand the test of time nor scrutiny. Shedding light on the difference between the exercise of power and legitimate authority is the first step, Recognition of illegitimacy is essential. In the past it was said that the emperor no longer had the favor of heaven. Here we measure the gap between their actions and what we the public are owed as hammered out in long-standing procedure, first, and secondly, what is owed according to just principles. Those who oppose being awake to this great and noble end – to being sensitive to people’s realities – are immature and cruel. They give us nothing to be proud of. Those grinning right now as they dismantle EPA don't care or are gambling they will not themselves pay for future fires, chemical spills, floods, toxics chemicals, heat.
T.S. Eliot may have had certain Hollow Men in mind but these are the ones of our time making of our world a wasteland. Responsibility to human and other life forms has to be at our core or we are a host of ghosts, a strange disease upon the earth. Anti-environmentalists are maybe not so united as we think, and maybe we loyal to flesh and blood are not so divided as we think. They use bluff and threats. We are in a high stakes game and have to keep our cool.
We can fortify each other by learning together, sharing information. They are attacking on every front so this is what will help. We of good will can and must unite.
Taking a moment to say you think EJ is good, and that learning how to implement it, make it real, is a good step, is just one of the many many things we can and should be doing to create the civil society that can stand up to thieves of state. If you think it should be done differently, say so! They are asking for our opinions. By commenting we create a community that says, we must continue the evolution of environmental justice.
This has been decades in the making. The Massachusetts DEP has just instituted a new air permit that looks at more than 200 things. It is a fantastic start on implementation of environmental justice. But federally, the EJ Screens that CA and New Jersey led the way in creating that were up on EPA’s website have been taken down. All the young people who did the work of environmental justice for the EPA have been placed on leave by the White House. The word from the executive is that this was what he was elected to do. Here is a chance to raise your voice for the true vision of the development of responsibility and what has been the real sense of the country about where to go, and still is, and can be again, if asserted.
It took EPA a long time to come up with their framework, which is explained here. EPA FACT SHEET: “Interim Framework for Advancing Consideration of Cumulative Impacts”. Here is where you can read the longer document and see how carefully EPA has planned out an approach to an enormously complex issue, that can be used in any context. Interim Framework for Advancing Consideration of Cumulative Impacts. It should be used as a basis for future work, and a model for other agencies having a say concerning impacts on communities.
The longer story is to promote ethically participating in democracy – find out how to be a delegate to party conventions, and go and help choose the candidates. Vote out those who shun the public interest. Go to meetings and when you hear good ideas work with others to propose and/or implement them. Target the Republicans who want to be elected again and won’t be if they go along with this violence. Learn how to engage in our amazing democratic system, which can be rather efficient at meeting our needs, if not the needs of those who want more money or power over others, (and already have enough).
The Administrative Procedure Act of 1946 is one example. It establishes the requirement of giving notice to the American public of new rules, new policies. It gives each citizen the role of commenting, of being an individual point of judgment and conscience that has a role in formulating our laws. You can participate in it so easily. You don’t have to think they have everything right here. The point is that this Administration is claiming we don’t need this stuff, it is claiming we don't want it!
Let's show them they are wrong. Let the American people be heard on everything that is happening – we can bring our voices together – here is just one place, one example, where each of us can say, this is the future we want. This is the government we want, one that is fair and just and which works to meet that standard. Keep this up. Implement it as soon as you can.
RSS Feed
