Association for Public Policy Analysis & Management

Public policy research spanning more than 50 years finds that environmental pollution is a key determinant of environmental agency responsiveness in the US though there are myriad factors, actors, and contexts that can either enable, or attenuate the influence of public participation in regulatory risk-based decision making. Due to devolution and delegation of authorities, environmental governance in the context of hazardous air permitting falls largely to state environmental agencies, and the tensions between civil society’s democratic values, environmental risk conceptions, and technocratic codifications have been emphasized in the public policy and administration literature. Using a novel theoretical perspective drawn from conflict and participation theories, the key aim of this study is to explore the linkages between contextual, organizational, and value-based characteristics of public comments and consequent agency responsiveness within the Resource Conservation and Recovery Act risk-based permitting process.

Regulatory risk assessment is an inherently uncertain process that operates in the penumbra between absolute empiricism and total communicative rationality. Despite troubling environmental impacts from hazardous air, the toxicological uncertainties regarding exposure to very low levels of air toxics, and the delegitimizing effects of routinized application of policy process routines rooted deeply in technical rationality, there remains a paucity of studies that provide a portal into these challenges. Findings from this investigation could help inform federal and state policymakers into the ideals expressed in contemporary risk assessment and environmental regulatory policy. Further, this examination could reveal institutional and epistemological barriers that might dampen robust agency responsiveness and prompt plans of action to help invigorate civic competence as it pertains to the public comment process within a democratic participatory framework.

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NB: This will not be a completed study by the time of the conference, but it is a proposal for a study for which I will have the literature review and methodological sections drafted by the time of the conference in order to obtain feedback and audience input. Should this be more appropriate to submit as a poster, given its somewhat nascent stage, I would be happy to receive that guidance. Best, -Andy