I appreciate the opportunity to provide input. DEQ and all citizen boards should adjust their public participation regulations to prioritize Environmental Justice.
I offer the following recommendations:
For any regulatory action:
- Institutionalize a hybrid option of virtual and in person to both submit comments and to participate in any public hearing, RAP or other function. This could include an answering service and virtual participation in any regulatory function. In addition, hearings or other functions related to regulatory actions should be held at accessible times outside of regular work hours as well as accessible to communities physically.
- DEQ, citizen boards and Environmental Justice office should identify EJ communities as defined by the Virginia Environmental Justice Act, notify, appropriately consult and engage with those communities each time there is a regulatory action
- Do not discount, discard or "count as one comment" if citizens submit form letters or similar comments. That should not discount the value or weight of their input.