Virginia Regulatory Town Hall
Department of Environmental Quality
State Water Control Board
Public Participation Guidelines [9 VAC 25 ‑ 11]
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8/20/21  8:44 pm
Commenter: Zander Pellegrino

Meaningful engagement for all

As a member of the environmental advocacy community and engaged Virginia resident, I shared this comment period with friends and neighbors. We even hosted a comment writing party to share information about the scope of this comment period, the power and composition of the DEQ and boards and the difference between regulatory and permitting decision.


Many friends and attendees had impassioned and moving stories of environmental injustices in Virginia. They had ideas to move our state closer to meaningful public participation from their previous experiences (and sometimes lack of meaningful engagement) with VA’s environmental regulators. Other attendees’ ideas came only after building trust and sharing possibilities. They did not have preconceived notions for how to improve public participation but after small groups and hearing others’ stories, they felt comfortable making their voices heard.


What both of these groups had in common is that hardly anyone was signed up to be notified of periodic regulatory reviews on Town Hall. There were not aware of this process but they are certainly all impacted by it.


I share this because it illustrates a problem with our reality and hopefully can lead to a picture for our future. Decades of neoliberal policies like state retreat, privatization and defunding of environmental causes created a situation where us environmental advocates supplement government outreach processes. Holding comment parties on a fairly narrow periodic review is ok, but I want a future with more meaningful participation that can reach frontline communities.


I want to live in a state where Virginia regulators (like DEQ’s EJ Coordinators) held multilingual, well-advertised, well-funded and frequent community engagement events before this review was even initiated. This type of meaningful community engagement would allow people to think through the future they want, especially if they knew their voices and priorities would impact the regulations.


That said, there are some immediate things we can do. I fully endorse the technical suggestions in the EJ Collaborative Letter and feel strongly about the following specific points:

  • In notifications to community members, clearly state how their comments will be incorporated and how they will influence decisions.
  • Virginia communities that have been historically disinvested in, marginalized and discriminated against are also on the frontlines of both environmental disasters and government policies (for better or worse). The DEQ should maintain a list of frontline communities and residents who will be intentionally notified in advance of all regulatory changes.
  • Allow people to make comments in a variety of ways. In addition to the written options currently listed, it would be great if people could leave a voice message and have it be transcribed. At least one VA senator does this and even has a voicemail set up with hot button issues for residents to drive their messages to. Including comments from social media and apps is also an option.
  • Multi-lingual written notification materials and live translation at public hearings should be mandated and commonplace.
  • Community engagement is a technical skill. It should be included as an ‘expertise’ and represented on RAPs just like someone who is an expert in biodiversity or turbidity standards.
  • Residents from EJ communities and social justice groups should have representation on RAPs.
CommentID: 99845