Analysis of the Impact of Public Comment on Regulatory Decision Making: The Arsenic Standards Public Deposited

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  • February 27, 2019
  • Brostrom, Richard James
    • Affiliation: Gillings School of Global Public Health, Department of Environmental Sciences and Engineering
  • A method for the characterization and analysis of public comment on an EPA standard was proposed. The arsenic emissions standard was chosen since it was the most commented upon standard ever promulgated by the Agency. The proposed method worked well, as participating groups were clearly defined and the intent of each of the groups was reasonable in relation to their inferred environmental ideology. The effectiveness of each of the major groups of commenters was measured by relating the number of comments submitted versus the number of changes made. Comments received on the risk assessment constituted 89 percent of all comments submitted, over half were submitted by citizens not belonging to any particular special interest group. Few changes were made to the risk assessment as a result of the comments and the effectiveness of the comments for all groups was less than two percent. Comments submitted on the technical issues of the standard were more successful in causing change to the proposed standard. The effectiveness of each group varied widely, but the average effectiveness was 20 times greater than for comments submitted on risk issues. Many changes dealt with the submittal of new cost and emissions data by the affected industries. To allow for a discussion of the comment process, Godschalk's Exchange Model was altered and applied to the standard. The Exchange Model indicated that the comment process was successful except in the Agency's response to the public comment. A group theory model was used to analyze the Agency's response to the comment. This model indicated that the changes made to the proposed standards by the EPA could not be explained rationally on the basis of public comment. Other factors which influence EPA must be considered when explaining the Agency's decisions in light of the public intent.
Date of publication
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Rights statement
  • In Copyright
  • Berry, Michael A.
  • Turner, Alvis G.
  • Shiffman, Morris A.
  • Master of Science in Public Health
Academic concentration
  • Environmental Management and Policy
Degree granting institution
  • University of North Carolina at Chapel Hill
Graduation year
  • 1987
Deposit record
  • 4229e0fb-b010-4ede-aa50-9d4a2f0726fb

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