Comments on "Rulemaking vs. Democracy: Judging and Nudging Public Participation That Counts"

August 2014
Citation:
44
ELR 10678
Issue
8
Author
Avi Garbow and Marna McDermott

In answer to the question “What kind of participation should we value?” our response would be: “All of it.” While nudging public participation that provides substantive feedback is certainly a worthwhile effort, agencies should also continue to facilitate the “cheap and easy” participation that Farina et al. characterize as to-be-resisted and of little value. We do not have to choose: public participation is not a zero-sum game.

Avi Garbow is General Counsel, and Marna McDermott is Associate Deputy General Counsel, at the U.S. Environmental Protection Agency.

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Comments on "Rulemaking vs. Democracy: Judging and Nudging Public Participation That Counts"

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