Public consultation seems to be everywhere and yet it’s very seldom practiced. An obvious way to stifle public comment is to avoid publicizing your public consultation effort as seems to be the Canadian federal government’s practice. In fact, the Canadian government seems to be exploring new ways to create barriers to public comments as per this April 25, 2013 posting by Glyn Moody for Techdirt,
… We pointed out that this kind of muzzling created a really bad precedent that might one day even be extended to the public. It seems that moment has come sooner than expected:
New undemocratic rules are creating a barrier to public participation in upcoming National Energy Board (NEB) hearings into the proposal for Enbridge’s Line 9 oil pipeline. For the first time, members of the public who want to send a letter with comments to the NEB about a pipeline project must first apply for permission to participate — by filling out a 10-page form that includes a request for a resume and references.
In fact, according to this April 5, 2013 posting on the Environmental Defence website, the process is quite challenging from a number of perspectives,
Under the new rules, any Ontario resident who lives along the 639-km pipeline route who wants to send in a letter about their concerns must first apply to the NEB for permission to send in a letter. As of today, the public will have just two weeks to fill out a 10-page form which asks for a resume and references.
“Since when does someone’s resume determine if they have the right to be concerned about what’s happening in their home community?” said Keith Stewart of Greenpeace Canada. “Anyone who lives and works in southern Ontario could be affected by a spill and everyone is affected by climate change. The right to send a letter of comment and have it considered by public agencies is part of the basic rights and freedoms Canadians enjoy.”
Line 9 runs directly through the most populated part of the country, through backyards, under farms and next to schools. The pipeline crosses every Canadian river flowing into Lake Ontario, threatening the drinking water of millions.
There is only a two-week window for the public to apply to participate, after which members of the public will be excluded from the hearing process. This means that if a resident along the route finds out about the project after that window, they have no voice.
Applicants are asked to provide qualifications, such as a resume or reference letter.
The application form is 10 pages long.
The application is very difficult to find online. [emphasis mine]
The basis on which participants will be rejected or accepted is unclear. [emphasis mine]
By comparison, the US National Nanotechnology Initiative’s (NNI) seems welcoming in its request for public comments. I saw the request in a Nov. 19, 2013 posting by Lynn Bergeson for Nanotechnology Now (and elsewhere too),
On November 19, 2013, the National Science and Technology Council, Committee on Technology, and Subcommittee on Nanoscale Science, Engineering, and Technology requested public comments on the draft 2014 National Nanotechnology Initiative Strategic Plan.
You can find the draft proposal and the comments form here (scroll down). You’ll notice the comments form requests your name and email but both are optional. Here’s a little more about what type of commentary is being requested (from the 2014 strategy webpage on the NNI website),
Comments of approximately one page or less in length (4,000 characters) are requested and must be received by 11:59 p.m. EST on December 18, 2013 to be considered. [emphasis mine] Please reference page and line numbers in your response as appropriate.
Please do not include in your comments information of a confidential nature, such as sensitive personal information or proprietary information. Responses to this notice are not offers and cannot be accepted by the Federal Government to form a binding contract or issue a grant. Information obtained as a result of this notice may be used by the Federal Government for program planning on a non-attribution basis. Do not include any information that might be considered proprietary or confidential. Please be aware that your comments may be posted online.
Of course, there’s no guarantee these comments about the NNI’s draft 2014 strategy will be read or that they will have any impact on the final plan.