OVERDUE FINES ARE 25¢ PER DAY . PER ITEM Return to book drop to remove this checkout from your record. BY ABSTRACT PUBLIC PARTICIPATION IN 208 WATER RESOURCE PLANNING BY AN AREAWIDE AGENCY By Paul Henry Lilly This study examines the basis and opportunity for public participation and describes techniques to involve the public in the planning process. Section lOl(e) of the 1972 amendments to the Water Pollution Control Act required that public participation be provided for and encouraged in the development and revision of Areawide Waste Treatment Management Plans specified under section 208 of the same Act. Regulations specifying minimum guidelines for public participation were developed by the Environmental Protection Agency (EPA). The Tri-County Regional Planning Commission (TCRPC) of Michigan was designated to develop a 208 plan and proceeded without previous experience to implement a public participation program based on the minimum guidelines. The TCRPC participation program was evaluated in this study by utilizing descriptive attributes of individual tech- niques and eight program objectives developed by the author. The descriptive attributes quantified the utili- zation of specific techniques while the program objectives examined each technique's contribution to the entire program. Through this evaluation it is concluded that the TCRPC's public participation program was limited in scope and did not develop to its full potential. The TCRPC staff failed to develop an overall participation program plan and recognize opportunities for public participation to occur. ‘Without previous experience or training in public participation the TCRPC staff was unable to trans- late the minimum guidelines into an effective program. This study is dedicated to my wife whose support and patience proved to be invaluable. ii ACKNOWLEDGMENTS I would like to thank my graduate committee for their support during this study and entire program. Drs. Eckhart Dersch, Lawrence Libby and Carroll Wamhoff were always supportive of my needs by contributing their ideas and guidance. I would also like to thank the staff of the Tri-County Regional Planning Commission for their openness and willingness to share agency documentation of their 208 public participation program. And finally, I am grateful to Bruce Moore and Tim Wright of the Water Quality Management Division of Michigan's Department of Natural Resources for keeping ‘me informed of ongoing programs and activities within the state. iii TABLE OF CONTENTS INTRODUCTION ....................................... Chapter I. II. III. IV. THE FUNDAMENTALS OF PARTICIPATION ............ Philosophy ................................. Basis for Participation .................... Make-up of Participation ................... Goals and Objectives of Public Participation Programs ................... TECHNIQUES FOR PUBLIC PARTICIPATION .......... A Framework for Evaluation ................. Technique Description and Application to the Planning Process .................. Implementation ............................. AN APPLICATION OF PUBLIC PARTICIPATION OBJECTIVES TO THE TCRPC's 208 PARTICIPATION PROGRAM ........................ TCRPC's Public Participation Effort ........ Comparison with State of the Arts and Objectives ........................... Discussion of Rationale for the TCRPC's Program ............................ Potential for Continued Participation ....... THE CONTINUING ROLE OF PUBLIC PARTICIPATION .. Findings ................................... Summary .................................... APPENDICES ......................................... .Appendix A. HISTORICAL BACKGROUND OF WATER RESOURCE PLANNING IN THE UNITED STATES ................ iv 121 126 126 136 176 180 184 184 198 203 203 B. DESCRIPTION OF TECHNIQUES USED BY TCRPC ..... C. PARTICIPANT QUESTIONNAIRES USED AT THE RIVER BASIN MEETINGS .................... BIBLIOGRAPHY ooooooooooooooooooooooooooooooooooooooo \lO‘U‘l-DUONH 00 LIST OF FIGURES State Planning and Development Regions ......... Interest Fields ................................ Approaches to Social/Technological Change ...... Six Stages of the Planning Process ............. A Ladder of Citizen Participation .............. Structures for Public Participation in Planning A Model for Public Involvement in the Planning Process ............................. TCRPC 208 Public Involvement Program ........... Water Quality Management System for TCRPC ...... vi 13 23 30 39 42 122 131 182 LIST OF TABLES Technique Identification ....................... 61 Primary Function Listing of Identifiable Techniques ................................... 75 Descriptive Attributes of Common Techniques .... 77 Work Task Identification and Utilization ....... 133 Descriptive Attributes Evaluation of TCRPC Techniques ................................... 137 Objective Evaluation of TCRPC's Public Involvement Program .......................... 166 vii ABBREVIATIONS APAC Areawide Planning Advisory Committee of TCRPC CAC Citizens Advisory Council of TCRPC DNR Michigan's Department of Natural Resources EPA Environmental Protection Agency IWL Issac Walton League LWV League of Women Voters NRDC Natural Resources Defense Council NEPA National Environmental Policy Act TCRPC Tri-County Regional Planning Commission of Michigan TPCC Technical Planning Coordinating Committee of TCRPC viii INTRODUCTION While water pollution has been recognized as a problem in this country since the turn of the century, the federal government did not become directly involved until 1948, when the first Water Pollution Control Act was enacted. Since that first act, considerable public sentiment has developed around the federal government's role in protecting our national environment.1 Appendix A provides a background of water resource planning. The "War on Poverty” generated calls of "power to the people” and “maximum.feasible participation" in the processes of governmental planning and decision-making which led to legislative mandates for such opportunities. One such mandate can be found in the 1972 amendments to the Water Pollution Control Act, commonly known as the "Clean Water Act." Commitment to an active public involvement program in the administration of the various goals and policies established under the Act was specified 2 under Section 101. The Environmental Protection lJoachim F. Wohlwill and Daniel H. Carson, eds., Environment and the Social Sciences: Perspectives and Applications (Washington, D.C.: American Psychological AssociatiOn, Inc., 1972, p. 66. 2U.S., Congress, Federal Water Pollution Control Act Amendments of 1972, 92nd Cong., 2nd Sess., 1972, 18 October 1972, pp._816-903. 1 Agency (EPA) was to administer the Act and in doing so develop and publish regulations specifying minimum guide- lines for public participation.3 These guidelines, although intended to encompass the entire Act, were developed emphasizing the opportuni- ties for public input into the Areawide Waste Treatment Management Plans required under Section 208 of the Act. Areas were designated by the Governor of each state to develop such plans. In March of 1975, Michigan's Governor Millikan designated the Tri-County Regional Planning Commission (TCRPC) as one such area. (See Figure 1.) In July of last year, the Commission accepted a grant from EPA and began the development of their 208 plan. With only the minimum guidelines,4 issued in August of 1973 by EPA, the Tri-County Regional Planning Commission began to consider the requirements of public participation and their incorporation into the planning process. With a limited exposure to participa- tion strategies and techniques, the work program for the plan was developed. The Commission's staff had been previously involved in water quality issues and had completed several technical studies in conjunction with 3U.S., Environmental Protection Agency, Water Programs, "Public Participation in Water Pollution Con- trol,” Federal Register 38, no. 163 part III, 23 August 1973, 22756-8. 4 Ibid. 3 FIGURE 1 STATE PLANNING AND DEVELOPMENT REGIONS Trl- County Region other agencies. Their public involvement and information programs, however, were not developed. The information services department of the Commission was responsible for disseminating information, increasing the Commission's visibility to local units of government and promoting intergovernmental cooperation through improved channels 5 of communications. Proposition This study will examine the development and imple- mentation of the TCRPC's public participation program as it relates to the development and implementation of an Areawide Waste Treatment Management Plan. This examina- tion and a review of the literature will identify speci- fic characteristics of the program that influenced its outcome . Objectives The objective of this study is to evaluate the efforts of the TCRPC‘s 208 planning staff in establishing and implementing their public participation program. Several sub-objectives will contribute to this effort. They are as follows: To determine the basis for public participation in water resource planning and to identify the roles the publics can play in the planning and 5Tri-County Regional Planning Commission, "Designation Package for 208 Planning," TCRPC, Lansing, Michigan, May 1975, Appendix H. 5 decision-making process; to identify the characteristics and functions of public participation in each stage of the planning process; to identify techniques used in the implementation of public participation programs; to develop a criteria for studying and evaluating public participation programs. Approach These objectives were accomplished by combining several study approaches. Observations, both documentary and personal investigations and literature review were combined to complete the objectives of this study. Liter- ature and related study documentation review were the primary sources of information used to investigate the techniques of and the basis for public participation in water planning. Design The TCRPC's 208 public participation program was evaluated on two levels. Public participation programs are comprised of techniques combined in a series to address various interests. The techniques utilized by the TCRPC were reviewed and rated against five attributes. These attributes address the technique's focus, commit— ment, communication, contribution and initiative. The ratings were then utilized to compare the delivery of each technique in the TCRPC program with a norm established through the literature review. 6 The second level of evaluation is based on eight objectives. These objectives scrutinize the combination of techniques that make-up the program. This review of the total program considers how the techniques are distributed and utilized during the program. Limitations As with any study, there were some limitations in the scope and detail that could be considered. The 208 planning process began with its Congressional mandate in the 1972 amendments to the Water Pollution Control Act. The TCRPC was designated to undertake this planning pro- cess in 1975 prior to the formulation of this study. The planning process had progressed to the alternative development stage before personal observation was under- taken. Consequently, reliance upon documentation and personal recall by 208 staff, as well as participants, was used to establish the agency's formulation of the program. Delivery and content of the program elements were not under control of this research and therefore could not be ‘manipulated to explore other approaches. This program represents only one out of eight 208 programs in Michigan that began in 1975. The TCRPC program was selected due to its proximity with Michigan State University where the author was enrolled. Secondary information, in the form of other participation studies in planning, were used to consider techniques not utilized in the Tri-County program. Other designated areas have approached partici— pation in different, sometimes unique, ways. The results of many of these efforts have not been completed or published. Whenever possible, preliminary information was obtained from the agency involved and is cited as such in this study. The components of public participation programs are very complex and are difficult to isolate as independent variables. The comparison of one program with another can identify differences that can be examined in further detail. The application of each program, however, must be considered independently since it is impossible to modify what has occurred. The value of this examination is found in the understanding it provides of public participation and the avenues that exist to promote an effective program. CHAPTER I THE FUNDAMENTALS OF PARTICIPATION Philosophy In the development of our democratic society some basic tenets have shaped the role individuals play in the decision—making process. Components of this democratic society dictate that the society must be open, allowing any issue to be the subject of public discussion and verdict, and that responsible leaders be held accountable for their decisions through sanctions provided within the system.6 These sanctions may be directed toward individuals in the form of non-support and/or recall or may be di- rected broadly at the problem. This broad access is through judicial, legislative and constitutional remedies and are considered to be the rights created under legisla— tive authority of the state and federal governments or 7 Elected basic rights guaranteed under the constitution. officials have been subject to legal actions brought about by individual citizens and groups organized to represent 6Emmette S. Redford, Democracy in the Administra- tive State (New York: Oxford University Press, 19697, p. 202. 7Ibid., p. 78. an interest area. This concept of interest areas has developed in various "interest groups" which represent a defined, at times very loosely developed, group of citi- zens. The effect "interest groups" can have in shaping public policy has been highlighted in resource management literature. Citizens are most effective when organized in groups in which they share concerns, educate each other and, in the process, become more clear and persuasive in arguing for a parti- cular policy alternative. Organized "interest groups” represent the coalition of a segment of society that has been recognized and is capable of presenting a concise input to those in a posi- tion to incorporate it into the decision-making process. This organization of individuals unified around common values and goals represents the political theory of Pluralism.10 This theory suggests that as society becomes more complex, these groups will take on an added impor- tance. As a result, public policy will be developed from the balancing of forces among opposing groups. The 8Donald R. Field, James C. Barron, and Burl F. Long, Water and Community Development: Social and Economic Perspectives, Man, His Community and Natural Resources, no. 1 (Ann Arbor: Ann Arbor Science Publishers Inc., 1974). P. 127. 9Transportation Research Board, National Research Council, "Application of Interactive Graphics in Citizen Participation,” Transportation Research Record #553, (Washington, D.C.: 1975), p. 30. 10D. Baskin, American Pluralist Democracy, (New York: Van Nostrand Rienhold, 1971), p. 94. 10 success of these groups lies not only in their membership size but more importantly in the tactics they employ.11 The Pluralism theory rejects the concept of the "public interest” and supports the idea that if an issue is of importance various groups will develop in support or opposition and influence public policy toward their inter- ests. Yet, a basic ideal in our Democratic society is that persons are the unit of value in social arrange- ments.12 Where social action is substituted for individual action "liberty exists only through participation either in decision-making or in control of leaders who make the d o o "13 BCILSlOIlS . A concept that affected interests must have effective access to administrative institutions and their allied structures is the basic question. This access can only be developed by the overt efforts of institutions. It is not a passive process. Within this concept of access lies a perplexing question: how does one define the collection of indivi- duals that make up affected interests? Members of society can sometimes be identified as being affected directly by some action. Taxpayers, for example, are identified and can be directly addressed. More commonly, however, affected interests are vague and do not permit such llIbid. 12Redford, Democracy in the Administrative State, 13Ibid. 11 specificity. In the situation where benefits are being derived by a large but undefined group of persons in society, the term"genera1welfare" is used. This esoteric term "general welfare" is applied over a wide variety of situations and interests. Basically, it provides to all the people of society well-doing or well-being in any respect and the enjoyment of health and common blessing of life while being exempt from any evil or calamity. "The general welfare can be considered roughly synonymous with "14- In a broadly viewed concept of the publicinterest. approaching public interest from this expanded view the concept can be applied to any individual or institutional action. When confronted with a number of conflicting interests, the decisiondmaker must search for the conse— quences for an action and, in doing so, consider the public interest as a "a symbol of the attempt to recognize and consult interests that might be forgotten or over- looked in the pressure of political combat."15 The decision-maker must determine the values which society and members of it place upon the outcome of his decision. These values are the result of human feelings being placed upon the subject of the decision being made. 14Carl J. Friedrich, ed., The Public Interest, Normos, no. 5 (New York: Atherton Press, 1967), p. 14. 15Glendon Schubert, The Public Interest (Glencoe, Illinois: The Free Press, I960), p. 203. 12 Since values are subjective they vary from individual to individual. They can, however, be considered as collec- tive groups and be looked upon as having a stake in the decision being made. These stakes or "value consequences” follow from any decision that is made and provide a ve- hicle to delineate the various groups.16 One example of this concept is addressed by Harold D. Lasswell. He identifies four value related interest areas and considers 17 Given a their contribution to the public interest. social context and a specified activity that has some value effects, various interests of the society can be outlined. Interests which are compatible with societal goals of human dignity are considered to be the common interests. Special interests are those value consequences that are incompatible with the common interest. Private interests, in part, are contained within the common interest. Addi- tional values not held within the common interest exclude these private interests from being encompassed by the common interest. A public interest develops when the societal common interests are sufficiently great as to warrant their inclusion as an element of the decision. Figure 2 represents how a given issue might look if these 16Car1 J. Friedrich, ed., The Public Interest, p. 63. 17Ibid., p. 64. 13 FIGURE 2 INTEREST FIELDS PECIAL INTEREST PUBL C INT EST COMMON INTEREST PRIVATE INTEREST 14 value interests were spacially distributed. The special and private interests are assigned areas to demonstrate their consideration as part of the public interest but do not necessarily reflect a specific fractional portion of the public interest. While the public interest is accepted as a function of the decision-making process, the specifics of its con- tribution can not be identified. Anthony Downs draws these conclusions when he states: ...the term public interest is constantly used by politicians, lobbyists, political theorists, and voters, but any detailed inquiry about the exact meaning plunges the inquiries into a wel- ter of platitudes, generalities, and philosophic arguments. It soon becomes apparent that no general agreement exists about whether the term has any meaning at all, or, if it has, what the meaning is, which specific actions are in the public interest and which are not, and how to distinguish between them.1 Since it seems to be impossible to always identify such public interests, criticism has developed regarding their consideration in the decision-making process. With the growth of this country's administrative bureaucracy came a separation of the public from the actual decisions which were being made. This is demonstrated in the expansion of agencies as an aspect of the government's administrative process. While agencies such as the Corps of Engineers and the Department of the Interior were accountable 18Virginia Heid, The Public Interest and Individual Interests (New York: Basic Books,gl970), p. 2. 15 through the administrative structure, they seemed removed from direct public access. Publics were not able to associate their input with agency actions. Individual letters and verbal petitions while having potential impact, provided little satisfaction for the sender and commonly 19 This con— were treated as statistics by such agencies. tinued reliance on agencies in the administrative decision- making process was based on the expertise model defined as: The division of labor around functional spe- cialties and the recruitment of trained personnel capable of responding to narrow problems with speed, efficiency and compe- tence. This model is presumed to reflect ”value free” profes- sional standards and ethics when applied to specific programs. Such "value free" decisions are not possible, however, when the task of such an agency becomes the es- tablishment of goals. Goal setting must involve value judgements and most of the technically trained profession- als are no more qualified than the general public to make 21 Agencies have often catered to spe- such judgements. cial interest groups to expedite successful implementation of their programs and to secure support for official 19Transportation Research Board, National Research Council, "Application of Interactive Graphics in Citizen Participation," p. 30. 20Field, Barron, and Long, Water and Community Development: Social and Economic Perspectives, p. 126. 2libid. 16 22 Such catering, at times directed at conser- policies. vation groups, has brought agencies into conflict with other groups through judicial challenges, resulting in delays, manipulations or terminations of agency projects. Administrative decision-making relies upon such interest groups in determining public policy. Demands for greater public access to agency procedures, while not challenging the expertise model with a participatory model, are direct- ed toward the acknowledgment cfi? citizen groups and con- comitant public interests in setting goals in environ- mental management.23 There currently exists two basic governmental per- spectives concerning public involvement. First, if estab- lished programs are to remain viable and not engender destructive protest, individuals must be afforded an oppor- tunity to affect the decision-making process. The second perspective is that citizens have a proprietorial right to be involved in decision-making that encompasses goal setting 24 and goal attainment considerations. These perspectives have recently focused sharply on the environmental 22See Geoffrey Wandesforde-Smith, "The Bureaucratic Response to Environmental Politics," Natural Resources Journal 2 (July 1971): 479-88; and HEIen Ingram, ”Patterns of Politics in Water Resources Development," Natural Resources Journal 11 (1) (January 1971) 102-18. 23Field, Barron, and Long, Water and Communipy Development: Social and Economic Perspectives, p. 127. 24 Ibid. 17 management responsibilities of the governmental decision- making process. While attempting to determine the publics opinion regarding environmental management, the various governmental agencies found that they could: ...often detect only the grossest, broad gauge conceptualizations of issue areas among much of the mass public and this is particularly true of the assessments o§5values and value orientations among the public. Basis for Participation Social The public has, however, over the last ten years narrowed their focus and increased their awareness of environmental matters. This in part can be attributed to the increased media coverage and first hand exposure to such problems in their natural environment. With a clear and demonstrated deterioration in the quality of many aspects of the natural, rural and in particular, the urban environment, citizens demanded immediate actions to eliminate such deterioration. This increased interest was visible in the social climate surrounding the late 60's. The changing concern for the environment was evident and led to what Erskise called the "Miracle of Public "26 Opinion. From May of 1965 to June of 1970 as 25William R. Burch, Jr., Neil H. Cheek, Jr., and Lee Taylor, Social Behavior, Natural Resourcesi and the Environment (New York: Harper & Row, Publishers, 1972), p. 215. 26Field, Barron, and Long, Water and Community Development: Social and Economic Perspectives, p. 285. l8 determined in national polls, the proportion of people viewing water pollution as a serious problem jumped from 35 to 74 percent with a similar increase with regards 27 These changes in opinion, however, to air pollution. did not mean that the behavior of the general population had changed. Realizing that such a change would be necessary to improve the nation's environment, the govern- ment began to focus on the fact that: ...Support for a program exists only when the proposal grows out of the thinking of a wide group. The best way to insure support at the solution level is to secure full participation at the groblem-defining and decision-making level.2 The public continued to criticize government agencies into the early 70's. The United States Forest Service, Corps of Engineers, Bureau of Land Management, National Park Service and others were seen as insensitive to the publics' aspirations for environmental management. The public criticized these agencies for: Maintaining elitist perspectives in which pro- fessional views are arbitrarily equated with the public interest and for failing to provide great- er opportunities for citizen involvement in29 decision-making and program implementation. 27 28Hans B. C. Spiegel, Citizen Participation in Urban Development, vol. 1, "Concepts and Issues," NTL Institute for Applied Behavioral Science, National Education Association, (Washington, D.C.: 1968), p. 32. 29Field, Barron, and Long, Water and Community Development: Social and Economic Perspectives, p. 126. Ibid. 19 The public was frustrated with the agencies' traditional responses to their concerns. Values placed on environmental questions were not manageable with existing agency techniques of evaluation. Benefit-cost ratios and engineering technology could not account for aesthetic considerations or political feasibilities. Four value areas have been identified by Daniel Ogden, Jr. that pro- vide a basis upon which to look at the publics' environ- mental concerns. While not exclusive they do provide some structure to the illusive public interest. These four areas are as follows: 1. Economic - The amount of work an individual is willing to do to acquire desired goods or services. Measurement of economic value is in some standard, the price in dollars or their equivalent in our society. 2. Social - These values are established by custom and practice. Essentially, these values are the result of private attitudes toward non-economic matters. These values establish how individuals are to behave. Social values differ among community members, and only after the community is studied, can these values be measured by comparison. 3. Aesthetic — An individual's expressed preference in the recognition of beauty, stated as likes and dislikes without respect to the costs or moral consequences. These values can only be compared among themselves. Only after some ranking of aesthetic order is determined for an individual, can any equating to other value areas be accomplished. 20 4. Political - Consensus established these values, confirming that the majority of the people wish society to act in such a manner. These values are expressed in voting habits and the support afforded to elected officials.30 Since many of the proposed changes in our environment were interpreted as matters of value preference rather than as ecological imperatives for survival, many segments of the public did not participate in their resolution. While most people, if asked, would say they were in favor of clean water or air, many are not convinced that such benefits are worth the costs necessary to achieve them. While some reductions in environmental degradation can be achieved by individuals, the thrust must come at broader societal levels. Thomas A. Heberlein identifies three ways in which environmental problems can be alleviated. These include the technical fix which is a structural approach, the cognitive fix which relies on man as a rational actor and the structural fix which manipulates man's behavior by changing the social or physical structure in which the problem takes place. Each of these affect 31 the environment in some form. While the technical fix has been the dominant approach in the past it is currently 30Daniel M. Ogden, Jr., "Environmental Values and Water Project Planning," paper presented to Arkansas- White-Red Basins Inter-Agency Committee and the Missouri Basin Inter-Agency Committee, Fort Collins, Colorado, 8-9 July 1970, p. 8. 31Field, Barron, and Long, Water and Communigy Development: Social and Economic Perspectives, p. 202. 21 recognized that modifications in the behavior of man will be necessary to insure environmental quality in the future. Technology will no doubt assist in the protection of our environment but it is ultimately the behavior of our society and the individual members of it that will make the difference. Our society relies on planning to determine the appropriate courses of action we must take to meet our needs. Planning basically considers existing or antici- pated needs of the client group and determines what changes would and would not be deemed desirable to satisfy those needs. Historically, society has relied upon tech- nological approaches to change in order to satisfy needs. As conflicts arose, new technologies were applied that manipulated the system in order to produce some form of need satisfaction. These technological fixes , however, normally accrued to only sub-groups of the total popula- tion and were often of short duration. This type of change is well defined and the course of action is specified before the actual process is initiated. Changes of this type and the planning involved with it is deductive. The problem is well defined and the change involved can be measured by some quantitative techniques. Unfortunately, the changes in our environmental system necessary at this time are not ones of the tech- nological type. The current situation is poorly defined and results from conflicts of interest rather than a need 22 to employ new, more advanced technologies. Social, political and other forces must be synthesized if a solu- tion is to be reached. The situation or the multitude of problems that comprise it, while not well defined repre- sent potential changes that would affect the society as a whole over a long period of time. Such changes then have the potential to drastically affect the environment and members of society. While a comprehensive planning approach to such changes would be desirable, the lack of data and tools for studying this area limit the analysis that can be performed. Without some comparison of the various change elements, no evaluation of alternatives can be performed. The interface of technological and social change must be improved if interaction and exchange is to occur. The political and social realities of our society must be considered and incorporated into the change, if implementation is to affect broad segments of society. These approaches to planning and change are depicted by 32 and have been modified in Figure 3 to demonstrate Bishop the interface necessary to implement the changes, both socially and technologically, that will be necessary to achieve an acceptable goal in environmental management. The interaction among members of society necessary to establish such a goal is the basis upon which the 32A. Bruce Bishop, Public Participation in Water Resources Planning, U. S. Army Corps of Engineers, Insti- tute for Water Resources, (Alexandria, Virginia: December 1970), p. 19. 23 FIGURE 3 APPROACHES TO SOCIAL/TECHNOLOGICAL CHANGE 241% -social- V“ (Ion term) {Os cud g '69“ Ex \ 2 .1 x ‘r‘ o -< TYPE or 8 PROBLEM WELL Lu\ ILL DEFINED g DEFINED a i . -technological- g (short run) {/07 \ ADAPTED FROM: Bruce A. Bishop. Public Participation in Water Resource Planning, U.S. Army Corps of Engineers, Institute forEWater Resources, (Alexandria, VA: 1970), pp.l9. 24 values described earlier are developed. These values must then be articulated at the interface of the techni- cally feasible and socially acceptable alternatives. While such an exchange would contribute to the general under- standing in a change situation, no universal acceptance of the procedure has been accomplished. Legal Regulatory and management decisions by public and environmental agencies require a basis in law. Public participation in such decisions also requires a basis in law. This basis is found in constitutional documents, legislation, judgements concerning the law, and in con- vention based doctrine. Only through such bases can the publics' opportunity to affect decisions be guaranteed. Various laws, and their interpretation by the judicial system, have been used as a vehicle to confront agencies with a view or opinion held by groups or individuals. One area of conventional law that has been used to argue the publics' point is that of the "public trust.” Through the courts, public trust cases have provided a counterbalance to market forces. The interpretation of this doctrine treats common property resources as an asset belonging equally to each citizen. Such resources can only be impaired when some clear compensatory benefit 25 can be provided for the beneficiaries of the trust.33 Success in protecting the environment along this line has, however, been limited. The major difficulty lies with identification of losses to the public and the degree of support for public needs generated by a project or action. Actions on constitutional grounds have focused on the rights of citizens under the first and fourteenth amendments. The first amendment provides for the petition of the government for a redress of grievances from citizens when actions of the government effect them adversely. Due process of law is guaranteed any citizen deprived of life, liberty or property by any state under the fourteenth amendment. The fourteenth amendment also provides equal protection of the laws to any person within jurisdiction of the United States. While these amendments have pro- vided a basis for environmental protection their use is limited because of difficulty in demonstrating interest or harm related to a proposed action. Only after the relationship between an action and ins effect upon the individual in question is established can a claim of protection or redress be considered in the judicial system. Legislative steps have been taken to bridge this gap in protection by providing an access to concerned 33Joseph L. Sax, Defending the Environment: A Handbook for Citizen Action (New York: Vintage Books, 1979). P.173. 26 citizens in a variety of administrative decisionrmaking processes. These provisions have been incorporated into the environmental legislation of the late 60's and early 70's. The National Environmental Protection Act (NEPA) and the Clean Air Act are two examples of such statutes. By providing specific requirements of public access and consideration within these laws the necessity of showing a "standing" under constitutional and case law was forgone. The incorporation of impact statements, required under section 102(2)(c) of NEPA, into the planning and imple- mentation process of federal agencies project development changed many agencies' determinations. The Alaskan Pipeline, Kennedy Library/Museum and several Corps of Engineers projects are examples of initial agencies' determinations being changed or completely abandoned due to the environmental cost that became evident in the preparation of an environmental impact statement.34 Opportunities for citizens to comment on proposed actions increased as public hearings were held in con- junction with the impact statements. Many states were also enacting environmental legislation specifying the publics' interest in the protection of air, water and other natural resources. In Michigan, the ”Thomas J. Anderson, 3"Walter A. Rosenbaum, The Politics of Environ- mental Concern, Second Edition (New York: Praeger Pub- lishers, 1977), p. 121. 27 Gordon Rockwell environmental protection act of 1970”35 established the judicial review of administrative actions necessary to insure the publics' interest in the environ— ment. Agencies responsible for issuing permits were forced to consider a wide variety of interests, which later resulted in the establishment of advisory or review boards and public review procedures. Under the 1972 amendments to the Water Pollution Control Act, public participation was to be accorded a new significance. "Emphasis for public involvement was placed at three levels: First, in the development of statewide programs...; secondly, in the preparation of basin and area-wide plans...; and thirdly, in the case-by— case consideration of local projects and permit applications."36 Make-up of Participation The Planning Process This study focuses on the public involvement aspects in the preparation of an areawide plan. The basic aspects of such an effort can be applied to the development of statewide programs. The public involvement associated with application and permit granting is a completely 3SSax, Defending the Environment: A Handbook for Citizen Action, p. 249. 36U.S., Environmental Protection Agency, Water Programs, "Public Participation in Water Pollution Con- trol," p. 22756. 28 different situation. The general approach to public involvement in permit granting is similar to a judicial review with the opportunity for parties to ask questions and state positions before the decision-making body. The statewide and areawide programs, however, are a planning effort and should follow the basic format of plan development and implementation. A planning program consists of several overlapping phases that, when sequentially addressed, provides the foundation for a continuing process. These phases have been identified in various ways by several authors and are, in principal, accepted by planners. Various planning groups have a tendency to stress one phase more than another due to their make-up and functional orientation. Distinct labels have been attached to the phases and these labels describe the planning activity that dominates that particular phase. Considerable overlap from one phase into the other often occurs since one effort does not exclude the others and a return to the previous phase may be necessary during the development of the plan. The author has chosen a combination of previously identified planning stages outlined by Borton, 37 Creighton, Warner and Bishop which divide the planning 37See Thomas E. Borton, Katherine P. Warner, and J. William Wenrich, The Susquehanna Communication-Participa- tion Study, report submitted to the U. S. Army Engineer Institute for Water Resources (Springfield, Virginia: Clearinghouse for Federal Scientific and Technical Infor- mation, December 1970), pp. 44-55; Synergy, Citizen 29 process into six generally sequential stages. As the planning process proceeds, the various stages are built upon each other. The process begins with the identification of goals and objectives for the planning effort. After the goals and objectives have been determined and formed into an operational format, they provide a basis for gathering data which is the second stage of the process. Existing data as well as data derived from detailed studies speci- fically designed to provide data that was unavailable or incomplete, must be compiled and used to develop alterna- tives. Alternative development is the third stage of the planning process. The various alternatives should then be evaluated against themselves and considered for their contributions toward the goals and objectives specified in step one. After this evaluation is complete, a preliminary plan must be developed and considered as a total approach. Reaction to this preliminary plan is considered and a final plan is developed based upon the total program of work. The final plan preparation and its implementation is the sixth phase of the planning process. Figure 4 represents Participation/Public Involvement Skills Workbook (Cuper- tino, California: Synergy Consultation Services, 1972), pp. 72-5; Katherine P. Warner, Public Participation in the Water Resources Planning_Process, PB-204 245, report prepared for the NatiOnaI Water Commission (Springfield, Virginia: National Technical Information Service, July 1971), pp. 38-48; and Bishop, Public Participation in Water Resources Planning, pp. 21-5. 30 FIGURE 4 SIX STAGES OF THE PLANNING PROCESS ——————--Identification of Goals and Objectives 1 ‘———~—-Data Collection r—«rL-O-Development of Alternatives 1 Evaluation of Alternatives 1 L——~—-—Preliminary Plan Development 1 Implementation 31 the sequence of stages that make-up the process and demonstrates the cycling necessary to maintain a dynamic approach to the planning effort. Each of these stages contain specific opportunities for public participation through a variety of techniques. These opportunities and techniques will be discussed in the next section. A more detailed description of each stage is necessary to provide the framework for a participation program. Identification of goals and objectives The identification of goals and objectives could also be called the issue definition stage since that is the basic resultant of the efforts during this phase. The agency must explore a wide range of issues related to the general planning effort and clearly define those issues which are related to the current effort. Since it is people's values that are reflected in such identification, these values must be transformed into an operational set of objectives. This transformation must be accomplished by integrating the participants‘various desires into areas and by choosing between expressed desires that conflict or are not related to one another. The choice between various inputs can only be legitimized if the participants take an active role in the decision-making. Agency credibility would be jeopardized if such a step excluded active participant 32 exchange. The opportunity to adjust initial statements when new information or problems are identified is one way of focusing a number of desires into one objective area. As participants receive additional information their de- sires can often be more specific and relate directly to the identified problem or goal. Agency personnel should encourage the participants to consider the future implica- tions of their goals and objectives. In this way, the relationships between various objectives and future development can be discussed. Once the goals and ob- jectives are developed, the agency can begin to collect information necessary to understand the specifics of the problem and formulate alternative solutions. Data collection Data collection must be accomplished for the phy- sical resource base, the social system and the economic factors which influence interaction between them. Contri- butions during this phase come from a wide variety of sources. Technical specialists can provide specific infor- mation on resource use and distribution. Citizens can provide additional information on local problems or the historical development of local activities. Some data will only be available through further studies and specific investigations must be undertaken to obtain such informa- tion. As information is compiled, the public should be informed and provided an opportunity to react. Such a 33 reaction might identify the need for further study. By interacting with the public and established contacts, the agency can verify the assembled data and reinforce its initial contacts. This phase of planning often becomes invisible, if it is not identified. Participants can also lose track of activities and may often lose the interest that was initially generated in the goal identification phase. Development of alternatives As the initial data collection phase is ending, the information must then be organized into a format that can be used to develop alternatives. The concerns expressed, the attitudes sampled and various data compiled will guide the alternative development phase. Agency personnel must consider a wide variety of alternatives. Ideas generated by the participants, that by agency standards would seem unreasonable, must be included into at least the first draft of any alternatives. The scope of alternatives must remain broad so that the public can react without having to support or reject a specific idea or proposal. It is at this point in the process that the social, environmental, political and economic effects of various alternatives should begin to play a role. The public can then provide information regarding constraints, implica- tions and priorities of various alternatives. Some adjustment or modification in alternatives at this point 34 will encourage the public's participation and help insure confidence in the next phases of plan development. Evaluation of alternatives Evaluation of the various alternatives implies some form of judgemental activity. In this phase the various alternatives must be examined and integrated into other decision variables. Each alternative must be subjected to a review using some form of empirical guidelines and philosophical framework. The public must understand the basis for evaluation and have the opportu- nity for input as to the reasonability and feasibility of various alternatives. Information on how the alternatives were derived must be provided. Some type of quantitative displays for similar alternatives will help people to establish their preferences and articulate concerns. Patterns of people's preferences may help the agency foresee conflicts in plan development. An accurate record of such inputs should be made, noting the intensities of these inputs for future reference. It is the agency's role to facilitate mutually satisfactory conclusions. Trade-offs between various alternatives will estab- lish a level of agreement among participants. Traditional methods of evaluation should be included in this phase. Benefit-cost and least-cost analysis of the alternatives will provide inputs for evaluation but must not outweigh the other methods of evaluation. The alternatives must 35 be considered for their impact and integration into the existing local, regional and national environment. Additional input on various alternatives may be required to continue the evaluation. Some cycling to the data collection phase can provide the needed information and demonstrate the agency's commitment to make the best choices. The philosophy that better information leads to better decisions may not always be true. Participants will, however, feel that the decision was based upon accu- rate input rather than the agency's subjective interpreta- tion. As the agency forms the alternatives into a package, the preliminary plan begins to develop. Preliminary plan development As the agency staff consolidates the alternatives and develops the preliminary plan, a considerable amount of thought needs to be given to the form in which specific alternatives are to be presented. The complex technical and social considerations identified through the previous stages form the basis upon which the preliminary plan is developed. Consensus-formulation through trade-offs must be made to establish the greatest possible common agree- ment. While the agency and established committees will ultimately select the alternatives to incorporate into the preliminary plan, they must maintain a degree of flexibil— ity. Certain new participants will inevitably want some input into the process. This group of participants are 36 characterized by their reactive nature. While they were not interested in the early stages they now feel affected by the plan and desire an input to the planning effort. The agency must look upon these groups as resources and not as hindrances to the plan. Through education and information programs, these participants can be brought up to date and can begin to contribute positively to the plan. After the alternatives have been incorporated into a package, the public should be addressed and feedback on the total preliminary plan obtained. Interaction with various publics will facilitate a thorough review. Attempts to have discussion among the various interests will promote acceptance of the various program elements. The preliminary plan represents the total of the planning effort to date. Reaction by the public to elements of the plan shall be considered and evaluated with the data and information collected previously. New information, how- ever, may point out considerations previously overlooked. These considerations might call for further study. The agency must maintain an open attitude during this phase of the process and respond to inquiries in a positive, interactive fashion. After a period of feedback, the agency with the help of a small group of participants can move into the sixth planning phase, that of final plan preparation and implementation. Although final plan preparation and implementation are addressed in this final stage, the implementation process is open-ended and must 37 be addressed as a continuing process. The focus in the final plan preparation should be on the issues and the structured response mechanisms to address them. Through a review and specification of the planning goals and objec- tives, the agency can demonstrate how the plan will attain the desired results. Impacts of the final plan must be addressed in this final stage and the required public meetings held. These meetings are more formal than those earlier in the process but they still provide an opportun- ity for the public to be involved. The agency should develop a justification for the elements included in the final plan. Implementation Implementation, or as it is often called, adoption, of the plan involves its integration into the existing social, political and economic systems. The agency can facilitate implementation by working with those groups that will be involved in following through on the plan's recommendations. These groups should be identified and consulted earlier in the planning process and brought along with the plan development. Implementing agencies will accept their roles more readily if they were involved in the formulation of their roles. Questions regarding the plan's implementation will surface as the details of inggr—agency and ingrg-agency interactions develop. The planning agency staff and 38 citizen participants must act as facilitators. As questions arise about content of or responsibilities under the plan, these facilitators can bring those parties involved together. In doing so, they work toward a decision that will be consistant with the plan and will be satisfactory to all those involved. While this is an over—simplification of the implementation process it does address the most important role of the agency as a facilitator and information source during this stage. Types of Participation Types of participation or non-participation in plan- ning range from citizen manipulation by an agency to citi- zen control of the agency and planning process. A typology offered by Arnstein in her article "A Ladder of Citizen Participation," displayed in Figure 5, suggests that participation be equated to the degree of power a citizen has in the planning process. Arnstein looks at power as the ability for citizens to determine how the planning process will be carried out and who will make the decisions. While her approach is aimed specifically at publics that are ”powerless" and their need for movement up the "Ladder of Participation,"ii:also serves as a guide to agency personnel in developing participation programs.38 38Sherry R. Arnstein, "A Ladder of Citizen Partici- pation," AIP Journal 35(4) (July 1969):216-24. 39 FIGURE 5 A LADDER OF CITIZEN PARTICIPATION F 1m ”—7 CITIZEN CONTROL Degrees of DELEGATED POWER Citizen Power PARTNERSHIP PLACATION CONSULATION . I Degrees of Tokenism [INFORMING THERAPY :Z: ‘—————+ Nonparticipation MANIPULATION L _ SOURCE: Sherry R. Arnstein," A Ladder of Citizen Participation." AIP Journal 35(4)(July1969):217, figure 2. 40 This eight-rung ladder is a simplification of the real-world situation citizens are faced with. The grada- tions of citizen input are affected by many factors in the planning process. One of the most influential factors is how the agency establishes the change relationship necessary in the planning process. The planner-client relationship, clients being citizens, community and interest groups, community offi— cials and their staffs, established by the agency is often referred to as the planning strategy. Strategy as defined by Bishop "is a procedure, established in advance, which determines how, when, and to what depth various parties will participate in the planning evaluation, and "39 In establishing a strategy the emphasis must decisions. be placed on broadening the interests involved, not restricting them to established groups. The seven planning strategies that follow are adapted from various planning experiences and studies by Bolan, Bishop, Creighton and others."0 39Bishop, Participation in Water Resources Planning, p. 36. 40Richard S. Bolan, "Emerging Views of Planning,” Journal of the American Institute of Planners 33(4) (July l967):237-40; Bishop, Public Participation in Water Resources Planning, pp. 36-43; and Synergy. Citizen Participation/Public Involvement Skills Workbook,;nx 105-8. 41 1. Information Processing (Figure 6a) The planner controls the flow of information and conducts the study. By developing alternatives and information regarding their evaluation, the planner controls the entire planning effort. One-way communication and the reporting of work performed, typifies this strategy. 2. Information with Feedback (Figure 6b) This strategy is a modification of the information ap- proach. By incorporating a feedback mechanism into the planning process, the planner obtains data from the client groups. The planner is ultimately in control of goal, need identification and plan development. Feedback may or may not influence the plan's development. The feedback, however, may contribute to the development of a wider variety of acceptable alternatives. Feedback loops require additional time to complete but will ultimately shorten the implementation phase by resolving potential conflicts. 3. Coordinator (Figure 6c) As coordinator, the agency seeks out clients that are important to the plan's development. The agency assesses client objectives then uses these assessments to evaluate agency generated alternatives. Several different alterna- tives may be presented to the various clients. The agency controls the information and communications. Interaction among the clients is not encouraged and provides the agency with the structure to completely control the process. Feedback is received by the agency from 42 FIGURE 6 STRUCTURES FOR PUBLIC PARTICIPATION IN PLANNING FIGURE 6a Information Processing COMMUNITY OFFICIALS AND STAFF GOALS ALTERNATIVES AND INFORMATION [DIAGNOSIS COMMUNITY GROUPS AND CITIZENS FIGURE 6b Information with Feedback COMMUNITY OFFICIALS PROPOSALS &| lALTERNATE PLANNER INFORMATION PLANS I COMMUNITY GROUPS AND CITIZENS l GOALS [DIAGNOSIS SOURCE: Bruce A. Bishop, Public Participation in Water Resource Planning, U.S. Afmy Corps of Engineers, Institute for Water Resources, (Alexandria, VA:1970), Figure 4, pp.37. 43 individual clients but may not be incorporated into the planning process. The agency has a role, as coordinator, to educate the client groups and provide them with information so they can articulate their objectives and feelings toward the plan's development. 4. Coordinator-Catalyst (Figure 6d) Client interaction is recognized in this strategy. Agency expertise is offered to the clients to facilitate their understanding and input. The agency is in the position of promoting participation in the activities formerly limited to staff. Technical and methodological assistants are used to encourage client involvement. The agency acts as a facilitator between the clients as they interact and confront one another regarding the plan development. 5. Advocacy Planning (Figure 6e) Advocacy strategy is similar to the coordinator-catalyst strategy. Client groups develop an understanding of their needs and objectives through discussion. The clients then present their desires to an advocate ombudsman who in turn presents it to the agency. The advocate continues to work with the agency to develop the plan and communicates with clients keeping them informed as tx> the plan's progress. 6. Arbitrative Planning (Figure 6f) This strategy utilizes an independent hearing officer that is not affiliated with the community or the agency. Inde- pendent of the clients and the agency, the arbitrator acts 44 FIGURE 6c Coordinator NEEDS & BUSINESS NEEDS & GOALS AND GOALS PROFESSION GROUPS CITIZEN NEEDS & AND GOALS HOMEOWNER PLANNER GROUPS OMMERCI NEEDS & AND GOALS INDUSTRIAL NTERESTS NEEDS & GOALS FIGURE 6d Coordinator Catalyst NEEDS & GOALS CITIZEN NEEDS & AND GOALS HOMEOWNER GROUPS ' NEEDS & GOALS' BUSINESS NEEDS & COMMUNITY OFFICIALS AND STAFF ALTERNATIVE PLANS SCHOOL AND UTILITY DISTRICTS COMMUNITY OFFICIALS ALTERNATIVE PLANS ( FIGURE NEEDS & GOALS CITIZEN 45 6e Advocacy Planning COMMUNITY OFFICIALS AND STAFF AND OMBUDSMAN HOMEOWNER (ADVOCATE) PLANNER GROUPS ALTERNATE PLANS INDUSTRY SCHOOL NTERESTS AND NEEDS & 1 UTILITY GOALS DISTRICT FIGURE 6f Arbitrative Planning NEEDS & 1 COMMUNITY GOALSyjf OFFICIALS BUSINESS STAFF AND PROFESSION MODIFY OR GROUPS APPROVE PLANS I I CITIZEN AND HEARING PROPOSED HOMEOWNER OFFICER PLANS PLANNER GROUPS ALTERNATE COMMERCI PLANS AND INDUSTRY SCHOOL - NTERESTS AND NEEDS & 1 UTILITY GOALS DISTRICTS 46 as the primary receiver in a three-step communications process. The arbitrator is in a position to control information received from various client groups and the agency. By negotiating differences between client groups and forwarding recommendations to the agency the arbitrator exercises some degree of control in the planning process. The arbitrator's role is to only communicate responses to the agency's proposals and therefore the arbitrator is active at specific periods in the planning process. These periods would be during the initiation of the study, when alternatives are being developed, during the time the alternatives are being formulated into a plan and finally, when the final plan is adopted. A disadvantage to this type of sporadic contact is that it leads to gaps in understanding among the client groups. 7. Plural Planning (Figure 6g) Plural planning, as its name implies, is a strategy that allows each client interest to independently develop alter- natives and submit a plan. The agency would reconcile conflicts between various client interests, alternatives, and plans. Agency personnel would consolidate the various plans and augment the final plan in areas not addressed by the client groups. However, it is not realistic to assume each client group would have the expertise necessary to develop a plan. The basic idea that each group would address their own needs and develop methods for dealing with them is significant. Another form of plural planning 47 m4noucH apono cowmmpomwa mcowumucOmmum apouo mouom xmme .wawocpoo kHOOH>p< meaanOnEOz wouuHEEoo mumcwamm mmosmxuo3 w<3 03H mequHHpm e mumumom muuommm pummoum mkwaamwn mwcHHHmE Hmwoomm OOHDSOOHm mmowuoz wamq mumuumam3mz wuuommm mmmuwoum ><3 mzo mmWH ZOHHcm Houomuucou Hmooq mamwowmmo unoaauo>ou mDOMU HMOMan agency action. In fact, many projects in the early 70's were stopped by court action until such a public review could be held. 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This emphasis on techniques obscures the importance of the objectives and encourages the borrowing and adopting of techniques without a critical evaluation of their benefit.68 The experience of other agencies should be utilized to tailor the technique to the objectives of the sponsoring agency. This type of tailoring effort requires the expertise and commitment of agency personnel beyond the traditional levels known to most governmental planning agencies.69 The commitment of agency resources to public in— volvement programs had been mandated by legislation and planning guidelines. These mandates, however, are general in nature and leave responsibility with the agency to implement a program. Agencies find themselves requiring additional staff support not found within their ranks and expenditures in areas where there is little or no previous experience to guide their judgments. In a survey of government planning organizations, conducted by Katherine Warner, the two most frequently mentioned factors needed by agencies to accomplish public participation programs 68Patricia Bonner and Ronald Shimizu, eds., "Proceedings of a Workshop on Public Participation," Great Lakes Research Advisory Board, International Joint Commission, June 1975, p. 53. 691bid., p. 183. 124 were "additional staff members and additional funds."70 This self-reported survey reflects only the agencies' point of view. However, it does indicate the need for such programs to be adequately funded and staffed. The agency must develop their plan for public in- volvement with these constraints in mind. By specifying the resources required before the planning process begins, a realistic budget can be developed and funds can be ear- marked for implementation of the desired techniques. As with any effort, the funding requirements for techniques that occur in the final stages will be jeopardized if a commitment does not exist to carry them out. With little previous experience in public participation, many agencies underestimate the total cost involved in offering a pro- gram. Some of the expenditures necessary in the program can be obtained through agency staff. Printing, meeting room rental, transportation and mailing charges are common to agency programs. Funding for guest speakers, surveys, advisory committees and informal contacts are much more difficult to establish. Equally important to the funding requirements are the manpower skills that will be necessary to carry out the program. By developing a plan the agency can be pre- pared for such requirements by training their staff or hiring consultants to perform the tasks. Staff training 7°Ibid., p. 183. 125 should be extended to the entire agency staff to help them interact with the public. Technically trained staff mem— bers may find it difficult to relate to the public and should be assisted in this effort by specialists in com- munications and public relations. The agency must allocate the resources, that will be required throughout the program, at the onset of the program. By doing so the staff and participants will feel that a commitment to implement them exists. Uncer- tainty on the part of the agency will cause the partici— pants to lose faith in the process. With a plan developed and the resources necessary to carry it out allocated, the agency will be in a position to follow through with its program. CHAPTER III AN APPLICATION OF PUBLIC PARTICIPATION OBJECTIVES TO THE TCRPC's 208 PARTICIPATION PROGRAM TCRPC's Public Participation Effort With any planning effort the actual implementation and realization of some specified desire may not be con- sistant with its conceptualized notion. The TCRPC's pub- lic participation program and the staff's perceptions exemplified this phenomenon. With little public involve- ment experience, the TCRPC 208 staff attempted to develop and implement a public participation program. This pro- gram was to assist the agency in developing an Areawide Water Quality Management Plan. This plan was part of a national effort to develop and implement measures to meet the long range goals of the Federal Water Pollution Control Act Amendments of 1972. In referring to Section lOl(e) of the Act, the Environmental Protection Agency, as admini- strator of the Act, specified that "the purpose of public participation in the water quality management process is to aid public education, create a plan sensitive to local needs and values, and build support for plan 126 127 implementation.”71 The sequence of events that the TCRPC used to develop its 208 plan and public participation program can be reconstructed through program documentation. The moti- vations behind these events, however, can only be specu- lated. Changes in staff and program emphasis continually modified the program since its inception. The text that follows is a documentation of events and procedures used by the TCRPC to develop and implement its public parti- cipation program. The TCRPC 208 planning program was initiated when Michigan's Governor Milliken announced in January of 1975 that the regional governmental agencies of Michigan would have the primary responsibility for developing the required plans. Each of Michigan's 14 regions was to sub- mit a program documentation and a request to the Governor for official designation. On March 28, 1975, the Governor designated the TCRPC as the areawide waste treatment management planning agency for Clinton, Eaton and Ingham Counties. Shortly after designation, the TCRPC began developing a study design to submit to EPA for approval and funding. The EPA Region V office officially offered financial assistance to TCRPC on June 27, 1975, and a Study Design was completed in August. Documentation and elements 71U.S., Environmental Protection Agency, Water Planning Division, Public Participation Handbook for Water Qpality Management (Washington, D.C.: June 1976), p. l. 128 of a work program were developed by the TCRPC staff for submission to EPA. This documentation outlined the work tasks necessary to develop the 208 management plan. Many of the tasks outlined in the Work Program had already begun when it was submitted in March of 1976. The formation of the 208 Technical Planning and Coordinating Committee (TPCC) and Areawide Planning Advisory Committee (APAC) in November of 1975 were significant in retrospect because they represented the only long term contacts the 208 planning staff developed. APAC represented the governmental units and agencies of the region. TPCC represented the technical agencies of the region. These two committees provided the agency with feedback and suggestions for the plan's development. A Citizens Advisory Committee had been formed by TCRPC in March of 1975 to provide input on a variety of program and planning areas. This committee, however, never became actively involved in the 208 process. The 208 program had its first public exposure in a Workshop sponsored by the League of Women Voters in April of 1976. This workshop was developed to stimulate interest in the planning effort and to acquaint participants with the TCRPC. A public meeting held in August of 1975 to dissem- inate and discuss project information marked the midpoint in the 34 month planning program. Printed materials in the form of brochures were first disseminated in September of 1975 although no records of recipients or quantity of 129 of brochures mailed were maintained by the agency. The agency utilized the membership list of APAC and TPCC for its information mailings. The agency also utilized its governmental unit's mailing list and an "interested persons list" for the mailings. This ”interested persons list" was referred to as a participants list by the 208 staff in their reports to EPA. The agency produced and disseminated the first of three newsletters in November of 1976. The agency utilized the previously mentioned mailing lists to distribute the newsletters. The 208 staff promoted a workshop in April of 1977 that was developed and presented by the Issac Walton League. In the spring of 1977, the agency held meetings with local elected officials to encourage them to support the plan and upcoming river basin meetings. These basin meetings in May, June and July were to get people involved in the final stages of the planning process. These meet— ings were publicized in local papers and announced in a brochure that received the broadest distribution under- taken by the agency. The river basin meetings were fol- lowed by two months of final plan preparation that culminated with a public hearing on September 21, 1977. This hearing and the written comments generated from it were the last opportunities for the public to influence the final plan. The Tri-County Regional Planning Commissioners had an information session on October 19 to review the staff 130 recommendations and comments received regarding the final plan. Less than a month later at a normally scheduled TCRPC meeting on November 16, 1977, the Commissioners approved the plan for submission to the Governor and EPA with a nine to six vote. The elements of TCRPC's 208 plan discussed in this section are displayed in Figure 8. A review of the time scale and mechanisms documented in Figure 8 demonstrates the emphasis that the 208 staff placed on public participation in the final stage of the plan's development. This reconstruction of the 208 public participation program documents the mechanisms that were utilized by the staff. A comparison of the public parti- cipation elements outlined in the March 1976 Work Program and the elements actually utilized by the 208 staff indi- cate that the public participation program was not executed as it was planned.72 Some changes in the planned public participation program might have been justified. However, TCRPC 208 staff manipulated the program without developing an alternative strategy. In fact, two work tasks vital to the implementation of the entire public participation program, outlined in the Work Program, were never implemented.73 The tasks were to develop a criteria to evaluate citizens participation input and to 72Tri-County Regional Planning Commission, 208 Areawide Waste Treatment Management Program: Work Program (Lansing, Michigan: March 1976), p. 113-5. 73Ibid., p. 34, 60. 131 no.2.»— £2 :0— :222 » gggpfsgggu3§§s3§§§>ISiE§ 2 >0: ‘3 on...» a: use: no 8:38 ooze-nu: 2 2.0%. a; ul- voaougoa so: um 98 v:- vouooauoo scan-oasis logo» 9093028 12.35 .0» :35 u: '59: anon soon in” .u.“.u.o.“o ‘03.. «in «u Quin #063303 on. cucn 25A...“ 36 Gog 99 some Oeeeeoooee e o ® i1 82:... u q quench—8.5.85 £5388~Ifie8a . . .58 .38 g 8.x...— _ S .5 8-38! 88... 1.5 _ e 8.1: 0 3E.— cg .5236 In: I»: E42. gs nae—nu .5 ...H ...E... .. E g 5 g a: <44 mOOmn. ...Zwiw >...O>Z. Uija wON UamU .r m “HEDGE 132 develop a participation log. The evaluation criteria was to "assess the effectiveness of TCRPC public participation efforts" and the participation log was to be a "file to facilitate public participation evaluation work tasks."74 The agency, in a final documentation of its public parti- cipation program, failed to make any reference to these tasks. When asked in an interview why these tasks were not completed the project coordinator stated "we should have done them, but we just could not find time. We felt "75 While this it was more important to get a final plan. statement has some merit when applied to the preparation of the final document, it is not a valid justification for the staff's dilatoriness during the preceding two years of the planning process. The public participation tasks outlined by the TCRPC staff, in its Study Design and Work Program docu- ments, were the only written materials generated that addressed how the public participation program was to be developed. The tasks documented by the Work Program are listed with those actually utilized in the planning program and are displayed in Table 4. This comparison does not evaluate the individual efforts, it simply indicates which of the work tasks were utilized and 74 75Interview with Karna Hanna, Associate Planner, Public Participation Officer, Tri-County Regional Planning Commission staff member, Lansing, Michigan, 11 May 1978. Ibid. 133 TABLE 4 WORK TASK IDENTIFICATION AND UTILIZATION Listed in Work Undertaken Completed Program APAC TPCC Participation Log NXNN ix: Information Depositories >< Institutional Map Opinion Leader X X Surveys Participation Program X Evaluation Criteria Public Hearing X X Newsletters X Brochures X Interim Outputs X Public Meeting River Basin Meetings X Local Government X Meetings Mailing Lists X *Dissemination of project information was noted as a work task without addressing mechanisms to do so. 134 documented in the development of TCRPC's 208 plan. A description of the individual mechanisms used by the TCRPC 208 staff can be found in Appendix B. The omission of work tasks that were specified in the first stage of the plan- ning process may be justified but to do so without con- sidering tin: consequences or developing an alternative strategy is capricious. The entire TCRPC 208 public participation program was characterized by a lack of fore- thought and follow through on the part of the staff members. The TCRPC staff did not document any evaluation of their public participation program. The only technique evaluation generated during the planning program was from participant questionnaires distributed at the river basin and interim outputs meetings (see Appendix C): The questionnaires distributed to the participants at the interim outputs meetings focused on the meeting format. Questionnaires utilized at the river basin meetings focused on alternative and preference identification although they contained some participant identification and program evaluation items. Each of the six river basin meeting questionnaires was tabulated independently. The tabulation from the first meeting was presented to the APAC on May 18 and to the TPCC on June 8. The TPCC also received the tabulation for the second river basin meeting on June 8. In documenting the river basin meetings, the staff referred to the questionnaires and the fact that "generally about 135 76 The staff half of those in attendance filled them out." went on to say that "while the results of the survey were in no way statistically valid, they did provide a signi- ."77 The text ficant level of response from a public... that followed this statement described a summary of the basin questionnaires and staff responses. Assumptions regarding program format, information sources and alterna- tive preference were articulated in these staff responses. To base any statement of program or public preference on an unvalidated sample of less than one-thousandth of the region's population seems to be presumptuous on the part of the staff. These inferences by the staff refer to the feedback obtained through only one of the mechanisms used during the thirty-four month public participation program. To evaluate this and other input, the staff should have considered the entire effort. Evaluation of the public participation program must be done on two levels. The techniques themselves should be reviewed, utilizing des- criptive attributes. Attibutes listed in Table 3 and the text describing them have been applied to the techniques used in the Tri-County effort to evaluate their utility. The second level of evaluation refers to the objectives 76Tri-County Regional Planning Commision, 208 Water Quality Management Plan, vol. I, part 1 (Lansing, Michigan: August 1977), p. 71. 77Ibid. 136 or goals of public participation programs specified by the author in a previous section. Comparison With State of The Arts and Objectives Technique Evaluation The first level of evaluation compares the indivi- dual techniques with their state of the arts descriptions and applications (see Table 5). The second level of evaluation considers how each of the techniques, identified by the author as significant through the first level of evaluation, contribute to the specified objectives of public participation programs. This evaluation of techniques utilized by the TCRPC staff begins with the two committees developed in the early stages of the planning process. APAC and TPCC were the only long term contacts established in the agency program. APAC was developed to involve the governmental and agency interests of the region. In developing this committee the agency created a representative contact. "ResolutionsHH A \ a p o c p 3 p m u {I}: C>CuOucH mumAA AAmz mApoz m3oz mwcwummz ucoficum>ou monmxnoz mmuuAEEoo .2 mupmupo EAHmucH moupnoonm mwcAuomz :Ammm Ho>Am aeraxpoz 42H monmxuoz >3A mmAMouAmomoa muouumAmamz mwcwuwmm OAAApm UM mMHDmHmHH< m>HHmHmommn m mAmAuOOmAO Op SOAupAAuupoo mmumOApcA x x x OApoz mzoz x x x waAuooz upmacuo>ou x x x x x x x x wcwummz cAmmm Hm>Am x x x x x x wcAumom OAAApm x x x x wcAuomz_mupmupo EAuoupH x mOAHouAmomOa mumAA AANZ x x moupsooum x x mnoquAm3mz x x x x x Dome x x x x x oAO>ZH UHAmDm w.UmmoH c mAmm m>HHUmhmO 167 the specific group of participants. These meetings focused on the alternatives specified by the agency. Since the participants had not been involved in the planning program to that point, the agency dominated the majority of available time with information dissemination. This infor- mation was necessary for participants to specify their concerns. While some conflict resolution did take place at these meetings, the input was minimal and the agency found it difficult to incorporate this input into the plan- ning program. The sole contact approach these meetings provided with participants limited the amount of conflict resolu- tion that could take place. The agency did not provide a continuous contact with these participants. The alterna- tives presented by the agency narrowed the range of responses participants could provide. The agency was, in fact, promoting specific alternatives during these meetings. The participants were, therefore, providing reactions rather than resolving conflicts. The two previously mentioned committees consequently provided the agency with the best opportunity for conflict resolution. These committees, however, were limited in scope and involved a highly specified group of partici- pants. Conflict resolution, therefore, was not incor- porated into the program. While conflict resolution was considered by the agency to be a part of the program, the mechanisms used to facilitate it were not adequate. 168 The agency's involvement with participants during the planning program provides the basis for an active participation program. Many traditional public partici- pation techniques such as public hearings, mailings and depositories provide information for the public. While these techniques address the legal requirement for public information, they lack the characteristics necessary to motivate the public. The agency must be aggressive in their recruitment of participants. The TCRPC focused their active participant contacts on established agency clients. Through the TPCC and APAC the agency demonstrated the characteristics necessary for an active program. By supporting these committees throughout the planning program the agency demonstrated a commitment to these participants. The agency's staff became actively involved with these committees in discussing the water problems of the region and developing alternative solutions. By meeting with these committees over a period of time the staff developed a working relationship. This relationship provided a foundation for the agency to advance through the phases of the planning program. The agency's utilization of a newsletter program demonstrates another active participation mechanism. While the newsletter program did not realize its full potential, it did contribute to the overall program. The staff's decision to limit the distribution and publication of the newsletter detracted from its utility. The three issues 169 of Waterlog, produced by the agency, addressed the informa— tion generated during the preceding planning phase. This step by step approach used to present the information generated during the planning program could have been utilized to recruit and provide background knowledge to new participants. The agency actively promoted and held six river basin meetings during the final months of the planning program. These meetings were the most active mechanism utilized by the agency for involving the general public. By addressing participants that were previously uninvolved in the process, the agency attempted to develop their interests and motivate them to participate. While they were successful in motivating new participants, the staff found it difficult to integrate their input into the program. With only a few months remaining before the final plan was to be completed these new participants were questioning the foundation upon which the alternatives were developed. This demonstrates the need for involving a diverse public throughout the planning program. The diversity of participants is an important objective in developing participation programs. The ten- dency is for agencies to identify groups or representatives from established contacts. While such participants can provide the foundation for the program, the agency must seek out others affected by uninvolved interests to participate. The first step in this process is to identify 170 broad interest areas that will be affected by the planning program. The TCRPC staff did not develop such a framework. They approached the program with the assumption that it would affect all the people of the region and, therefore, no specification was necessary. Such a broad identifi- cation, however, was not sufficient to motivate partici- pation. The agency staff took steps to encourage partici- pation by specific groups through APAC and TPCC but ignored other water related interests within the region. Each of the techniques utilized by the staff to address the diverse interests were solitary and did not build upon one another or the program. The agency should have varied the techniques used to address the public. The staff could have increased participation in the early stages of the process through workshops or discussion groups as opposed to relying solely on public hearing and public meeting formats. As docu- mented, the techniques utilized by the agency during the first half of the planning program, emphasized information dissemination. Brochures, news articles and depositories provided the public with information but lacked feedback mechanisms necessary for participant involvement. Oppor- tunities for the public to interact withtjuaagency intensi— fied during the final phase of the planning program and focused on the previously developed alternatives. Without an active part in developing the alternatives, these part— icipants were expected to articulate their preferences 171 within the short time period of the meetings. Two important aspects of the communication process, between participants and agency staff, were not recognized in this particular program. These aspects of the two-way communications process are critical to its utility. Two— way communications must take place with a range of participants and extend over the entire planning period. The agency engaged in two-way communications with the public through the interim output and river basin meetings. These meetings represented significant milestones in the planning program that required feedback. The agency, how— ever, was not motivated to communicate with the public continuously during the planning program. The agency utilized two-way communications with the APAC and TPCC during the entire planning program. These committees maintained their interaction with the agency by holding regular meetings at which staff members and consultants were present. This commitment by the agency provided these committees with an opportunity to explore questions over an extended period of time. The agency attempted to develop two-way communications with the various governmental units of the region through a series of governmental meetings. These meetings, like the public meetings, found the participants unprepared to respond. The agency had not established a foundation with these participants through prior communications. 172 The agency neglected to establish mechanisms to encourage and gather input from participants throughout the planning program. While the major public meetings provided such channels, their focus and timing limited the public's contribution. Channels for public input must be established and supported by the agency. These channels must be maintained throughout the planning process. The agency concentrated their efforts on inputs received through APAC and TPCC. These committees provided a channel for established agency clients. These inputs were utilized by the agency to represent the broad interests of the region. However, such a broad representation did not exist on these committees and their input lacked the sentiments of those participants not represented. The agency did not evaluate their channels of communication at any time during the planning program. The majority of the program lacked any type of identifiable structure for incorporating public input into the process. Input from the formal meetings and hearings was documented in the final plan. This input, however, referred to the alter- natives developed by the agency. Public input regarding problem identification was inappropriate at this stage of the planning program. This articulation of concerns by the public during the final stages of the planning program caused the staff to display a defensive posture toward the plan. The public had not been involved in the planning program prior to 173 these final meetings. Since the agency presented the information at the meetings, participants often assumed that the staff had developed the plan. The participants did not identify with the representation of APAC or TPCC and therefore felt their viewpoints had not been incorporated into the written plan. The river basin meetings and public hearing did provide the public with an opportunity to articulate their desires. These inputs, however, could be characterized as reactionary rather than developmental. The agency recognized the need for govern- mental units of the region to express their desires in the early stages of the planning program. The general public, however, was neglected until the alternatives were developed. The problem identification and goal setting phases of the planning program were developed by only a segment of the participants. The agency assumed that the interests identified by the TPCC and APAC would represent the general public. In developing the public participation program, the agency neglected to identify the broader range of participants that existed and also neglected to provide them.with mechanisms to articulate their desires. An emphasis was placed on information dissemination throughout the planning program. The staff had experience in disseminating program information to its member units of government and the media Of the region. The information effort for the 208 planning program was based on these 174 contacts and relied on techniques previously utilized by the agency. The staff concentrated their efforts on disseminating program information rather than developing and delivering educational material. In a planning program of this magnitude, the agency should have addressed the educational and awareness requirements of the public within the region. The complexity and scope of the 208 planning program frustrated the staff in their attempts to work with the governmental officials of the region. These officials needed a better understanding of the program as did the general public. The agency assumed that the traditional media coverage was adequate to develop a level of public understanding sufficient for their participation. Such a level never materialized within the population of the region. The agency attempted to enhance participant understanding through newsletters and brochures. These materials, however, were distributed to only a small seg- ment of the region's population. The agency suggested, in the final plan, that the newsletter be continued in the future to inform citizens of progress on 208 plan imple— 88 The agency did not evaluate the impact of mentation. its newsletter during the initial planning period. As the author has described it in a previous section of this paper, the newsletter did not inform the public about the plan but rather addressed established participants and 88Tri-County Regional Planning Commission, 208 Water Quality Management Plan, vol. I, part 3, p. III. 175 provided the agency with some exposure among its clients. Since the agency did not develop a broad base of partici— pants, the need for educational materials did not develop. By working with the TPCC and APAC the staff was able to support the committees' informational needs. This staff support reinforced the committees' basic understanding and encouraged their participation. Such support was not extended to the Citizens Advisory Council during the planning period. The agency staff responded to requests for information but failed to address the need for an educational program to enhance participation. The staff could identify with the participants of APAC and TPCC. These committees provided the agency with feedback on a variety of planning alternatives. Each committee concentrated their evaluations on specific areas of concern. APAC, as representatives of governmental groups, articulated their preferences for management and funding strategies. TPCC's inputs centered around the technical opportunities that the planning program provided. While both these committees reviewed the alternatives as presented in the final plan, they lacked the comprehensive approach a broader representation of participants could have provided. As the primary indicators of planning direction and alternative selection, these committees were not representative of the identifiable interests within the region. 176 The agency began to collect information from a broader range of participants after the alternatives had been developed. Feedback received through the river basin meetings and public hearings indicated preferences for specific alternatives presented by the agency. Comments from some participants at these meetings indicated their desire to pursue options not identified as alternatives in the plan. The staff's response to these inquiries was that this plan was a first attempt and it could be updated after initial approval. This approach to new inputs was due in part to the time limitation imposed for the plan's approval. The opportunities for alternative modification were minimal. These inputs did, however, provide the agency with an indication of alternative preference and an indication of the participants' perceptions of the entire plan. Discussion of Rationale for The TCRPC's Program A review of the techniques utilized in the planning program using the objectives identified by the author highlight two significant aspects of the agency's effort. The first significant factor was the emphasis that agency staff placed on interacting with TPCC and APAC. These two groups represented specific identifiable interests of the region. They, however, did not represent all the identifiable interests of the region and lacked representa- tion from the general public. The EPA made specific 177 reference to including representatives of the general public on the policy advisory committees in their guide- lines for planning programs. TCRPC's program lacked this general public representation during the first twenty-four months of the planning program. The second factor relates to the agency's timing and delivery of the river basin meetings. This meeting format had the potential of involving a broad range of participants in the planning process. The agency, however, delayed these meetings until the alternatives had been developed. While the meetings did contribute to the fulfillment of the objectives, their potential as a mechanism for involving participants in the initial phases of the planning program was not recognized by the agency. The author noted at the beginning of this section that events of the planning program could be reconstructed through program documentation but the staff's motivations could only be speculated. Reflecting on the total program, including contacts with participants, review of program documents, staff interviews and personal observations, H the author offers the following discussion of agency" rationale. The staff began the planning program without previous experience in developing public participation programs. The EPA had developed requirements for minimum participation standards and specific guidelines for addressing program elements. These elements identified 178 various aspects of the planning and implementation program. Access to information, consultation, enforcement efforts, legal proceedings and rule making activities are examples of the program elements. The EPA notified the planning agencies of these requirements in the Federal Register, 89 dated August 23, 1973. Approximately four years later, in June of 1976, the EPA published a Public Participation Handbook for Water Quality Management. The preface of the handbook begins with "This handbook is one of a series designed to provide States and areawide agencies with assistance in carrying out water quality planning."90 TCRPC had been engaged in its planning program for fifteen months when this document was distributed. This delay typified the support offered by EPA to those agencies designated in 1974 and 1975. Without practical experience or EPA guidance, the staff began the public participation program. The 208 planning staff was comprised of persons with urban planning, natural resources and sanitary engineering backgrounds. The information officer was a journalism graduate and had demonstrated an ability to function effectively with media representatives. Without the advice of someone in the social science field to consider the public's needs, the staff began to 89U.S., Environmental Protection Agency, Water Pro- grams, "Public Participation in Water Pollution Control," pp. 22756-8. 90U.S., Environmental Protection Agency, Water Planning Division, Public Participation Handbook for Water Quality Management, p. i. 179 develop their program. Logically, they began with the identified interests of the agency, local units of govern- ment and the technical interests of the region that had been involved in previous agency activity. These interests became identified as APAC and TPCC respectfully. The program documentation during the first sixteen months of the planning program except for the material documented in the work program, lacked any reference to a public participation plan. This leads the author to con- clude that the staff did not feel a need for such a plan. This conclusion is reinforced by the agency's failure to develop a public participation log or evaluation criteria 91 The author found as outlined in their work program. no evidence to indicate that the staff deliberately subverted or neglected any attempts by the public to participate. They simply did not recognize the opportuni- ties for the public to participate. The individual designated as the agency's public participation coordinator had additional responsibilities that superseded her role as public participation coordinator. There were identified technical tasks to complete and the staff placed a higher priority on them than on the public participation program. Without pressure from the EPA or the public for more participation opportunities the staff was content to 91Tri-County Regional Planning Commission, 208 Areawide Waste Treatment Management Program: Work Program, pp. 34, 60. 180 continue the planning program without modifying their approach to public involvement. Potential for Continued Participation The potential for public involvement in the continuing planning process within the region as required by sections 208 and 303 of 92—500 92 and specifed in the Federal Register93 is not promising. In the final plan, the agency recommended a structure for implementation and continued planning that acknowledged public participation in the following manner: In order to continue the opportunity for the public to give advice and opinions on water quality matters, it is recommended that a Citizens Clean Water Committee (CCWC) be formed for each WQMB. The role of the com- mittee would be to advise the WQMB on issues coming before it for consideration and to alert it to new areas of concern. The chairperson of the respective WQMB, who is a member elected from the WQMB, would also sit on the CCWC to coordinate activity among the three groups. To encourage citizen input at the regional level, it is recommended that a Water Quality Subcommittee of the Citizens Advisory Council be established to give input to TCRPC. It is further recommended that a member from each of the CCWCs form the nucleus of the Water Quality Subcommittee. A person from TCRPC would provide technical assistance to the CAC and CCWCs. 92U.S., Congress, Federal Water Pollution Control Act Amendments of 1972, pp. 839, 846. 93U.S., Environmental Protection Agency, "Policies and Procedures for Continuing Planning Process, p. 55349, Sec. 131.22, part c. 181 The recommended structure is depicted in Figure 1-2 (see Figure 9). It is important to note that each functional category has its own special set of functions. There is no top or bottom per se in the chart. In this recommended structure, the agency delegates the majority of responsibility to the Water Quality Manage- ment Board for organizing and encouraging public participation. The agency's role of providing technical assistance to the Citizens Advisory Council and Citizens Clean Water Committees is not sufficient to insure participation. The agency failed to establish a meaningful relationship with the Citizens Advisory Committee and failed to organize a Water Quality Subcommittee during the initial planning program. To presume the interaction between the CAC and agency staff would change during the continued planning process is serendipitous. To encourage the public within the region to participate, the agency would have to undergo a radical change in their approach to and understanding of public participation. This author does not foresee any forces from.within the region, state or EPA regional office that would cause the agency to change. If, in fact, the 208 plan is to be updated or modified, an alternative strategy for public involvement could be established and funded. Agencies and organized groups within the region such as the Cooperative Extension Service, United Conservation 9L'Tri-County Regional Planning Commission, 208 Water Quality Management Plan, vol. I, part 1, pp. 22-4. .Ax .AnnmA "A: .wcAmcmAv .H .Ao>.cmAm ucoEmwmcmz muAAmnc nouns mom .aoAmmAEEoo prccmAm Amcowwom muGDOUnAHH "AUMDOm 182 ”5:583 885382.53 55558 .88 5.852.. : 5... 5...... 8.2.25.2. 388258. - 8:252, . 88:58 H .5... :58 .555. :58 :58 e . E... .3... 28:2 .. 5.23 .25... 5.55. 55 5:58 5:sz max—mg hwHHA