Extraordinarily weak enviro DOH Review letter

The letter reportedly being circulated among environment and good government groups regarding public participation in the DOH Review of the "health impact analysis" in the Revised Draft SGEIS is poorly thought out, vaguely drafted and entirely insufficient. I request that it not be submitted in its current form.

First, the reader can hardly tell what is being referred to.

Second, the letter would not prevent the DOH Review from being completed because it does not require immediate public notice of the intent and scope of the proceeding as well as review and comment about how the effort should be undertaken. Instead, the letter requests a 60-day comment period after the DOH Review is completed. That makes no sense. It would be too late to change anything by then.

The letter also might conflict with a major institutional initiative that could be underway to require public notice, public comment and a hearing about the proceeding along the lines of the hundreds of communications that have already been submitted to the Governor requesting:

a) immediate public notice of the intent and scope of the DOH "health impact analysis" Review;

b) a 30-day minimum public comment period;

c) at least one public hearing to require the reviewers to hear testimony from interested parties; and

d) a restart of the SGEIS proceeding to allow public comment about how best to resolve all the concerns documented about DOH's inadequate review.

Finally, the Administration has repeatedly made clear that no Final SGEIS will be adopted until the DOH Review is completed. I do not think that matter is in question.

Our problem is that the DOH Review will be entirely inadequate unless we expand the scope of the proceeding by requiring full public participation.

I wrote about that concern to the Governor: http://www.toxicstargeting.com/MarcellusShale/documents/letters/2012/12/...

Unless I hear by 10:00 AM that the letter will be revised to address these serious concerns, I might let 10,000+ people know about its shortcomings.

Many activists are already extremely unhappy about the weak position taken by one of the groups in this matter. See bottom section at:

http://www.toxicstargeting.com/MarcellusShale/alerts/2012/12/10/immediat...

I strongly urge you to beef up the letter.

Best,

w