Promoting public participation in national environmental health action plans

The extent to which public participation is required in developing National Environmental Health Action Plans (NEHAPs) is both an issue of democracy and public participation in different countries, and an issue of effectiveness in implementing plans. In some countries public participation will be central to successful implementation, in others the general public will be treated as passive recipients of state authority direction.

Successful implementation of NEHAPs will require that the many different stakeholders – principally the general public – have equal and effective access to relevant information; are helped where necessary to understand both the meaning and limitation of this information; have a voice in decision-making and are empowered to choose.

A well informed, engaged and empowered public can be an important driving force for NEHAP implementation: local organizations, communities and individuals should accordingly be involved at an early stage and throughout the process. In this regard, the signatories to the Århus Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters (1998) have agreed to apply its principles with equal force to environmental health issues. Effective involvement of the public is conditional on the NEHAP being presented in an accessible form. States should therefore develop communication strategies at national and local levels.

In principle, the goal of public participation is to give each and every member of society the opportunity to participate. Local decision-making processes should generally allow for direct participation by the public, and other decision-making processes should also do so as far as this is feasible.

NEHAPs should be available and understandable to the public, and they should be as non-technical as is compatible with proper rigour. In this context, NGOs perform a useful function in interpreting the plan to the public and giving it local relevance. Educating and empowering people with regard to environment and health issues will encourage greater public participation.

Where public participation is viewed as central, bottom-up strategies will be employed both in developing and in implementing NEHAPs. In developing the NEHAP the principal stages of a bottom-up approach might be: (1) the government invites regional and local authorities and other interested parties to make their proposals for a plan; (2) the government or designated agency integrates the various proposals into a coherent draft national plan; (3) the draft plan is then published or put out for comment from all interested parties; and (4) the government takes account of comment in a definitive plan and takes any constitutional steps necessary for approval of the plan.

Among the disadvantages of the bottom-up approach are: (1) the government may have to issue guidance on what is required from contributors or have to pull together widely different approaches; (2) the government may lose control of the timetable, which is likely to be longer than a top-down approach; (3) it is probably more resource intensive, at least initially, than a top-down approach; and (4) it may be difficult to integrate international aspects into the plan.

In the top-down approach, the principal stages of preparing the plan might be: (1) the government or a designated agency prepares a draft of a national plan which so far as possible takes account of local, regional and international considerations; (2) the draft plan is then published or put out for comment regionally and locally. Comments could also be obtained from all interested parties at this stage; and (3) the government takes account of comment in a definitive plan and takes any constitutional steps necessary for approval of the plan.

The top-down approach has the disadvantage that it may appear too authoritarian and inhibit participation from those outside government. Moreover, the government may find itself under two types of pressure: to become over committed to what are intended to be no more than initial proposals; and to be under pressure to expand the plan beyond what is reasonably achievable.

The background study carried out by the Regional Environmental Centre for Central and Eastern Europe (REC) shows that while some countries have given the public wide possibilities for participation in the NEHAP process, in others there is little or no public involvement. In the case of LEHAPs (or similar initiatives such as Local Agenda 21 or Healthy Cities), a greater degree of participation appears to have taken place. Although the REC survey covered a relatively small selection of countries and at a fairly early stage in the NEHAP/LEHAP process, its results indicate that there is much room for improvement.

The European Charter on Environment and Health, adopted at the First European Ministerial Conference on Environment and Health in Frankfurt in 1989, recognized public participation to be an important element in the context of environment and health matters. At the Second European Ministerial Conference, held in Helsinki in 1994, this recognition was reflected in the emphasis given in the Environmental Health Action Plan for Europe to the goal of strengthening the involvement of the public and nongovernmental organizations (NGOs) in environmental health decision-making.

Public participation has also emerged as a priority issue in other fora, most notably in the Environment for Europe process. At the Third Ministerial Environment for Europe Conference, held in Sofia in October 1995, environment ministers from throughout the region covered by the United Nations Economic Commission for Europe (ECE) endorsed the ECE Guidelines on Access to Environmental Information and Public Participation in Environmental Decision-making.

Partnerships between the public and private sector are one way to harness the private sector for public good. Moreover, pressure of demand from a knowledgeable and engaged population exerts a powerful influence on economic sectors. Some enterprises now combine a review of environmental performance (often including occupational health and safety) with their annual reporting system. States should urge enterprises to enhance the value of such reviews by extending them to environmental health.