Email submissions

Environmental Assessment Office

Email submissions

Please note that personal identifiers such as personal names have been removed from the comments below to protect the privacy of individuals submitting feedback to the Environmental Assessment Office consultation.

Date Received: May 23, 2015

BC's Environmental Assessment Office comments on public participation

BC's coastal ecosystems sustain life and cultural traditions. We need new and progressive marine planning, diverse solutions to sea-level rise, and stronger regulations for fish farms.

To better achieve its goals, consult meaningfully and ensure public ‘buy in’ of projects, the EAO should follow the excellent recommendations of the West Coast Environmental Law Group:

Require the involvement of the public throughout all stages of the assessment;

Ensure that formal public comment periods are long enough to allow the public to thoroughly analyse all relevant information and prepare detailed responses;

Ensure that all relevant records are considered by the EAO and made publicly available;

Build flexibility into formal public comment processes to reflect the varying complexity of and public’s interest in different projects, and accommodate identification of data gaps and the reception of new information;

Require that all information and comments related to follow-up, monitoring, and compliance and enforcement be made publicly available;

Require proponents to respond to all public comments and that those responses be made publicly available;

Provide sufficient public funding to enable participants to analyse information and prepare comments at all stages of the assessment on issues of importance to them, including retaining experts and counsel where appropriate;

Establish means of providing “dialogue participation methods,” such as advisory committees, task forces, and community or advisory boards to emphasize ongoing dialogue and communication among parties; and

Establish a mechanism for addressing and resolving broader systemic concerns regarding the EA process by First Nations and the public.


To Whom it Concerns:

I write to express my support of the West Coast Environmental Law proposals to improve the EAO process.

Your website states that comments must be in MS Word document format.

I think that PDF format is even easier to access, and so I have attached the submession to EAO from West Coast Law in PDF format.

Please note: the letter can also be found at this URL link: http://wcel.org/sites/default/files/publications/2014%2011%2024%20EAO%20public%20participation_WCEL%20comments_0.pdf

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Recommendations for improving public participation in BC EAs

Environmental assessments should have early and ongoing processes, as well as adequate time and resources, to meaningfully engage the public. Limited participant funding, restricted opportunities, short timelines, poorly developed processes and narrow project scope impede public participation.

To better achieve its goals, consult meaningfully and ensure public ‘buy in’ of projects, the EAO should:









Establish a mechanism for addressing and resolving broader systemic concerns regarding the EA process by First Nations and the public.Recommendations for improving public participation in BC EAs

Environmental assessments should have early and ongoing processes, as well as adequate time and resources, to meaningfully engage the public. Limited participant funding, restricted opportunities, short timelines, poorly developed processes and narrow project scope impede public participation.











I would also like to point out the website dedicated to informing and asking the public's response isn't user friendly. I found it difficult to respond and navigate, which discourages engagement. I've noticed the lack of comments and no emails and can't help but feel that the ability to notify and engage with participants has not been successful. Which I feel goes to the level of disconnection the average citizen has when asked for their input. Simply put there is no substantial effort to really ensure that there will be many comments and therefore the process has been futile without the public being properly informed and ease of communicating.


Comments for BC’s Environmental Assessment Office on Public Participation

We support the following recommendations put forward by West Coast Environmental Law group. Environmental assessments should have early and ongoing processes, as well as adequate time and resources, to meaningfully engage the public. Limited participant funding, restricted opportunities, short timelines, poorly developed processes and narrow project scope impede public participation.


 Require the involvement of the public throughout all stages of the assessment;

 Ensure that formal public comment periods are long enough to allow the public to thoroughly analyse all relevant information and

 prepare detailed responses;


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

 Build flexibility into formal public comment processes to reflect the varying complexity of and public’s interest in different projects, and

 accommodate identification of data gaps and the reception of new information;



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





I fully and strenuously support all the recommendations of West Coast Environmental Law as communicated to you 24 Nov 2014 and posted here: http://wcel.org/sites/default/files/publications/2014%2011%2024%20EAO%20public%20participation_WCEL%20comments_0.pdf

Date Received: May 24

BC Environmental Assessment Process input

As chair of the BC Wildlife Federations Mining Land Use Committee I have been involved with BCs Environment al Assessment office since its inception. Back then

I was on their mailing list and received hard copies of all of the material that I asked for.

I still have most of the applications and reports in my files. Certainly most of the mine proposals. I was involved in the Ea process for South Kemess, Mt Polley,

Red Chris and many more. I am also one of the founders and chair for a number of years of the Environmental Mining Council of BC. I served on the Leadership council of the Whitehorse Mining Initiative. I am also a BC Park Elder with park involvement that goes back to 1962.

The question being asked is what is wrong with the Environment Assessment Process

And what could improve it.?

I believe that one of its greatest faults is that it is a flawed process.

It does not decide whether a proposed mine should be permitted, but rather what changes need to be made to allow the mine to be permitted.

I should point out that until fairly recently no mine once it entered the Environmental Assessment Process was denied its certificate. If a certificate was denied then the proponent could come back again and again with a new or changed proposal. Examples of this would be the proposed Windy Craggy mine on the

Tatshinshini that was only brought to a conclusion when the government bought the proposal to end the process.

The Proposed Taseko mine is a current example it this “Come again and again”.

A second fault is that once a mine proposal gets its certificate it can come back, sometimes immediately with changes it wants to make which are considered by the EA Office as adjustments to the certificate. The Assessment Process is not reopened to the public to consider the changes possible impacts. Two examples of this would be the South Kemess mine that decided once it got its certificate, that wanted its certificate agreed mill site changed ro a location albeit one that was rejected during the EA Process for Environmental reasons. An other would be the Bear Mountain Wind Farm proposal

That changed to above ground power lines and a different road location. These changes might have made sense but why was this not decided during the process rather than once they got their certificate. The public was not able to be involved in these changes.

An other change t hat needs to be made is the splitting of a proposed development for the process. The Environmental Assessment process needs to consider all the aspects of the proposal and its possible cumulative impacts. An example of this would be the South Kemess mine where the mine and the power line were considered separately. It was all one project one could not go ahead without the other. As it was, the power line was subject to a scathing report from the Forest Practices Board.

A big concern is the issue of cumulative impacts. As it was this was not considered in the BC Environmental Assessment Process although it was in the Federal

Process.With the melding of the two processes It is important that Cumulative impacts be included.

I was told that now the BC process does include cumulative impacts, but I have not found out when or where although I did ask the EAO.

Another issue is that once the Proposal gets its certificate the EA office steps out of the process and leaves certificate compliance and enforcement up to the line agencies.

The EA office has no enforcement capability although it seems the Auditor General felt they had of should have. (See attachment) With the staffing and budget cuts to the Ministry of Environment the do not have the funding or staff to address compliance or enforcement.

I would be willing to meet with you at any time to expand on my input.

What is right with the Environmental Assessment office is the staff that I have dealt with over the years. They are committed people who are open and forthright whenever I have met with them. I did meet with the board on one occasion and participated in a open discussion on the issues. I count some as friends still, years after their retirement.

Ed Mankelow Past President

BC Wildlife Federation

Past chair Environmental Mining Council of BC


To The BC Environmental Assessment Office (EAO):

As a resident of British Columbia I concur with and fully support the following ideas for improving public participation in environmental decisionmaking.

Environmental assessments should have early and ongoing processes, as well as adequate time and resources, to meaningfully engage the public. Things like limited participant funding, restricted opportunities, short timelines, poorly developed processes and narrow project scope impede public participation.











 Ensure that formal public comment periods are long enough to allow the public to thoroughly analyze all relevant information and prepare detailed responses;



 Require that all information and comments related to follow-up, monitoring, and compliance and enforcement be made publicly available;


Provide sufficient public funding to enable participants to analyze information and prepare comments at all stages of the assessment on

 issues of importance to them, including retaining experts and counsel where appropriate;


 Establish a mechanism for addressing and resolving broader systemic concerns regarding the EA process by First Nations and the public.

The following link provides a more detailed overview from the West Coast Environmental Law organization on how BC’s environmental assessment process can be improved to help provide the best long term protection for BC’s environment, something our citizen’s long term health and local economies rely on : http://wcel.org/sites/default/files/publications/2014%2011%2024%20EAO%20public%20participation_WCEL%20comments_0.pdf


Basic to improving citizen participation in environmental assessments is successfully communicating to the public that input is being received, and communicating this in plenty of time for citizens to inform themselves and formulate responses.


To Who It May Concern about EAO Public Participation Process…

I would like to see:

Public participation at all stages.

Ensurance that adequate notice is given maybe one month in advance and again one week in advance.

Ensure a reasonable amount of time allowed to receive responses.

All follow up or monitoring information should be made public.

Proponents should respond to public comments and this should be made public.

Provide committees and task forces to allow for in depth dialogue and proper dissemination of facts and create opportunities for feedback.

Ensure First Nations concerns are addressed and keep in mind any special process around this factor.

Thank you,


Hello,

I heard about the comments regarding the EAO process via Environmental Alliance website, otherwise I don't think I would have come across this. In the past I have attended the Northern Gateway Pipeline public consultation process, I have never done anything like it before, stating my concerns for the environment before a panel board. Although I thought it was a good start to have such a process, I did wonder if it would help at all. When the news came that the project was still going forward, it felt that many of our shared views and values were not heard. A consultation process to me means having the public "heard". Youth also need to be much more engaged in such matters because projects that

affect the environment affects them in the long term. Targeting young audiences is necessary, getting the word to them about the consultation process and how it can be of value.

The time allotted for the consultation process needs to be long enough so that people have time to comment and present their ideas and knowledge. I value having a democratic process that allows us to state our concerns, more of this needs to be considered, especially since there are now a greater number of corporations that wish to extract and take away from our land and water. The two most precious resources that are all of our livelihoods.

One other thing I would like to mention, with any such future public consultations might the the panel take in consideration the precautionary principle. This may not be conducive for all future consultations, yet it seems to be the case. We ought to be exercising precaution, and having such a process that allows us to give feedback and question the validity of LNG pipelines, oil pipelines, mining, etc is just that, taking a cautionary measure to have full valued input before moving forward.

I'm not sure if this comment will be of value, but I did want to put forward my interest and value of the consultation process for future environmental projects.

Thank you,


Dear Madam/s/Sir/s:

To better achieve its goals, consult meaningfully and ensure public ‘buy in’ of projects, the Environmental Assessment Office should:






 Ensure that formal public comment periods are long enough to allow the public to thoroughly analyse all relevant information and prepare detailed responses;


Build flexibility into formal public comment processes to reflect the varying complexity of and public’s interest in different projects, and

 accommodate identification of data gaps and the reception of new information;


 Require proponents to respond to all public comments and that those responses be made publicly available;

 Provide sufficient public funding to enable participants to analyse information and prepare comments at all stages of the assessment on issues of importance to them, including retaining experts and counsel where appropriate;

 Establish means of providing “dialogue participation methods,” such as advisory committees, task forces, and community or advisory

 boards to emphasize ongoing dialogue and communication among parties; and


Thank you,


Recommendations for improving public participation in

British Columbia Environmental Assessments

Submitted to the British Columbia Environmental Assessment

Office (EAO) Review of Public Participation

May 26, 2015

Public participation is a central element in any sound environmental assessment process, not only for the engagement of the public in discussions of acceptable project alternatives, designs, execution, and the mitigation of negative impacts and enhancement of positive impacts, but also for the opportunity to integrate local knowledge, community perspectives, and alternative information and analysis into the process, allowing for a much more robust and comprehensive interrogation of all aspects of a development proposal.

MiningWatch Canada sees environmental assessment (EA) as a crucial element in planning for sustainable and equitable development, and we have consistently pressed for credible, independent, comprehensive, and participatory EA processes at all levels of government and for all jurisdictions. The integrity and effectiveness of provincial EA regimes is now even more important with the federal government’s effective abdication of its EA responsibilities under the 2012 Canadian Environmental Assessment Act (CEAA 2012). The federal EA regime is now greatly reduced in both the scope of its application and the scope and depth of its assessments – especially the key aspect of public participation – as well as providing for the substitution of provincial EA processes for the federal one (as has now become routine in British Columbia), or even the acceptance of a provincial process as equivalent to the federal one.

MiningWatch has reviewed the relevant materials and our conclusions and recommendations are very effectively represented by the submission by West Coast Environmental Law (WCEL).

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As WCEL points out, in order to engage the public meaningfully, there must be early and ongoing processes, as well as adequate time and resources. Public participation can be impeded by limited participant funding, restricted opportunities, arbitrarily short timelines, poorly developed processes and narrow project scope.

MiningWatch specifically endorses WCEL’s key recommendations, that is, that the EAO should:

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In closing, we welcome the EAO’s interest in improving public participation in EA, and we urge you to pay close attention to ensuring that any changes do go in the direction of more effective public participation: better access to information, adequate time, and sufficient resources for the public and public interest intervenors. At the same time, we note that the present review does not address concerns that we and others have with any other aspect of B.C.’s EA process, including the scope of assessments, the assessment of alternatives, and the role of EA in ensuring Free, Prior, and Informed Consent for Indigenous peoples, and urge you to establish a process to address such concerns. As previously noted, this is even more important in the context of CEAA 2012 and the heightened expectations now placed on the provincial EA regime.

Thank you for the opportunity to comment as part of this important review.

West Coast Environmental Law. Recommendations for BC Environmental Assessment Office (EAO) Review of Public Participation. Nov. 24, 2014. http://wcel.org/sites/default/files/publications/2014%2011%2024%20EAO%20public%20participation_WCEL%20comments_0.pdf


To whom it may concern:

Thank you for providing the opportunity to make comments for the proposed changes to the public’s participation in BC’s environmental assessments.

Recently, British Columbia Women’s Institute (BCWI) participated in an environmental assessment. It is of utmost importance that the public be provided an opportunity to comment and be allowed adequate time and resources for meaningfully engagement.

From our experience there was not enough time provided to allow thorough analysis of all relevant information in order to present detailed response. The business presenting the project has years to prepare its documents and the public is only provided a few weeks to review and comment. Public consultation should be required throughout all stages of the assessment.

We do live in a democracy and items of importance to specific areas of the province should be allowed public opinion as in most cases it will only have adverse effect on those living in the immediate area. The impact on the environment or even the taxpayer or ratepayer’s pocket book could be far more reaching than where the project is to be located.

According to your website “ Provincial legislation sets out which types and sizes of proposed projects require an environmental assessment certificate before they can be built and operated.” In some cases public comments should be required prior to environmental assessment certificates being issued regardless of size or type. Again the government dictates what is important; people living in an area may have an entirely different opinion especially in sparsely populated areas.

BCWI encourages the Environmental Assessment to establish a better mechanism to keep the public engaged in the consultation process.

Sincerely For Home & Country


Dear Environmental Assessment Office reviewers:

Re: Improving public participation in environmental assessment

On behalf of the Islands Trust Council, I am writing to provide input to BC Environmental Assessment Office’s (EAO) consultation on ways to improve the participation of the public in environmental assessment. I understand that the EAO’s intention when seeking public input is to ensure that all potential environmental, social, heritage and health effects that might result from the proposed Project are identified for consideration as part of the assessment process.

In recent years, Islands Trust trustees and staff have engaged in environmental assessment processes relating to the proposed Raven Coal Mine

Project, the proposed BURNCO Aggregate Mine Project and the proposed Woodfibre LNG Project. Drawing on their experiences, I’ve heard the following suggestions for improvement:

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Public comment periods should always be a minimum of 60 days, and these dates should be well-advertised at least 10 days in advance of the public comment period start date in traditional and non-traditional (e.g social media) ways.

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The EAO website should be improved so that it is easy to do keyword searches on public comments on applications. This would allow members of the public to see not only what the proponent has to say but also what others have to say in order that they might be properly informed on the spectrum of opinion and ideas.

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The EAO should support town hall style meetings to support democratic dialogue and to allow for question and answer periods to be heard by all participants, rather than just the “open house” format. I’ve heard that the current open house format results in the proponent’s representatives surrounding and overwhelming individual members of the public. Town hall style meetings would allow citizens to hear each other’s perspectives.

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Public information sessions/town hall meetings should be hosted as early as practical in the process and should be hosted in affected communities selected by the EAO. In the case of projects that involve marine shipping, affected coastal communities should have the same opportunities to learn and comment as communities close to the proposed facilities.

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There should be more training available to local government staff and elected officials to help them participate effectively in EAO working groups. Training could include examples of how other local governments have structured and funded their participation.

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Working group meeting minutes should be taken by EAO staff and posted promptly to the website.

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The EAO should formally advise local governments of new environmental assessment processes in their regions through correspondence or notices that can be placed on public meeting agendas. There should also be notices to advise of each public consultation opportunity as well as opportunities to participate on EAO working groups.

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The EAO should consider the principles and best practices within the Auditor General of British Columbia’s 2008 report Public

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Participation: Principles and Best Practices for British Columbia as it reviews its public consultation and engagement methods.

To address community concerns that members of the public do not have the same ability as the proponent to provide expert reports,

the EAO should: o hire the expert consultants and charge the proponent for the consulting costs, and/or o provide funding to public interest intervenors to hire qualified experts to interpret and verify the proponent’s information and ensure that there is a formal avenue for submission of public evidence.

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The EAO should ensure that projects within or adjacent to the Islands Trust Area boundary specifically acknowledge the Islands Trust’s provincial mandate to preserve and protect the region.

The Islands Trust Policy Statement is a statutory document founded in extensive community consultation and approved in 1994 by the then

Minister of Municipal Affairs. In the Islands Trust Policy Statement the Islands Trust Council holds that public participation should be part of the decision-making processes of all levels of government, and that economic opportunities should be compatible with the conservation of resources and protection of community character.

The Islands Trust Council is a federation of local government bodies representing 25,000 people living within the Islands Trust Area and about

10,000 non-resident property owners. The Islands Trust is responsible for preserving and protecting the unique environment and amenities of the Islands Trust Area through planning and regulating land use, development management, education, cooperation with other agencies, and land conservation. The area covers the islands and waters between the British Columbia mainland and southern Vancouver Island. It includes 13 major and more than 450 smaller islands covering 5200 square kilometres.

Thank you for your consideration.


To Whom it May Concern:

I have been participating in the EA process for the Raven Underground

Coal Mine Project since 2009. The proponent’s resubmitted application for the project has recently been withdrawn. I must admit to being quite exhausted by this 6-year odyssey. In 2013, along with colleagues, I wrote a critique of the EA process. I would like to resubmit this document for your consideration as part of the engagement process.

I appreciate your attention to my comments.

WHAT IS WRONG WITH THE RAVEN UNDERGROUND COAL MINE ENVIRONMENTAL ASSESSMENT PROCESS

May 5, 2013

What is an environmental assessment?

Present environmental review assessments (EAs) are, as they should be, largely political exercises because so many of the questions raised by resource development projects involve values, goals and visions. Science contributes to the process by collecting physical and biological data and predicting potential effects. Predictions, however, involve uncertainty.

Questions about acceptable levels of risks and uncertainties about negative effects are not resolved by science. Project benefits, risks and costs may not all flow to the same people, and decisions about who benefits, who pays costs and who takes risks are not scientific matters. It is important that accountable representatives of the public make these sometimes difficult decisions, and that they are made in the broad public interest. Fairness to all interests requires that such decisions be based on stated criteria and be made publicly.

The promise:

That a joint Provincial and Federal environmental review would administer neutral, transparent assessment processes that consider the views of local, provincial and federal government agencies, First Nations and the public.

The critique:

The Ravel Underground Coal Mine review has been conducted by the

Canadian Environmental Assessment Agency and the B.C. Environmental

Assessment Office. The process is not balanced. Rather, it favors the proponent over the public, is often discretionary in nature, limits the scope of science produced and ultimately, does not serve environmental or public interests. The experience with this review has been that: a) The review process is biased in favor of the proponent. Interests of the general public, First Nations, local residents and the environment are not adequately represented. b) Criteria for decision-making are not clear. Decision-makers are not accountable to the public. c) Agency decisions have unduly limited the scope of the science produced by this environmental assessment.

d) The public consultation process has provided some opportunity for public input; however government agencies and the proponent have not acted to resolve stated concerns and there has been no opportunity for substantive public debate. e) Government agency consultation with their advisory Government

Working Group has been limited.

THE CRITIQUE IN DETAIL

1. The review process is biased in favor of the proponent. Interests of the general public, First Nations, local residents and the environment are not adequately represented.

• The goal of the Raven Mine assessment has not been to determine whether the proposal serves the public interest. Rather it has been designed to identify potential impacts and develop technical strategies to mitigate them so that the project can proceed.

• Intangibles like quality of life and hard-to-quantify values like sustainability and local self-sufficiency are not well integrated into the review.

• The Raven Mine review relies primarily on information from Compliance

Energy and government agency employees. The formal process involves little analysis by independent experts.

• There is a relatively small amount of public money available for local governments, First Nations, citizen groups, environmental groups, and other industries to participate in the process. Compliance has spent more than

$10 million on the review; governments provided about $430,000 for First

Nations and $84,000 for others to support their participation.

• There is no mechanism in the process to determine if a project has earned

“social license”. Among the 1500 people who attended public consultations only a handful supported the project, and among 2,865 written submissions, over 95% opposed the project or had serious concerns about it. To date in the process, responses by the review agencies have been dismissive.

2. Criteria for decision making are not clear. Decision-makers are not accountable to the public

• Decision makers denied requests by all Comox Valley local governments,

Coal Watch, the Environmental Law Centre (University of Victoria), the B.C.

Shellfish Growers Association and many other organizations to refer this project to a public hearings by a federal-provincial review panel. The provincial Minister of Environment can make this decision at his/her discretion. The federal Minister can do so when the project may cause

“significant adverse effects”, or “when public concerns warrant”. The denial did not provide any criteria for how this decision was made.

• This project was referred to a “comprehensive” joint federal provincial review. Decision-makers at all points in the resulting process are federal and provincial project managers, agency heads, and Cabinet Ministers.

They appear to have complete discretion about criteria like “significance”,

“tolerable risk” and ‘uncertainty’, as well as the scope of impact assessment.

In this case they made unexplained decisions contrary to strong public recommendations about: o whether the environmental and public concerns warranted an public review panel o public consultation venues, public meeting process, adjudication of conflicts and responses to public input o scope and detail of the proponents application: study areas, methodology, and elements of baseline data.

• Agency staff produce a final report, which is reviewed by the agency director who produces a second report to the Minister, who makes the final decision in consultation with Cabinet.

3. Government agency decisions have limited the scope of the science produced by this EA

• Agencies decided on narrow terms of reference for this proposal: o the definition of the affected area around the mine that would be studied for possible effects is very restricted o terms of reference excluded assessments of the project’s contribution to global CO2 emissions produced by transport to and burning the coal at destination o ecological studies in Baynes Sound are restricted to the immediate vicinity of the proposed mine and deal with a small number of parameters

and only a few species. There is no assessment of the health, structure and function of the larger Baynes Sound ecosystem. o There is insufficient consideration of cumulative effects of this project combined with others, including historic mine pollution, residential development and Compliance Energy’s plans for further coal mine development in the area.

4. The public consultation process has provided some opportunity for public input; however the government and the proponent have not acted to resolve stated concerns, and there has been no opportunity for public debate

• Public meetings were poorly implemented. Two minute limits on questions and responses made substantive exchange impossible, comments at meetings were not accurately transcribed and the lack of a meeting on

Denman Island excluded may affected citizens.

• 2,865 people sent comments about the terms of reference for the proponent’s full application. The proponent was required to keep a Tracking

Table intended to record its responses to commentators. In most cases individual’s names were not listed in the Tracking Table along with their comments; this made it difficult for commenters to locate the proponent’s response to their submissions. Many of the proponent’s responses were superficial and defensive rather than acknowledging or responsive.

• Compliance Energy’s full application is 12,000 pages long. The public has

50 days to review it and comment in writing. Very few members of the public will have the capacity to manage this.

• Public meetings during the public review of the full proposal will be open house information sessions only, providing no public forum for discussion of concerns.

5. Government agency consultation with their advisory Government Working

Group has been limited.

The public is reliant on a Working Group chosen by government agencies in this process. It is composed of government agency experts, VIHA, First Nations

and local government representatives who are expected to represent various public interests. The reality has been that Working Group members may comment on material generated in the process but do not have real influence or authority to affect decisions.

• Meetings of the full Working Group are infrequent, and much of the work takes place in smaller sub-groupings or in one-on-one meetings with the proponent. There has been little opportunity for Working Group members to hear and discuss each other’s concerns and comments.

• The Working Group has not been asked to analyse the content of the full

12,000 page application prior to the public comment period. They were tasked only with assessing whether the proponent had discussed all the required subjects.

• Working Group members have expressed concerns about lack of sufficient time and resources to properly address the documents under their review.

Some have found that they cannot oblige the proponent to respond satisfactorily to critical comments.

• The Working Group may not include expertise in all fields of assessment.

• The proponent may discuss issues with Working Group members, and may call on members’ expertise, but the public does not have the same access.

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