Community Access to Clean Air Decisionmaking
Summary
The report finds that while most US states meet the minimum legal requirements for Title V air permitting notices, there are substantial gaps in transparency, accessibility, and the actual influence of public input on final decisions. It highlights that many public notices are written at a college reading level and lack plain language, and that few agencies transparently report how public comments shape permit outcomes. The analysis suggests that states with specific environmental justice or cumulative impacts laws tend to have better engagement practices. It recommends that agencies adopt plain language, provide multilingual resources, and establish clear mechanisms for reporting how community input affects regulatory decisions.
Key insights
- Most state agencies meet basic legal requirements for providing information on draft Title V permits, but the information is often fragmented across websites. While at least half of the 50 states use mapping tools to show active Title V facilities, public hearings are infrequent and usually must be requested by the public.
- A review of 87 public notices across 35 states revealed poor readability and a lack of plain language. Only one notice received an 'A' score from the Readable tool (Ohio), while 11 scored 'D' or 'E' (Connecticut, Missouri, New Hampshire, New Jersey, and Texas). Only Michigan and Minnesota integrated three or more plain language elements.
- There is a significant lack of transparency regarding how public input influences final permit decisions. Of 28 responding agencies, 18 post responses to comments online, but only 13 could provide an example where public input led to a change in a final permit.
- States with specific laws regarding cumulative impacts or environmental justice generally exhibit higher levels of public engagement. At least 11 states have laws enhancing participation in air permitting, and 16 states have internal agency guidance for meaningful engagement.
- State agencies generally possess limited internal capacity for public engagement. Among 28 responding agencies, only 16 have at least one full-time employee dedicated to enhancing public participation, and only three provide financial assistance or grants to help community organizations participate in permitting.
- Federal policy shifts under the Trump administration have hindered public participation, including the removal of the EPA's EJSCREEN tool from public use in 2025 and 2026 guidance urging states to prioritize rapid permit approval over the consideration of public comments.
Cite the original document
- APA
- Minovi, D. (2026). Community Access to Clean Air Decisionmaking. Union of Concerned Scientists. https://www.ucs.org/sites/default/files/2026-10/Community-Access-to-Clean-Air-Decisionmaking.pdf
- Chicago
- Minovi, Darya. Community Access to Clean Air Decisionmaking. Union of Concerned Scientists, 2026. https://www.ucs.org/sites/default/files/2026-10/Community-Access-to-Clean-Air-Decisionmaking.pdf.
- Wikipedia
- {{cite report |last1=Minovi |first1=Darya |title=Community Access to Clean Air Decisionmaking |publisher=Union of Concerned Scientists |date=October 2026 |url=https://www.ucs.org/sites/default/files/2026-10/Community-Access-to-Clean-Air-Decisionmaking.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @techreport{minovi2026community, author = {Minovi, Darya}, title = {{Community Access to Clean Air Decisionmaking}}, institution = {Union of Concerned Scientists}, year = {2026}, month = oct, url = {https://www.ucs.org/sites/default/files/2026-10/Community-Access-to-Clean-Air-Decisionmaking.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
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