Lessons from a plain language analysis: U.S. Clean Air Act Title V public notices as barriers to environmental justice

Abstract

The Clean Air Act’s Title V program offers opportunities for the public to participate in permit-related decision-making in a handful of ways, but this process rarely leads to substantive changes that prioritize environmental justice (EJ) in overburdened communities. Efforts to increase the use of plain language may be one strategy for improving public participation—as a tool for improving access to the process but also to increase transparency and accountability. We conducted a content review and thematic analysis of Title V public notices across 20 states representing all 10 EPA regions. Our analysis considered the following variables: accessibility and navigability; audience and purpose; overall design and organization; and language and word choice. We also coded for themes related to the actionability of public participation processes and ways documents addressed environmental health and justice. We learned that public notices were often written poorly and, on average, for readers with a college reading level. Little to no attention was given to writing strategies that could improve understanding, such as minimizing jargon, utilizing basic information design principles, and communicating clear processes and timelines. References to specific pollutants were largely lacking, with no acknowledgement of public health and cumulative impacts. With these lessons, we provide specific suggestions to improve public notices. Plain language is needed to bring public participation processes into alignment with increased agency efforts to work in earnest towards EJ. Although political, legal, and organizational barriers may persist, U.S. environmental agencies at all levels must begin working towards becoming environmental health literate organizations.