5 
An important and unresolved issue in recent discussion 
about participation is the question of standing: who should 
be included to represent the public? Efforts to answer this 
question show up in debates about the "public intervenor". 
The right of citizen representatives to intervene as "full 
parties" in adjudicative hearings has been clarified and ex- 
tended by recent legislation. The actual ability to inter- 
vene, however, is significantly restricted by the agencies; 
they determine who may participate and what issues may be con- 
tested. ^ Moreover, agencies frequently use the willingness of 
a group to bear the costs of intervention as one measure of 
commitment. Yet intervenors often lack the necessary resources 
to present a convincing argument. Businesses consider inter- 
vention in regulatory procedures to be a necessary investment 
and they can take tax deductions, or add residual costs to the 
price of their products.^ The concerned citizen, however, quick- 
ly discovers the high cost of acting on his beliefs; for the 
purchase of scientific expertise compounds routine costs of 
time and travel. 
Several groups have considered the idea of financing inter- 
vention. ^ But controversy surrounding these proposals (e.g. 
Senator Kennedy's 1976 prosed Public Participation in Government 
Act) suggests the general ambivalence about expanded public 
influence. Supporters feel that greater participation would 
make agencies more accountable to the public and would also 
educate citizens about the process of decision-making. Oppo- 
nents warn of the high costs of intervention and note the dif- 
ficulties of distinguishing between deserving and undeserving 
groups. Funding citizen intervenors, it is feared, would open 
agency doors to narrowly based interests, and to a flock of con- 
flicting demands. True, it might produce greater information, 
but it also might create the administrative nightmare of publicly- 
financed opponents blocking federally supported projects. 
[A-114] 
