One consistent feature of participation requirements is 
their lack of specificity. Implementation of participatory 
measures raises the problem of who will be involved, yet few 
participation requirements have comfortably dealt with this 
question. In this context, representation may be biased towards 
small, but well-organized groups with few claims to represent 
the "public". Without more specificity, administrative discre- 
tion prevails. It is the agencies that select members of ad- 
visory committees; the people who may speak at open committee 
or staff meetings; the individuals to contact when legislation 
calls for notification of the "people directly affected" by an 
action; and the individuals who have administrative standing to 
initiate grievance procedures. Lack of specificity allows manipu- 
lation; if agencies do not specify procedures, efforts to in- 
crease public involvement can become undermined by an uncertain, 
discretionary, and arbitrary environment. 
The timing of public involvement further limits potential 
public influence. Most opportunities for participation are 
offered late in the decision-making process; usually citizens 
can only react to proposals already developed and accepted by 
agency staffs. Because public involvement occurs so late in 
the process, the burden falls on public intervenors to prove 
there are problems with a project (even though it is the appli- 
cant who formally bears the "burden of proof") . If the public 
enters the decision-making process after significant choices 
are already made, it can only accept or veto. Consequently, 
the public becomes a "nay sayer" , perpetuating prejudice on 
both sides: government is the "enemy"; the public only plays 
a negative role. 
Finally, the problem of cost limits effective participa- 
tory procedures. Participatory measures such as intervention 
have considerable potential for influencing decisions, but to 
effect a decision, an intervenor must be able to present a 
[A-117] 
