Making Effective Comments Verena Owen Where the

Making Effective Comments Verena Owen

Where the rubber meets the road This is an important step so leave plenty of time to make comments n For EACH issue that you identify you should discuss n Describe the issue l Identify the rule l Explain how the rule applies l Suggest a permit modification l

Tips on how to write an effective comment letter Be specific!!!! n Discuss any potential problems with the draft permit n Cite statutes, regulations, and guidance (Remember: the recipient of n your comment letter speaks governmentese) n Attach supporting documentation

Tips on how to write an effective comment letter Consider requesting a meeting with the permitting authority to resolve the issues or requesting a public meeting/hearing n Copy the Regional Office n

Ineffective Comments Zoning n Nuisance issues n Not a federal issue l May be an indicator of another problem l

Where to send your comments Permitting Authority n You may copy U. S. EPA on your comments but the permitting authority is required to respond to your comments n

Develop relationships with government personnel Enforcement Officers, Permit Writers, Community Liaisons l Helpful source of information l Good working relationships often have fruitful results l

Examples The Big Company has been a thorn in my side as long as I can remember. This permit allows them to dump grime on my house. You must require Big to come and clean up our house every Friday.

Examples I believe that the facility should be regulated differently.

Examples The applicable regulation for this facility is 40. CFR 60. 290(a) because it produces more than 4, 550 kg of glass per day and is therefore not exempt under 60. 290(c).

Examples The permitting agency did not consider the information submitted about the company’s compliance history nor address the failure of the company to sign the compliance certification.

Examples Shouldn’t you have looked at the frequency of monitoring?

1) The permit does not assure compliance with all applicable requirements because individual permit conditions lack adequate monitoring. One prominent change between the draft and final permit is the deletion of continuous opacity monitors. Now this permit does not require sufficient periodic monitoring to assure compliance with the opacity standard. I have been unable to locate the method or the frequency of opacity measurement in the permit.