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A How-To Guide to Write Effective Public Comments

There are different kinds of comments.

You can write to your state and federal representatives in support or favor of laws: these comments don’t need to get into the nitty gritty to have an impact. Overwhelming numbers in opposition to a project can sway a rep.

You can write to permitting agencies who give the go-ahead on development projects, like docks, hatcheries, mines, pipelines, etc. These guidelines focus on these kinds of comments. Effective comments at this level generally involve some research:

What kind of permit is being considered?

What are the laws governing this permit?

What is the nitty gritty of the proposed project and what will its impacts be?

Who reads comments?

  • Permitting agencies
  • CC your representatives
  • Send them to newspapers
  • Post on Facebook
  • Can use them to give testimony at public hearing.

Why do comments matter?

  • Permitting agencies are required to respond to substantive comments.
  • Comments can change permits.
  • Agencies are afraid of lawsuits.
  • Be able to talk with friends, strangers and politicians about the issues you care about.

Kinds of Permits:

Typical Sate Permits:

  • Department of Natural Resources (DNR) issues these permits: Plan of Operations, Reclamation and Bonding, Monitoring Plan (Surface/Groundwater/Wildlife), Tidelands Leases
  • Department of Environmental Conservation (DEC) issues these:  Waste Management Permits and Bonding, Contingency Plans
  • Alaska Department of Fish and Game (ADF&G) issues Fish Habitat and Fishway Permits
  • Typical Federal Permits:
  • US EPA Section 402 National Pollution Discharge and Elimination System Permit (NPDES)
  • US ACOE Section 404 Dredge and Fill Permit
  • NMFS Marine Mammal Protection Act
  • USFWS Migratory Bird Protection
  • National Environmental Policy Act (NEPA) requires Environmental Impact Statements (EIS) for federal action determined to significantly affect the quality of the human environment. It’s got two steps where you can comment:
  1. Scoping
  2. Draft EIS

For large projects, there are often a number of agencies and permits. There will be a coordinating agency, eg. for large-scale mining in Alaska, DNR is the lead state agency. For the Feds it is often the Army Corps.

Getting Started:

Stay in the loop:

Join whatsup@npgroups.org weekly updates from Trustees for Alaska, The Alaska Center and Alaska Women’s Environmental Network.

Join KBCS’s list to receive copies of our comments before the deadline. Our comments may help you write your own.  Email Penelope at pah02003@mymail.pomona.edu if you want to be on that email list.

Read the draft permit or proposal closely:

  • What exactly are they proposing?
  • What laws must the permitters follow: they should be cited in the text of the draft permit.  Also, they will be on the agency’s webpage.
  • Look at attachments: maps, tables.
  • How big is it: like a football field, like ten football fields?
  • Get a picture in your mind: 4,500 gal per minute =
  • Ask basic questions: Where will the water go? What exactly is in the water? How much is in there? How do we know? How does it affect living organisms?
  • Get a species list for the area.
  • How long will the permit last?  
  • Any special protections in region?
  • What are they not talking about?

Find out more:

  • Look up the laws cited. Just copy and paste the citation into google and you will get the full text. Structure your comments around these laws. They are what the agency cares about.
  • Call the agency contact person listed on the public notice and ask them your questions.
  • Research what has happened in similar kinds of developments.
  • Please only use .org, .edu, .gov and cited sources.
  • Search for the issue you’re commenting on in the news. Call the journalist who wrote the article.
  • Read other comments:
  • Cook Inlet Regional Citizen’s Advisory Council (esp. for stuff on oil and gas in Inlet)
  • http://pebblewatch.com/resources/permitting/
  • SalmonState (for Pebble questions)
  • EarthJustice (for large-scale issues)
  • Northern Alaska Environmental Center (for northern Alaska issues)
  • Trustees for Alaska
  • Cook Inletkeeper
  • The Alaska Center

Analysis:

  • Persuade your reader.
  • What is at stake?
  • Keep to the facts.
  • Quote and cite laws:
  • Lists, numbers, diagrams, research results, examples, are all good.
  • If you have a lot of points, number them.
  • Topic sentences.
  • Always address any special protections to land or animals.
  • Tell ‘em what you’re gonna tell ‘em. Tell ‘em. Tell ‘em what you told ‘em.

Start like this:

Angela Hunt

Alaska Department of Environmental Conservation

Division of Water

Wastewater Discharge Authorization Program

555 Cordova Street

Anchorage, AK 99501

Regarding: Aquaculture Facilities in Alaska General Permit, Permit No. AKG130000

Dear Ms. Hunt:

Go!