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Effective Public Comment

How to make your voice heard in the environmental review process

Audience at the Mercer Island public meetingphoto by Washington State Dept of Transportation, on FlickrNearly 800 people attended a scoping meeting in Washington state regarding a proposal to implement a tolling system on I-90.

As a concerned citizen, it can be difficult to navigate the environmental review process. If you’ve ever submitted a comment on a project, you may have been left wondering what happened to the comment, or wishing you could have made your point more effectively. Here’s an overview of the public comment process, and a few tips on how to maximize your impact on government decision-making. 

The Public Comment Process

First, here’s a little background on the public comment process. As governmental transparency has become more and more of a hot button issue, opportunities for public comment on agency decision-making processes have become more prevalent and more accessible to the average person. Take the National Environmental Policy Act (NEPA), for example.

NEPA was signed into law back in 1970. The Environmental Protection Agency describes NEPA as the established national policy goals for the protection, maintenance, and enhancement of the environment, and provides a process for implementing these goals within federal agencies.

As large, federally-linked development projects, such as pipelines or wind farm projects, go through the permitting process, NEPA provides the public with the opportunity to review and comment on the project, as well as on the environmental impact statements (EISs) associated with the project. The public plays a vital role in the NEPA process, pointing to issues of particular concern on the front end of the process (called scoping), and also in reviewing the findings of draft EISs. The public is often given the opportunity to attend informational meetings about projects locally, and is provided with access to decision-making documents (often online).

Lead government agencies must take into consideration all comments received from the public, as well as from other parties (such as cooperating agencies), during a comment period. Agencies respond to comments received on draft EISs in the revised version of the document.

Your comments can have a real impact on project design and mitigation of environmental impacts. Here are some tips to keep in mind to help make your comments even more impactful.

Tips for Effective Comment
by Rachel Tamigniaux Gupta – September 25, 2014

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On Shaky Ground

Longwall coal mining is sinking farmland in Illinois

South-central Illinois boasts some of the richest farmland in the world. It’s a land of corn and soybeans – a land as flat as a pool table that stretches until it meets the horizon far in the distance.

Lately, something strange has been happening to this land. You’re driving along, and suddenly you see an entire field that has sunk six feet below the surrounding fields. And you see that during the frequent spells of rain, pools of water have gathered in the field. Some areas are completely submerged.

photo of crops in a flat farmland, looming dark band of hill in the backgroundphoto by Christopher JohnsonThe people in Hillsboro are never far from the coal slurry impoundment at the Deer Run Mill.

There’s a force behind everything, and the force behind this sinking land is a coal-mining technique called “longwall mining.” Approximately 500 feet below the surface, coal miners dig tunnels along long panels of coal, which are between 1,200 feet and 1,400 feet wide and nearly three miles long. Then the workers lower giant machines that cut the coal along the panels and deposit the black nuggets on conveyor belts that carry the coal to the mine entrance, where it’s transported to the surface.

Hydraulic roof supports, known as shields, hold up the roof of the mine as the machines attack the coal. After the coal is extracted, workers remove the shields, and nothing remains to support the soil above. Within days everything sinks by six to seven feet. It’s an effect known in coal industry parlance as “planned subsidence.” Longwall mining is more efficient than traditional room-and-pillar mining, in which miners remove the coal from around columns of wood and coal that support the ceiling of the mine. In longwall mining, the company takes out more than 90 percent of the coal, as opposed to 50 to 60 percent in room-and-pillar mining.

Those efficiencies, however, are extremely damaging. Longwall mining is causing extensive environmental harm to farming communities in the central and southern parts of the Prairie State. It’s also perpetuating America’s dependence on coal, which emits far more carbon dioxide than any other source of energy.

Longwall mining has already affected communities throughout central and southern Illinois, but the tremors are being felt especially strongly in Hillsboro, a town of 6,100 people that’s about an …more

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Is There Really Such a Thing as “Ethical Oil”?

A trip to a tar sands conference and trade show offers a glimpse into the oil industry’s Id

It’s late afternoon on the third and final day of the “Peace Oil Sands Conference and Trade Show” held last May at the Belle Petroleum Centre in downtown Peace River, Alberta, and author and television host Ezra Levant is giving his keynote address titled Ethical Oil to a room of approximately 100 executives from Canada’s oil and gas industry. Levant is fired up as he declares: “If someone ever in their life tells you that your oil is immoral, that you’re a climate criminal … stop them right there and say: ‘Oh no, I’m not an oil man. No sir, no ma’am. I’m an ethical oil man.”

Fort McMurray, AlbertaPhoto by kris KrügFort McMurray, Alberta. “Good neighborly” activity by oil companies in this region — venting emissions from highly concentrated bitumen tanks into the air — is making some local residents sick.

With those words, Levant drills to the essence of his role in Peace River. He’s there to give moral and ideological cover to the companies that are busy digging up the oil desposits along the Athabasca River, deposits that have been shown to be more carbon intensive than more conventional sources of oil. Levant’s speech is, basically, damage control, and it’s a well-practiced schpeel. Levant is host of “The Source” a daily TV program on the Sun News Network (the Fox News of Canada), a platform he frequently uses to offer justifications for the Canadian petro-state.

“If you believe in making the world a better place, if you believe in the environmental credo of ‘thinking globally, act locally,’ then you must come to the conclusion I have,” Levant said during an October 2011 episode titled Ethical Oil versus Conflict Oil, based on his national bestselling book Ethical Oil: The Case for Canada’s Oil Sands, which won the National Business Book Award earlier that year. “[My conclusion is that] we must in fact follow our morality and produce as much oil sands oil as possible, knowing that every extra barrel we produce and sell to our American friends, or even if we export it to Asia, is one less barrel that will be sold by a Saudi Prince, an Iranian terrorist-supporter, a Nigerian kleptocrat, Hugo Chávez in Venezuela. Every barrel of oil that we sell is one barrel less that the bad guys sell.”

On its face, …more

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Why South Asian Americans Are Speaking Out About Climate Change

When islands disappear in Bangladesh or crops fail in India, we're not looking at abstract numbers, but at people who may be part of our extended families

On Sunday, I was at the People's Climate March in New York City, learning, sharing, and marching with three generations of South Asian American activists to the beat of dhols (drums). It was an emotionally charged day. I have been working as an organizer within the South Asian community and as a landscape architect for over a decade, but it wasn’t until a couple of years ago that I fully understood how these two identities came together. South Asian Americans embody the dilemma of climate change. Our home countries of India, Pakistan, Bangladesh, Nepal, Sri Lanka and the Maldives are among the most climate-impacted in the world, but we live our lives in a nation that's the single biggest historical emitter of greenhouse gases.

South Asians contingent at the People’s Climate MarchPhoto courtesy Brown and Green: South Asians for Climate Justice South Asian Americans — whose home countries are among the most climate-impacted in the world, yet who live in a nation that’s the single biggest historical emitter greenhouse gases — embody one of the dilemma’s of climate change.

When the People's Climate March was announced, my group, San Francisco Bay Area-based Brown and Green: South Asians for Climate Justice knew we needed to be there to help amplify voices from the global frontlines and to add our voices and perspectives to the climate justice movement.

Some of us may be America's doctors and engineers, cab drivers and motel owners, but we are defined by more than our professions. According to a 2012 survey, 67 percent of Indian Americans consider themselves environmentalists, and 69 percent would prioritize the environment over the economy. Our values are far greener than many other sections of the American population.

Most of us are also recent immigrants, tracing our roots in the US to after 1965 (when the legacy of racist anti-Asian immigration laws ended in the wake of the Civil Rights movement). That means when there's climate-linked flooding in Kashmir, sea level rise in Bangladesh, crop failures in India, or glacial lake outburst floods in the Himalayas, we're not looking at abstract climate-impacted communities, but at people who look like us, who might be part of our extended families, with whom we share language, religion, or other cultural touchstones.

We make up 1 percent of America, and if activated, we have an …more

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People’s Climate March: Morning After Musings

Corporate apologists are going to be most threatened by the moral message that religious and social justice groups brought to the airwaves.

Sometimes, one has to break from journalistic detachment to emotionally process a historic event. On Sunday, about 400,000 people showed up to the People's Climate March in New York City, more than quadruple the number predicted by march organizers. 

Last night, as I sat on the train back from New York to Washington D.C., I felt a number of emotions when I processed the events of the day. Although I met famous personalities Senator Bernie Sanders and Bill McKibben my mind dwelled on the folks I met who are still suffering after Superstorm Sandy, and those who have been fighting oil pipelines in their own backyard, and those have been arrested in nonviolent direct actions in the past few years. I met one person who was fighting a natural gas export facility that I had shilled for as a corporate pollster almost a decade ago.

Ark Makes Way Through Flood of PeoplePhoto by Light Brigading An Ark float makes its way through a flood of people at the People’s Climate March in NYC yesterday. Unlike casting doubt to undermine sound science, it’s much trickier to counter a well-crafted message based on morality, love, and justice.

The People's Climate March is probably my most significant political experience. I think it has the potential to be more significant than Earth Day, which kicked off the environmental movement nearly half a century ago. (Read my previous on-the-ground report from the march here)

As I rode the train home, I felt optimistic. Maybe it is something about trains. For me, they remind me of my time when I lived in Germany where sustainability was an unquestioned value of those of all political stripes, where everyone composted and recycled, and where some days more than 50 percent of energy comes from solar power. The turnout at People's Climate March gives me a genuine hope that we as a society could be on the verge of a paradigm shift. The march brought together 1,574 “partner organizations,” from labor unions to faith groups to various social justice communities. The crowd looked like America in a true demographic sense: it was racially, religiously, and socioeconomically diverse.

But as the train trip progressed I looked out upon rustbelt landscapes and saw what looked like a coal-fired power plant. I remembered that …more

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Nearly 400,000 Marchers Sound the ‘Climate Alarm’ in New York City

Largest climate protest in history draws comparisons to the first Earth Day action in Manhattan 44 years ago

New York City: A massive river of humanity poured through the canyon of concrete called Manhattan this morning as the People’s Climate March kicked off. Advertised as the largest climate march in history, it was predicted that as many as 100,000 people would participate in the event. The actual turnout was four times as much.

Crowd shot of the People's Climate March in NYCPhoto by Annette BernhardtFrom those effected by Superstorm Sandy, to interfaith groups, to scientists and students and ethnic coalitions — every conceivable interest and identity group found its place behind various props, banners, and works of art at the People's Climate March in NYC today.

When I spoke with Senator Bernie Sanders earlier in morning, at a point when anyone would have been thrilled with 100,000 marchers, he was grinning ear to ear: "Success has been achieved. This is already a huge march. Best of all, many young people. We are going to send a loud message to Koch Brothers and their billionaire backers," he said.

Today’s event was the result of months of organizing and the participation of over 1,574 “partner organizations”  — from labor unions to faith groups to various social justice communities  — each of which turned out their members en masse. About 550 buses brought 25,000 people from all over the country. Many others took trains in, and then of course, there were the locals.

We marched today to send a very loud and clear message that citizens across the world are demanding action from their governments on climate change. Two days ahead of a United Nations Climate Summit in the city, marchers (including no less than the UN Secretary-General Ban Ki-moon) hope to reinvigorate the climate movement and add momentum to the climate talks in Paris next December, where a binding global treaty on climate is supposed to be concluded. A similar effort failed in 2009 in Copenhagen. The stakes are high.

Earlier in morning, marchers assembled along 27 blocks on Central Park West, from 59th Street to 86th Street. The assembly zone felt like an ecosystem with countless niches. From those effected by Superstorm Sandy, to interfaith groups, to scientists and students and ethnic coalitions, every conceivable interest and identity group found its place behind various props, banners, and works of art.

At the …more

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“Love Will Save This Place.”

Why we still need wilderness in the era of climate change

This article originally appeared at The Nation.com.

Trust the academics, God bless ’em, to confirm the obvious.

This summer the journal BioScience reported that global climate change has eclipsed biodiversity conservation as the top environmental concern among philanthropies and scientific researchers, as well as in media coverage. The shift is hardly news: A glance at the websites of the leading environmental organizations reveals that global warming is the central issue for most campaigning outfits. Over the past fifteen years, as reports about the scope of the climate crisis piled up, much of the green movement has pivoted from a focus on wildlands preservation to human self-preservation.

Forward on Climate ProtestPhoto by Steve RhodesClimate change activists protest against the Keystone XL pipeline in San Francisco.

Environmentalists’ urgency will be on display today in New York City as crowds gather for the People’s Climate March. Organizers are hoping to recruit more than 100,000 people to rally in Manhattan on the eve of a climate summit at the United Nations, with similar demonstrations to take place worldwide. Greens hope the global day of action will highlight the recklessness of the carbon barons and their political sock puppets, and jolt global leaders into action to stem greenhouse gas emissions.

By coincidence, the People’s Climate March will come just two weeks after the fiftieth anniversary of the signing of the Wilderness Act. That law is one of the signature accomplishments of the American environmental movement. It marked a sweeping extension of the national park philosophy by establishing a legal definition of wild places as areas “where the earth and its community of life are untrammeled by man.” The anniversary should be an occasion for celebration, yet conservationists find themselves in something of a defensive stance. The wilderness ideal is experiencing a “midlife crisis,” The New York Times declared this summer. Drawing two-dimensional lines on a map appears insufficient for the multi-dimensional threats of an overheated and overcrowded planet. Federal land managers are struggling with whether to manipulate wilderness areas to save certain plants and animals, while advanced technologies erode the wild’s remoteness and isolation. The once-solid certainties about the value of wild nature are melting under the glare of a hot, new sky.

Environmentalists are having to figure out where (or whether) wilderness fits into civilization’s twenty-first-century survival kit, a question that is forcing a split among the green …more

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